Representation by Clare Ella
- Date submitted
- 26 February 2023
- Submitted by
- Members of the public/businesses
I am pasting below the response that I sent to IGP during the PEIR consultation phase. In order to prepare that response I spent many hours reading their published documents. Due to the unfathomable/ structureless way in which the latest Application documents were originally uploaded to the PINS site, it has been difficult to see what - if any- amendments have been made that are relevant to the points I raised. I have requested a copy of the Application docs on a memory stick. Once I have had the time and opportunity to scrutinize the latest docs I will update my comments, using page and para refs for the updated proposal docs. I know, for example, that Green Lane off Ingham Road Stow (Cottam 1) has been widely publicized by IGP as removed as a proposed construction route, but I note in the small print that they still propose to use it for maintenance vehicles! The main issues and impacts I refer to in my note below, remain my main concerns. I was born in a house on Ingham Road Stow over 50 years ago, and have run, walked, ridden and driven along the local roads and tracks and played and picnicked in the fields and on verges over many years. I have been involved in Stow village affairs in various capacities including Stow Fun Raisers (which organizes events in Stow including community litter picks, BBQs, Christmas carols around the village tree and the annual family bike ride along local lanes and tracks that are not all public rights of way but have traditionally been opened for us to use by local landowners) and secretary of Stow Recreation Fund, which has funded many community projects including the defibrillator at the Cross Keys pub and flashing speed signs and metal village signs at each entry point into the village and benches in locations on popular walking routes. I now live less than half a mile from the edge of the proposed Cottam 1 site. As such I have a considerable amount of local knowledge and have the long term benefit of the village and its people and surrounding countryside at heart. I have a number of comments and questions and as the comments do not all fit easily into your pre-populated feedback form, and there is nowhere for questions, I am emailing this document to you with comments, and also some questions. I will highlight my questions in red and would appreciate replies to those. The rest is feedback for you to please note. Para numbers relate to the PEIR for Cottam and its appendices An overarching consideration, in the light of the recently announced proposal for a further large solar panel project by Tillbridge Solar, is that many of your calculations re cumulative effects will need to be re-considered as there will presumably need to be more work re shared cabling routes and there will be increased traffic, labour force and pollution considerations, with a further loss of local wildlife habitats etc. 3.2.73 – Will the further soil sampling results be made public? 4.5.3 Why are there still two different options for energy storage sites? There is a considerable difference in area used and length of construction time. Why has this not been resolved before the PEIR? 4.6.2 What further surveys are being or have been carried out? 4.6.4 ‘land between and under the arrays to be sown… with limited cutting.. some areas grazed’ – are any areas in the 3 Cottam sites planned to be grazed? Table 5.2 and 5.2.2 - the preference for solar panels is a site with a southerly aspect - as sites with a different aspect are likely to need a bigger development footprint as there would be an operational need to increase the distance between arrays in order to avoid overshadowing…. The plans/ maps illustrate (and the report goes on to say 5.3.2) that the Cottam 1 site favoured technology is East-West tracking panels in N-S rows. …. mostly 2 panel modules in portrait formation, up to 4.5 metres high, tracking the sun, causing glint & glare throughout the day What is the rationale for using E-W tracking panels which require a larger footprint, including moving parts which will themselves require power to move and pose a greater potential for maintenance issues with moving parts? The Gate Burton project is planning to use South facing fixed panels with a maximum height of 3.5 metres so why can they not be used on the Cottam and WB projects? What are the deciding factors? Why would companies developing sites virtually next to each other, on assessing all the latest info and technology, decide such radically different approaches are preferable? 5.3.3 goes on to say that in places South facing fixed panels may be required – but ‘fixed panels tend to have a greater ground cover ratio and therefore shading than tracker panels’ – so which is actually the bigger footprint, as you seem to contradict yourselves? Table 5.2 second row – ‘The Schemes location has been determined through the exclusion of land that the best available data identifies as being within an ALC category that is, or includes, best and most versatile land’. This is patently untrue. The Appendix 6a and 6b maps show a number of areas in Cottam 1 that are grade 2 - D1 has been excluded from the area covered by panels in the latest version but remains in the red boundaried area, whilst D5 and the parts of D6 and D7 that are grade 2 are shown as within the panel site. There are also a number of grade 3a areas - most of G4, F4 & F5, E4, D4 and part of D6. (E3 has been excluded). Why has ‘best and most versatile land’ still been included, when the PEIR says it has been excluded ? This is not a truth. Furthermore, George Eustice, Secretary of State for Food and agricultural affairs has recently stated that 3b is in fact classed as BMV land and therefore should NOT be considered as suitable for solar panel farms. In the light of that, how can you continue to press ahead with your application? 