Representation by Roy Clegg
- Date submitted
- 8 June 2023
- Submitted by
- Members of the public/businesses
Objections to the provision of Solar Farms in the application entitled West Burton Solar Project. 1. Consultation with Local Communities The Consultation process undertaken by the developer has been abysmal at best. They have failed to engage with the community as required in the planning process. The Local Council Councils have had little voice in the decision making and the developer has continuously, when asked for details, been tight lipped stating that the final details will be decided upon later or failed to respond to questions raised. 2. Sheer Size There are currently four proposals in some stage of planning the equivalent to 5,000 football pitches and 36 times larger than the largest solar farm currently in the UK. Almost 20km from one end to the other, with a perimeter stretching over 80km. Much of the land earmarked for development is currently used for agricultural purposes and needed for sustaining our food supply. The visual impact of the 4 proposed developments on the area may well be unbearable to residents and visitor alike. This development will employ solar panels mounted spread across many thousand acres of open countryside adjacent to many local villages. There will also be 2m high security fencing, CCTV and security lighting around the development. Additional equipment will be placed across the site in large unsightly containers. It is claimed that efforts will be made to screen the solar panels and associated equipment, it will be very difficult to hide these developments on rolling countryside. 3. Loss of Productive Land I am concerned about the loss of productive farmland and believe that no large-scale solar plant should be approved for development on greenfield land until the collective impact on the environment, biodiversity and food security is fully understood. The developer has not demonstrated that the land in the proposal is classified as 3b. Current Government policy is clear in that developments of this nature should prioritise development on Brownfield sites and low-grade land before considering development on productive farmland. Using productive agricultural land should be an absolute last resort. The proposed solar park will take out of a large amount of agricultural production and stay out of production for 50 years and decimate local agricultural work and impact on suppliers to farmers. When, and if the time comes for the land to be put back to agricultural production many of these farmers and trades will have disappeared and be lost forever. This is a significant effect not just on the farming community but also on the food supply chain. The developers would have us believe that the land being used is classed as grade 3B farmland, but grade 3B, has, in recent years, achieved crop rates as much as 40% higher than the national average coming in up to 12 tons per ha. During the construction, maintenance and decommissioning the land will become compacted, and receive no tilling or aeration for 50 years! This is not beneficial for the land, and we need to ensure the food security, that 10,000 acres can provide. 4000ha times the average wheat yield of 7 tons is 28,000 tons of wheat a year lost, or 1.4million tons over its lifecycle and £420m @£300 per ton in revenue. As shown in the figure below we are losing production at an alarming rate. It appears that the Secretary of State is proposing to redefine “best and most versatile” agricultural land to include lower-value 3b land, to protect it for growing crops and deter solar farms. This is a sensible move. Land graded 3b represents 29 % of our agricultural land and as many farmers will attest it can produce high yields of a variety of crops. In Lincolnshire the wheat yield is over 20%, set against an average of about 14%. Energy security can be achieved without compromising food production. Land is a finite resource must be used wisely. 4. Safety The Projects include battery storage facilities. The batteries will be lithium-based, which have a reputation for being unstable and very dangerous if they develop a fault. The chemical reaction caused when the batteries fail emits large amounts of toxic gas, mainly hydrogen fluoride, after which explosive gases are given off that can cause substantial explosions. The chemical reaction caused when the batteries fail emits large amounts of toxic gas, mainly hydrogen fluoride, after which explosive gases are given off that can cause substantial explosions. The overlapping of boundaries and interlocking of equipment and services of the solar farm developers will make it almost impossible to identify responsibilities for Health and Safety, Fire etc. The developers have failed to identify and deal with safety issues in respect of fire and Battery Equipment Storage Systems (BESS). Current regulations do not require BESS planning applications to be referred to the Environment Agency, the Health, and Safety Executive or, indeed, the Fire Service. The Planning Inspectorate have responsibility to determine and recommending action on each planning application but pass on the requirements of enforcements, if approved, to the Local Authorities to deal with. So, the situation that prevails is that a LPA cannot comment on some Planning Issues and yet find themselves being held responsible for such items after approval. If this is so, then, in the case of securing decommissioning, should the project be approved, the PI should make it conditional upon incumbent landowners for securing decommissioning and completed, with the land being returned to its previous state. In order to deal with any unforeseen circumstances, e.g., financial default by the developer or its successor companies. The larger the BESS, the greater the risk of a runaway fire. There are many other safety issues that need to be dealt with, including use of inverters, cable connections, solar panels, and end of life management plans for the solar farms. It is imperative that proper safety assessment is done prior to the application proceeding particularly given that the Local Authority and the Fire and Rescue will be responsible for the safety aspects. At the Energy Storage industry’s Summit held on 2nd March 2021 which reported on fire safety issues at BESS, the Deputy Fire Safety Commissioner of the London Fire Brigade, Charlie Pugsley stated: “If we know some things could fail catastrophically or it could have those effects, it’s going to be a difficult day if one of us is standing there in court saying we knew about it, but we didn’t do anything.” 5. Health and Wellbeing The impact of the proposal and also the cumulative impact of 4 solar farms on the health and wellbeing of local residents and visitors has not been considered by the developer and needs addressing. 6. The Impact of EMF on Marine Life, Flora and Fauna and Human Life in the Cottam Solar Project. The developer, has not made any consideration of the impact of Electro Magnetic Fields (EMF) on: o Marine Life. o Flora and Fauna. o Biodiversity Net Gain A separate document will be submitted to support the statement. 7. Biodiversity Net Gain The Developers claim they will achieve biodiversity net gain, but they give no details how exactly this will be achieved, other than to set aside some land for ‘mitigation’. 8. Levelling Up A view across the UK of large-scale solar farms under planning that fall outside Local Planning Authority remit. This clearly demonstrates that Proposed developments in the UK are significantly NOT levelled up. They are mostly located across the East of England, driven by capacity being freed up by the coal-power substations coming offline. 9. Flooding Laying new tracks and access routes during the construction process will cause compaction of the soil and ongoing maintenance will cause further compaction to the soil, which is already less aerated, reducing its ability to absorb rainwater. The run-off characteristics of rainwater from solar panels is different to that falling straight to the ground. Generally, rainwater falls evenly over a wide area. The run-off rainwater from solar panels would be concentrated, like rain running into the gutter of a house. When rainfall is heavy, gutters are deluged with water and overpowered. Run-off rainwater from solar panels will create channels and gullies in the soil, causing compaction and speed up the run-off from the site into nearby fields, roads, rivers, and other vulnerable areas. 10. Traffic During the construction phase HGVs, abnormal loads and construction traffic will pass through local villages creating noise, pollution, and damage to roads and verges, as well as extra risk for pedestrians, cyclists, and horse-riders. It is also likely to disturb the biodiversity on more rural lanes. Some roads will be too narrow and there will be a need for temporary, localised road widening, as well as a construction compound to transfer the abnormal size loads and HGV loads to smaller vehicles. The developer has not considered the mental health and wellbeing of the community.