Back to list West Burton Solar Project

Representation by 7000 Acres (7000 Acres)

Date submitted
7 June 2023
Submitted by
Non-statutory organisations
  1. Summary Introduction: Overall, the limited energy security and decarbonisation benefits the West Burton Solar Project claims to achieve are outweighed by the significant adverse impacts it would have on the region (its communities, ways of life, landscape and its wildlife) and on the nation (in particular pressure on land use and food security). The West Burton Solar Project (WBSP) is one of four NSIP proposals in West Lindsey, Lincolnshire, which fall within a 6 mile radius which together would cover 10,0000 acres of farmland and become the largest solar complex in Europe, and one of the top few globally. Due to the unprecedented nature of this development and the significant impact on the area and communities, the four NSIP solar projects need to be considered together by the Planning Inspectorate, i.e. Cottam Solar Project, West Burton Solar Project, Gate Burton Energy and Tillbridge Solar. 2. Inadequate Consultation: The Public Consultation was insufficient/inadequate. Information was lacking and misleading. Access to and comprehension of information for all was limited. Therefore, those affected were unable to gain understanding of the proposals. 3. Adverse impact on visual aspect of landscape: The proposed West Burton Solar Project would have a significant impact on visual amenity in its own right. The combined effect of four large solar farms in one area of Lincolnshire would be overwhelming; solar arrays would become a devastating, dominating feature of our landscape. 4. Impact on Health & Wellbeing: The WBSP has the potential to have a significant detrimental impact on the general health and wellbeing of residents (rural mental health is a particularly important issue locally), depriving access to visual amenity, changing views, destroying agricultural jobs and livelihoods. There is the possibility of socioeconomic decline from the cumulative effect and size of these developments, which would then affect people’s health and wellbeing, which then has the long-term potential to impact on health inequality. Such impacts have not been appropriately considered by Island Green Power. 5. Socio-economic: The West Burton Solar Project fails to describe how proposed development could mitigate the harm through loss of employment and livelihoods caused by the development or contribute to local planning policies and actions to remedy the underlying socio-economic situation. 6. Opposition from local Parishes & Councils: All local Parish Councils and Meetings that have expressed a view to date are opposed to the proposed developments. Development at this scale, against the express wishes of local councils and their communities is undemocratic. 7. No consideration for community benefit: The West Burton Solar Project will provide power to the National Grid rather than local homes. It will displace agricultural jobs, provide few employment opportunities, and reduce local amenity, providing little or nothing in return. 8. Sustainability of Communities: Many small villages surrounded by the West Burton Solar Project have few opportunities for employment and very few amenities other than the open countryside landscape that it sits in. The scale of the WBSP would rob villages of this key attribute and erode the attractiveness of villages, driving some people away and serving to deter people from moving in, therefore reducing their capacity to sustain communities and populations. 9. Separation of communities in an industrial landscape: The large islands of development proposed for the West Burton Solar Project are, in terms of size, an order of magnitude larger than many of the villages they surround, i.e. Marton, Brampton, Sturton-by-Stow and Saxilby. This is compounded by there being 4 schemes within a close area. The partitioning of the countryside in this way effectively segregates rural villages and places them in an industrialised landscape. 10. Inadequate mitigation / screening: The West Burton Solar Project proposes solar panels which would have a height of 4.5m as well as extensive security fencing. At that height, the character of the land would undoubtedly be dominated by solar panels, which could not be adequately screened by hedgerows (at all) or by trees (for many years), Island Green Power propose to re-evaluate landscape and visual effects after 15 years, which represents a significant proportion of people’s lives. 11. Cultural Heritage & Archaeology: The area in which the West Burton Solar Development is proposed is dotted with rural historic parishes, within which many historic buildings remain, including several dating as far back as the Domesday Book. The impact of the proposed scheme to heritage and such cultural assets has not been adequately explored or mitigated. 12. Traffic Disruption: The volume of road movements and size of vehicles, particularly during construction, maintenance and decommissioning are not compatible with the local, inadequate road infrastructure. Again, there is a cumulative affect with the potential for 4 major solar developments in the same region. The West Burton Solar Project does not adequately consider the impact of traffic through rural routes and villages and the potential for disruption, damage, and noise. 13. UK Food Security: The land proposed to be developed for the West Burton Solar Project is productive arable land, as is the land associated with the three other large solar developments in the region. The impact of the West Burton Solar Project, and the cumulative impact of the 4 schemes on Food Security has not been considered, particularly in light of the circumstances of war, pandemic, crop disease and global warming (e.g. rising sea levels) on national and global supply chains. 14. Existing Land Productivity: The proposed area covered by the West Burton Solar Project is productive agricultural land, producing food for people and animals, as well as biofuels. The overall sustainability impact of displacing this production has not been considered, in terms of what production will be lost and the additional food miles and carbon impact of production being required elsewhere. 15. Impact on wildlife: The details provided by Island Green Power to date do not provide a thorough assessment of the potential harm to the ecology and biodiversity of the area. In addition, Solar farm biodiversity net gain claims are unproven in the UK at this scale. 