5.2.5 – not sure what the second sentence adds to 5.2.4 – should it read West Burton?? Table 5.5 – Avoidance of areas of surface water flooding greater than 1m depth. I witnessed a number of residents of Ingham Road giving evidence to your representatives at the Marton event and again to different representatives at a meeting in a private house, of flooding well in excess of 1m in areas to the north of Ingham Road that are currently included in your solar panel site area. There are photographs on social media from inside 4WD vehicles trying to drive on roads and looking towards the relevant fields. Your representatives were offered photos showing drowned sheep and the level of surface water. If this local evidence is considered, often viewable on local community facebook pages as part of road closure warnings etc or sadness at the loss of livestock, rather than the desk-top evidence that seems to have been relied on, you will see that the reality is different to what you are reporting, and basing your conclusions on. 6.4.5 You quote from the 7/04/22 Government energy strategy document, but don’t include all of the paragraph which states (my bold) ‘We will continue supporting the effective use of land by encouraging large scale projects to locate on previously developed, or lower value land, where possible, and ensure projects are designed to avoid, mitigate, and where necessary, compensate for the impacts of using greenfield sites. We will also support solar that is co-located with other functions (e.g. agriculture, onshore wind generation, or storage) to maximise the efficiency of land use. We have also included solar in the latest Contracts for Difference auction round and will include it in future rounds. So – are you saying that it is not POSSIBLE to use brown field or non-BMV land? Are these solar panel sites really avoiding greenfield sites apart from where NECESSARY? Do you have any plans for co-locating agriculture eg sheep -grazing between panels on these sites? What a surprise that your investors will be protected by CfD guarantees.. 7.4.5 – although not yet decided – it is admitted that the panels are likely to come from China. Is there no other source that is less likely to be reliant on ‘cheap labour’ (I saw you’ve signed up the Solar Energy UK ‘statement of condemnation and support’ but that is pretty toothless), and involving less of a carbon footprint in transporting it across China, across the sea and then from the port to the sites? 7.8.6 – are construction activities going to take place between 8-18.00 weekdays as set out here or 7-18.00 as set out in 4.5.6? Table 8.1 NPPF 2021 Para 98 – how does the scheme enhance the network of footpaths and bridleways in the Cottam 1 area? How does that sit with using Green Lane from Ingham Road to Coates Lane as a construction route? Similarly your replies to para 174 and also para 180c (NB the potential effect on the ancient pollarded oak waymarker at the north junction between Green Lane and Coates lane) do not appear ‘compliant’. Same comment re LP17 LP55 – no – the location is NOT suitable in terms of accessibility as I will cover this point further below.. Table 8.1 continued Policy DM10 – How can you justify using land just over the border into WLDC that would not be allowed in the Bassetlaw District?? If you apply the same criteria to land in West Lindsey the Scheme would not comply as ii) would not be correct – there are areas in Cottam 1 site shown on the maps as to be used for panels that are ALC assessed as BMV land. . How disingenuous to use land a few miles away that, but for an administrative council boundary, you would not be allowed to use 8.5.16 – Is there any preliminary information or data re lighting of the site during construction and operation? It is currently possible to walk many of the local lanes at night and, due to the distance from residences or streets with lights, have excellent night sky views. How will this be impacted eg. by lights at the construction sites during working hours in winter and overnight throughout the construction period, or generally during the operational phase? The Planning Inspectorate Scoping report highlights related lighting issues at 3.3.6, including the effects on hedgehog and bat corridors. Where in the PEIR is this addressed ? 8.7.23 Just one example of sadly many instances where you haven’t taken the time or trouble to correctly name local villages / roads/ tracks – or proof read your public documents…. Gillingham Lane? 8.7.32 Cameringham ? Thornton in the Fallows? 8.7.55 Thorpe the Fallows? 8.7.59 Scrampton? Heapam? 8.9.27/8 Gillingham Lane 8.9.38 Willingham and Willingham by Stow?? Do you mean Willingham and Stow? 11.5.4 Normandy?? 8.7.42 repeated 8.9.46 "the footpaths in the area appear well used..