Representation by Parochial Church Council of the Parish of Stow-with-Sturton (Parochial Church Council of the Parish of Stow-with-Sturton)
- Date submitted
- 22 May 2023
- Submitted by
- Parish councils
By way of background, and for those not familar with the organisation of the Church of England, the Parochial Church Council is the statutory body, and a charity exempt in law, responsible for the ecclesiastical parish of Stow-in-Lindsey. Sometimes this parish is also referred to as the parish of Stow-with-Sturton. The Parochial Church Council (hereafter PCC) is responsible for it’s parish church, St Mary’s Church in the village of Stow. This church, also known as Stow Minster, dates back to Anglo-Saxon times, with substantial parts of the present building dating back to 975AD. Around 1140 - 1160AD the east end of the building, known as the Chancel, was rebuilt. Part of the responsibility for the repair and maintenance was allocated to various land, the owners of which were duty bound to contribute as and when required. Today, the Chancel Repair Liability (hereafter CRL) lies 55% with the Church Commissioners, 34% with the PCC, and 11% with various pieces of land.The church is a Grade 1 listed building (NHLE 1146624) and attracts visitors from all over the world. For example, in the last month we have had visitors from South Africa, United States, Slovenia, Czech Republic and Australia (identified via our visitors book - though not all visitors sign the book). The World Monument Fund, a New York based international organisation concerned with the preservation of heritage buildings around the world, included St Mary’s Church in it’s 2006 watch list of the 100 most endangered sites in the world. This was a great priviledge and humbling to note that there was such international concern for the ongoing maintenance and preservation of the building, which contains a number of internationally significant features. The PCC, in association with the Priest in Charge, also has a duty of care for the souls and wellbeing of the people of the parish. The ecclesiastical parish of Stow-in-Lindsey covers the same geographical area as that overseen by the civil parishes of Stow and Sturton-by-Stow, except that there is a seperate ecclesiastical parish of St Edith’s Church, Coates-by-Stow which includes the hamlets of Coates-by-Stow and Normanby-by-Stow. It is with the above background that the PCC wishes to make the following observations on the proposals. Rights over Land - Chancel Repair Liability Specifically, regarding: West Burton (area 3) - the PCC is concerned about the proposals about the use of land at Stow Park and the implication this might have on our right to Chancel Repair Liability. Our concern is compounded in the formal notice of the proposed Section 48 of the Planning Act 2008 application that accompanied your letter of the 14th June 2022 in which we find the following statement at paragraph 4, 2nd bullet point: Compulsory acquisition of land, including interests in land, rights over land and imposition of restriction, powers to override, suspend or extinguish rights over land and powers for the temporary use of land On Tuesday 19th July 2022 the Freephone number [] was contacted at 9.16am by our Churchwarden, [], to seek clarification of the meaning of the above statement in relation to our right of CRL. He was advised by the operative taking the call that someone would respond to discuss the matter. At the time of writing no response has been received. In the light of the possibility that our right for CRL may be overridden, suspended or extinguished, and the potential (in the absence of due compensation) this has for the PCC’s ability to maintain a Grade 1 listed building of national and international significance the PCC must object to the proposal for West Burton 3 in relation to it’s location on land to which CRL is attached. There is a process for buying out or ‘compounding’ the liability. This would be dealt with under the Ecclesiastical Dilapidations Measure 1923 as amended by the Ecclesiastical Dilapidations (Amendment) Measure 1929. The Appendix to this letter outlines our particular area of interest. Cultural Heritage Specifically for both West Burton and Cottam: (Chapter 13 and supporting appendices in the main Preliminary Environmental Impact Reports (PEIR) for both projects are the sources). The PCC is concerned about the impact on St Mary’s Church, Stow (Grade 1 of national and international significance NHLE 1146624) which is within 5 kilometres of both developments (c.1.49km to NE of West Burton 3, and c.1.15km to W of Cottam 1). We note the PEIR for West Burton, paragraph 13.4.6 on page 395 Consequently, this PEIR will identify all designated assets ‘of the highest significance’ within a 5km radius of each of the five Sites under consideration. It is proposed that the assets thus identified will then be taken forward for further assessment in accordance with the methodology detailed in The Setting of Heritage Assets (Historic England 2017). This will involve a ‘sifting’ exercise at Step 1, whereby a suite of techniques will be utilised to ‘scope out’ from further assessment those assets where it is considered that views from, or towards, would not be affected by the proposals. Such techniques would include the use of Zones of Theoretical Visibility (ZTV) maps, viewshed analysis from selected receptors, analysis of online aerial and street view imagery, as well as on-site ‘ground-truthing’ where this is deemed appropriate and where access is possible. It is considered likely that this would greatly reduce the quantity of designated assets that would require more detailed analysis in subsequent stages of the assessment. and from Table 13.3, on page 399 the factors to be considered when assessing buildings of major significance (and in this the PCC consider the Grade 1 listed St Mary’s Church, Stow to be so categorised) i) Changes to key historic building elements such that the resource is totally altered ?ii) Comprehensive changes to setting (where this affects the significance of the asset). ? Regarding the above extracts the PCC notes also Historic England and Lincolnshire County Council Archeology Services are in ongoing discussions about impact assessment generally but these were not yet complete at the time of producing the reports. The PCC wish to record it’s concern about potential impacts on the visualisation from distance of St Mary’s Church, Stow, the impact on visitor numbers and on surrounding archeology that could inform the history of Stow, and request it’s further involvement in the ongoing discussions about the locations and size of West Burton 3 (as indeed it will so request regarding the nearby development proposals for Cottam 1 and Gate Burton Energy Park). It should be noted that St Mary’s Church, Stow also appears on Historic England’s “Heritage at Risk” register. The PCC would also point out that any change to the right over land for Chancel Repair Liability would materially affect the ability to maintain St Mary’s