16. Nature of the schemes is not truly temporary: Between the operational period of up to 40 years, plus a period of construction and decommissioning, a life-cycle of the development of around 50 years could never be classed as temporary. 17. Scale Effects: The project design fails to consider or mitigate the impact of the large individual parcels of the West Burton Solar Project, each of which dwarfs the villages they surround. 18. Lost appeal for visitors / tourism / new people: Development at the scale of the West Burton Solar Project would alter the character and appeal of the region to attract visitors, tourists, or new people to the region, particularly when considered in the context of the 4 proposed large solar developments. The development would be clearly visible from historic buildings, such as Lincoln Castle and Lincoln Cathedral. The project has failed to assess the potential impact of the development in this important regard. 19. Impact on Leisure & Recreation: There is an extensive network of footpaths, bridleways and isolated rural roads within the area covered by the West Burton Solar Project, which are used for walking, cycling, and horse-riding. The direct impact of the West Burton Solar Project, and the combined impact of the 4 proposed large solar projects on leisure and recreation have not been adequately considered. 20. Joint consideration of schemes: Because of the unprecedented nature of this development and the significant impact on the area and communities, the four NSIP solar projects should be considered together by the Planning Inspectorate, i.e. Cottam Solar Project, West Burton Solar Project, Gate Burton Energy and Tillbridge solar. 21. Failure to consider neighbourhood plans: The project does not consider the detailed work by communities in developing approved neighbourhood plans, including, for example aspirations for green spaces, open landscapes and the rural nature of villages. 22. Policy Landscape: While there is a clear case for solar playing a role in decarbonisation, there is no clear case for extensive displacement of farmland through the installation of large-scale ground-mounted solar farms. 23. Failure to Follow NPS: The proposed project has failed to follow the requirements of the current and draft National Policy Statements in a number of areas. 24. Pressure on Land Use: Many planning requirements call for effective land use, the re-use of brownfield sites and avoiding BMV crop land. The West Burton Solar Project uses no brownfield sites. Given the limited contribution to decarbonisation and the adverse consequences arising from using farmland at this scale, the West Burton Solar Project represents a grossly inefficient use of land in the face of ever-increasing pressures on its use. 25. Agricultural Land Classification: The group does not have confidence in the Agricultural Land Classification data published by Island Green Power for the West Burton Solar Project. Given the potential for a margin of error or change in the developer’s ALC figures, it is imperative that there is an independent soil analysis conducted to establish the accurate picture and to be certain of the methodology that has been followed. Aside from the sub-classification of land between 3a and 3b, there is also debate within the Government that all grade 3 land should be included in BMV. The application of the ALC classification only is flawed as it does not consider crop yield. 26. Failure to consider alternative sites: The proposed project fails in that reasonable alternatives have not been adequately considered, as is required by the EIA regulations and the National Policy Statements. 27. Misuse of NSIP process: Given the load factor of solar in the UK and the intermittency of power produced – and the fact that the development would provide no power when the country would most need it on winter evenings (i.e. it could not be relied upon when needed), its status of “National Significance” or strategic importance is questionable, and it is therefore a misuse of the NSIP process to develop the project in this way. 28. Compulsory Purchase: Given the flawed arguments surrounding the potential benefits of the WBSP development, as well as the failure of the developer to consider alternatives which would have fewer adverse impacts, the WBSP does not meet the necessarily high threshold to allow compulsory purchase. 29. Accuracy and fullness of information provided by IGP: Supporting information provided by IGP’s consultants and experts is partial and fails to objectively consider all aspects and implications of the development. 30. Combined impact of concentrated energy development in a single area: The combined impact of all solar developments in the region (NSIP and locally determined developments) would take a significantly higher proportion of land locally than the national average figure quoted by solar developers to illustrate how little land would be used by solar, thus the impact on the region would be disproportionate. 31. Limited benefits of solar (load factor & timing): that matching electricity supply with demand in the moment is an essential part of electricity supply, the WBSP cannot deliver on claims to power approximately 144,000 homes owing to the low overall load factor for solar power in the UK, along with its intermittency and seasonal variation in output. 32. No consensus about how much solar is needed: Given the untapped resource of solar on domestic rooftops (only 3% of domestic properties have solar panels in the UK) and commercial properties (which, alone could double the UK’s current solar capacity), there is no clear case for uncontrolled development of large scale, ground-mounted solar farms such as the West Burton Solar Project. 33. Questionable net effect of solar on CO2 policy objective by allowing uncontrolled solar development: Uncontrolled development of large-scale solar farms such as the West Burton Solar Project has the potential to limit the contribution of solar to carbon reduction policy. The incremental effect of “too much” solar, through uncontrolled development means that the incremental gain anticipated by the addition of each scheme will diminish, as each scheme contributes to provide power at the same time, beyond what is nationally required, thus diminishing the potential contribution to the CO2 policy objectives from each scheme. 