(and) because the network is sporadic the local lanes are used to supplement the network.." So yes, many pedestrians/ dog walkers/ runners/ bird watchers/ (horse riders on bridleways etc) use the local public rights of way, and where they don't connect up, we use the local lanes eg. Thorpe Lane, Fleets Road, Ingham Road, Green Lane.... But this is then contradicted at 14.6.30 "The level of pedestrian activity on the roads around the site is very low......the addition of HGVs to the network will affect the relative pleasantness of any pedestrian and cyclist journeys in the area..."but "the likely significant effect of the construction traffic to pedestrian and cycle amenity will be minor adverse and temporary, which is not significant" It's not the 'relative pleasantness' I'm concerned about, so much as the danger.. with no footways on most of the relevant lanes, and the width of construction traffic taking up most of the narrow lanes.. which you acknowledge at 8.7.42 and 8.9.46 are well used in connecting the PRoWs & paths. Why do you change your view of the level of usage when you want to support a different point? How do you calculate the effect as only minor adverse? The Planning Inspectorate Scoping opinion dated 9th March 2022 at para 3.9.3 states ‘ The Proposed Development site will affect a number of PRoWs but no surveys are proposed to understand the baseline use of these PROWs. Surveys should be undertaken to provide baseline data in relation to the use of the PROWs affected by the site, where appropriate, to define the change in characteristics of tourism and recreational use of PRoW as is required to define receptor sensitivity in Table 21.3 and the magnitude of change in Table 21.4.’ Where are the results of these surveys? Have they been carried out? Will they look at pedestrian, equestrian and bicycle usage? 8.7.112/3 Will these ZTVs and photomontages be made available to the public? At presentations representatives kept talking about the modeling and ZTVs but none were ever shown . 8.8.4 the CRC is still far too wide at this stage for meaningful comment on the proposed route 8.9.92 – vintage points?? 8.9.93- form locations?? – I guess you’re spending millions on this project so I hope you get a decent proof reader for the contracts and documents that really matter rather than just the ones that you don’t expect the rural locals to actually read.….. 8.9.97 – you acknowledge the high sensitivity residential receptors – yet seem to give little weight to their locations when carrying out your desk-top assessments of the impacts on their lives due to noise, dust, vibration etc 8.10.4 Table 8.6 – this will obviously now have to be re-written in the light of the Tillbridge Solar proposal 9.4.11 In discussing the Willingham to Fillingham road verges you acknowledge that ‘It is noted that the verge suffers substantially from over-run due to the narrowness of the road carriageway which leads to damage from overtaking and the passage of agricultural machinery’…… This road is typical of the back roads in the area (compare to lengths of Stow Lane/ Ingham Road and Thorpe Lane). Having seen the damage caused in places on the narrow sections, how do you conclude that these roads are suitable for construction traffic, and indeed the increased use due to workforce traffic? 9.4.15 – A habitats survey at just one time of year, just one nocturnal/crepuscular bird survey visit of all the land within the site boundaries late June/ early July, an eDNA test for GCNs of the 28 located ponds in June 2021 (when many other sites would be dry) – is this really a reliable way to carry out all of the wildlife data collection? Have local residents been asked for input? Have you approached any of the local farm workers, birdwatchers and dog walkers etc who live, work and exercise in these areas and asked what they see? 9.4.16 – Have the promised further surveys been carried out? Including those of ponds found to be dry in May-June 2022, ‘a thorough walkover survey of all accessible land within the Survey Area, and .. 30m beyond this, to collect baseline habitat inventory and condition information’ etc? 9.4.17. what exactly does ‘the survey effort and scope….reflects what is believed at the time of writing to be sufficient and proportionate to inform the evaluation of baseline conditions for this project based on our professional judgment ‘ mean in reality?? Why not ask locals for the videos and photos they have of bats at night, snakes during the day, owls at dusk, badgers found dead, frogs toads and newts seen near or in the Till, families of deer observed etc. Occasional visits by ‘professionals’ who don’t know the land will invariably miss things that locals are aware of. Desk-based surveys of reported sightings will never reflect the true situation on the ground as very few are reported.. People don’t report a sighting of an adder or grass snake or woodcock to Lincolnshire Wildlife Trust – they take a photo and share it on their social media pages!! 9.4.20 again, how can a desk based study be relied on to inform such sections of the PEIR? 9.4.58 I have seen a video of what is a regular display of bats flying at dusk at a location less than 100m from the Site and on a construction traffic route for Cottam 1. Again, desk based surveys are not appropriate to evaluate the local bat population. 9.4.85 – appendix 9.1 report at para 3.2.33 states ‘Wetted ditches and watercourses are likely also to be key habitats for otter and water vole, both being legally protected species recorded near to or within all Sites. This will need to be considered when carrying out any engineering works close to or within ditches or river corridor’ Where is this finding highlighted in the PEIR? 9.6.92 admits that they may be impacted through direct harm or disturbance during construction activity affecting ditches, watercourses and associated… habitat. 9.6.96 mentions limiting movements of construction vehicles within buffer zones – but not prohibiting them 9.4.87 again desk studies won’t show all sightings .. I saw a polecat when out on my bike down Ingham Road about 4 years ago. I told friends but it won’t show up on your desk study 9.4.94 again how can desk based studies be a valid means of correctly recording reptile populations? Especially in the 21st century! Where would locals who see grass snakes, adders, common lizards and slow worms record them? On social media – not by reporting them to the sources you will have used. Your conclusion at 9.4.97 that specific reptile surveys were not considered proportionate to undertake cannot be supported. 