Church, Stow and thus it can be deemed that any change in CRL is a change to a key historic building element such that the resource is totally altered. General observations The PCC wishes to make the following general observations in exercising its concern for residents of the ecclesiastical parish od Stow-in-Lindsey. i) Concerns about the local infrastructure's ability to support the construction phase. Local residents have expressed concern about the inadequacy of class “C” roads, unclassified roads and green lanes to support the heavy vehicle movements required during the construction phase. Such roads, according to knowledgeable locals, were not engineered to support the quantity of heavy traffic envisaged in the projects and are therefore at serious risk of damage. Often quoted is a relatively recent incident of a large vehicle unable to avoid the roadside ditch in the “single” track section of the road between Stow and Ingham which closed the road for several days. Such closure of a well used local routes could easily repeated should these warning concerns not be heeded. ii) concerns about the impact on local residents’ mental health. There are two specific examples that have been reported to the Churchwarden. One where there is a potential suicide risk because of the proximity of a scheme to the resident’s home - the resident having chosen to live in a rural setting now finds that the proposed development to be disastrous to their wellbeing, and likely to affect the property value should the decision to sell be inevitable because of the disruption and changed environment brought about by the proposed development. In another report, a distraught farmer said that "If I don't rent them the land it will be compulsory purchased - either way I lose” and thus felt there was little value in raising objection to the proposed project. These two examples, one of which relates to the Cottam project, the other to the Gate Burton Energy Park project, nevertheless reflect the sentiments expressed to the members of the PCC to these massive solar projects that will surround our parish. iii) Overall the local area is in line for FOUR large schemes, not only Cottam and West Burton, but also Gate Burton Energy Park and now Tillbridge Solar. A fifth (but smaller) scheme, located at Stow Park, is also in the planning stage. In addition there are already two large solar farms in the area between West Burton 3 and the Gate Burton Energy park proposal.The PCC are not sure how all this fits with the Government strategy on Food security as described by Department for Environment, Food and Rural Affairs (DEFRA) recently published Government Food Strategy. The following is taken from the introduction to the strategy: We are the Department for Environment, Food and Rural Affairs. We’re responsible for improving and protecting the environment, growing the green economy, sustaining thriving rural communities and supporting our world-class food, farming and fishing industries. We work closely with our 33 agencies and arm’s length bodies on our ambition to make our air purer, our water cleaner, our land greener and our food more sustainable. Our mission is to restore and enhance the environment for the next generation, and to leave the environment in a better state than we found it. The massing of solar projects in the area is unlikely to “sustain thriving rural communities”. Elsewhere in the strategy the importance of retaining agricultural land as part of the food strategy is stated: The conflict in Ukraine has shown us that domestic food production is a vital contributor to national resilience and food security. Domestic food production can reduce the offshoring of food production to countries that do not meet our high environmental and animal welfare standards. Not only odes the Ukraine conflict bring into sharp relief the weakness of having dependence on relative few countires as major producers of a given food type, the strategy emphasises the need to avoid “offshoring” food production abroad.The strategy also recognises the need to treat farmers fairly As the custodians of our natural environment and important contributors to our food security, farmers must be treated fairly. The concerns raised to us by residents would question whether local farmers are being treated fairly. The expediency of accessing the National Grid at the Cottam and West Burton seems to be the overriding consideration for the proposed projects. iv) The oft quoted “levelling-up agenda” raises questions about whether there are similar such projects, in similar such concentrations being proposed elsewhere in the country, and thus to what extent this project is respectful of the aim to level-up across the country. v) At the Glasgow COP26 conference the Government was keen to address issues in Climate Change. Global warming is happening, and recent record temperatures in the UK (UK record of 40.30C at Coningsby on 19th July 2022) are evidence of this. The consequence of this is altered weather patterns, and thus inevitably alterations in the food production ablities of countries around the world. It is therefore important to retain food productive land for this purpose in those more temperate countries as the probabilities of equatorial, and thus hotter, countries to maintain production becomes evermore at risk. Another feature of the altered weather patterns is that historic data on sunshine levels etc. is no guarantee for the future expectation. It is therefore unwise to over proliferate massive solar schemes in the West Lindsey District Council area. vi) It is noted that there is an extension to the consultation deadline for West Burton 4 to 23rd August 2022 in respect to Agricultural Land Classification (ALC) arising from soil sampling revealed differences against the information used about ALC in the PEIR. It is therefore imperative that sufficient soil samples are taken across all land to be used within proposed projects to ensure that no Grade 1, Grade 2 or Grade 3a land is taken out of food production should these projects proceed. Consultation Process St Mary’s Church, Stow has been a hub for access to project materials during the consultation period Wednesday 15th June 2022 - Wednesday 27th July 2022, including copies of all paper based material except the lever arch files containing Appendices to support the PEIRs. There was no reason to believe that this was an oversight at the time, however today, Wednesday 27th July 2022 copies of all appendices were delivered to the church, together with the updated ALC data for the West Burton 4 site of the West Burton Solar project. To receive the appendices at such a late stage in the consultation process at a consultation hub (c.1.49km to NE of West Burton 3, and c.1.15km to W of Cottam 1) that is so close to the project sites could be construed as a deliberate attempt to disenfranchise consultees of relevant information. Not everyone has internet access or capacity to use “data sticks”, neither of which are user friendly when trying to cross reference material.