34. Solar has the least impact on electricity price: solar provides power when demand is typically at its lowest in the UK, and along with the economics of supply and demand, this is when the prices are also typically at their lowest (at these times, already sometimes negative). The claimed economic benefit of solar on energy prices is, at best, therefore marginal. 35. Claiming to be able to power homes with solar and batteries at low cost is misleading: As a solution, for any electricity system, solar and batteries alone would be an uneconomic proposition, because there would need to be so much excess solar production capacity required to cater for intermittency, along with vast amounts of energy storage – which, together would render the concept unfeasible. 36. Claims of community benefit are exaggerated: The proposed West Burton Solar Project takes power generated at low voltages in parcels of land that surround villages, stepping up the voltage through transformers to connect directly to the National Grid at 400kV, rather than directly to local villages, hence, Island Green Power’s claims to be able to “repower the region with clean, green energy” are misleading. 37. Connecting solar directly to 400kV represents an inefficient use of strategic national infrastructure: using this connection to the National Grid for WBSP would sterilise the use of a high voltage substation connection and preclude its use by future high-power applications. 38. There is no requirement to connect solar direct to the National Grid: Because solar power is generated at low voltages, there are few restrictions to where it can be connected or located. That IGP have cited the connection to the National Grid at the West Burton substation as a starting point for the site location undermines the breadth of alternatives considered as part of the WBSP development. 39. Connection to National Grid: Congestion in National Grid connection applications process means that the likely connection date for the West Burton Solar Project is November 2028. In the WBSP PIER document, the operation date is 2026. It is therefore not possible to complete and operate the project in the timescales indicated by IGP. 40. Inefficient land use: Given the low solar gain, the WBSP constitutes a grossly inefficient use of land – let alone productive arable land and undermines the credibility of the developer to claim that reasonable alternatives have been considered. 41. Electromagnetic Fields: The developer, West Burton Solar Project, has not made adequate consideration of the impact of Electro Magnetic Fields (EMF) and no attempt has been made to reduce EMF’s and their associated impact. 42. Flood Risk and Soil Erosion: The potential for surface run-off and soil erosion from such a vast area of solar panels on this network does not appear to have been properly evaluated, particularly when considered in conjunction with other proposed schemes. Information available relating to flood management, drainage and soil erosion are therefore inadequate. 43. Long-term soil quality / BNG: Island Green Power claim there will be a 10% biodiversity net gain from the West Burton Solar Project, but have failed to explain how this would be achieved, nor is it clear what methodology or assumptions lie behind the assertion. 44. Role of Batteries: Island Green Power provide very little detail on the storage facility included in the proposed development. Operating in a separate segment of the electricity market, it is unclear therefore whether the proposed energy storage system can truly be considered to be associated development for the proposed solar farm. 45. Safety & Environmental risks of batteries: The safety and environmental concerns arising from battery development at this scale have not been appropriately considered, including through operation and transportation. Large scale battery installations have begun to be developed in recent years but have been susceptible to failures involving fires and the emission of toxic and flammable fumes. Resulting in environmental damage from toxic run-off. 46. Glint / Glare: The impact of glint and glare on aviation (e.g. RAF, airfields, gliding clubs), or other outdoor activities (e.g. horse riding, hunts) has not been thoroughly considered, as well as visibility from prominent roads. 47. Noise: It is unclear from the information provided by Island Green Power what noise pollution will arise from the proposed West Burton Solar Development, either from electrical equipment (e.g. battery and inverter fans), or from wind noise / resonance from the configuration of large panel structures. 48. Decommissioning Arrangements & Recycling: The West Burton Solar Project documentation provides little detail on the arrangements for decommissioning and recycling, nor the standards to which the developer would be held to at the end of the life of the project. That Island Green Power does not have experience of development at this scale, there is no guarantee the region is not left with the legacy of a disused solar farm liability at the end of the project’s lifetime. 49. Financial Due Diligence: It is evident from Financial Returns that neither West Burton Solar Project Limited nor its parent company Island Green Power have direct capital to support the estimated £800+ Million pounds to develop the project or deal with the decommissioning of the West Burton Solar Project. It is widely expected therefore that if approved the Project will be sold or further investment found. It will be important that the decommissioning is secured and be completed with the land being returned to its previous state. With this in mind it is strongly recommended that if the application is approved, it is conditional on the incumbent landowners ultimately being made responsible for the identified decommissioning as a backstop against unforeseen circumstances, e.g. financial default by the developer or its successor companies. 50. Sustainability and ethics in sourcing of materials: The U.S. government has identified forced labour in China as an area of concern for the solar supply chain. Furthermore, the process of extracting the raw materials for batteries requires large amounts of energy and water, often in mines where workers face unsafe conditions. Any materials sourced by IGP for the West Burton Solar Project should be truly sustainable, e.g. free of forced labour, where workers’ safety is paramount, and where the full environmental implications are understood.

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