9.4.98 states there has only been one sighting of a grass snake in the sites - on the banks of the River Till – but the report at appendix 9.1 4.8.6 (illustrated as TN5 on the map for Coates South) records a sighting on the edge of a dry ditch, some distance from the Till. A sighting during the limited ground survey, together with the one on the banks of the River Till, surely indicate a much larger population and the likelihood of the presence of other reptiles? 9.4.101 There may be no desk-based survey records of other amphibians within 250m of the site but again locals will tell you of numerous sightings eg. near Pooh Sticks Bridge (the bridge over the Till to the east of the junction of the north end of Green Lane and Coates Lane). 9.5.5 You admit that the movement of the local deer population is likely to be impacted – but appear to just dismiss that as unimportant. 9.6.34 Woodland in close proximity to the array sites, haul routes and cable installation works would remain sensitive to degradation through accidental pollution events, dust deposition and vehicle over-run…. The PEIR acknowledges that there aren’t large stands of trees in the area – yet admits that the trees we have are likely to suffer adverse effects 9.6.82 The effects of the installation of solar panels on bat activity .. and their prey.. is largely unknown! 9.6.114 – ‘The solar panels also appear to be attractive sheltering features for brown hares avoiding predators and inclement weather’!! I had to laugh – are we supposed to believe that generations of hares would have fared better hiding from kestrels and rain under solar panels rather than the abundant hedgerows ….. 9.6.126 and 9.6.134 detail the likely adverse effects on skylark, yellow wagtail and lapwing populations, and admit it is not possible to predict the residual effects… approx 40 years ago there was an abundance of lapwing in the area, with a number of local fields regularly hosting large populations. These declined with the changes in farming practices and for a number of years they were rarely seen. The populations have slowly improved in recent years – just in time to be adversely affected again by your proposed projects. 9.6.142 can we really trust that there will be ‘sensitive timing of works’ around nesting sites and breeding/ nesting times? What guarantees will there be that supply timetables, transportation schedules and labour considerations won’t in fact take priority ? 9.6.147 and 148 probably illustrate the more likely attitude to ornithological considerations !! 10.3.3 – will the Delta-Simons report involve any consultation with local residents re actual flooding issues and observations? 10.4.14 – cottam 1 (west) still includes areas that are within flood zone 3 and 10.4.18 ‘The eastern extent of the southern parcel 3 is shown to be impacted with maximum flood depths above 0.9m … that bounds the River Till’ Why then did your representative at a meeting at a resident’s house in that area repeatedly argue that your reports DID NOT indicate that there was flooding above 0.9m? That area should not be included in the panel Site. 10.5.3 the report admits the potential for mud & debris to enter the water/ drainage systems restricting flow – affecting an already delicate balance which can easily lead to flooding if there is heavy rainfall. 10.5.22 summarizes that during construction there are a number of potential effects on surface water which require mitigation and the examples given in Tables 10.5 and 10.6 make very concerning reading – will all the mentioned mitigation measures be taken in reality? I remain unconvinced that they will reduce all the adverse effects to ‘negligible?’ Table 13.1 the Planning Inspectorate Scoping Report directed that the extent of trial trenching activity should be agreed as part of a written Scheme of Investigation with LCC. What a surprise that you objected to the expense and time involved in the extent of trial trenches that LCC have asked for. I’m pleased to see that at the meeting on 9th June the Planning Inspectorate supported LCC’s position that our local cultural heritage is more important than your profits 13.4.28 – Table 13.9 will now have to be re-written in the light of the Tillbridge Solar proposals 13.5.5 - supported by the report from Lanpro Services at App 13.1 - Anomalies have been detected in areas in Parcel D that are possibly indicative of unrecorded Late Prehistoric or Romano-British activity, and in Parcels F and G that possibly represent unrecorded enclosure systems of unknown date but those in F may be further Medieval activity. The detailed information included at eg. para 7.5 of Appendix 13.1 is very difficult to find:- that appendix would not download from the website – it just buffered repeatedly, and with no pagination of the appendices eventually supplied on a USB stick (not for even the appendices by chapters let alone individual appendices and sub-appendices) it has meant that it has taken hours to sift through all the extraneous material to find the relevant nuggets. The geophysical survey at Appendix 13.2 concludes that ‘the archaeological potential of the study site is high where there are the ten areas of activity’ Where are you publishing the results of the trial trenching that you are carrying out? Is it publicly available? Has a WSI yet been agreed with LCC? G1 is the proposed location for the very heavy transformer and storage batteries for Cottam 1 so the land preparation, abnormal load transportation and delivery, operation and decommissioning will all potentially destroy any archaeological remains that are not found prior to the commencement of the project. What are the criteria for this location being chosen – apart from distance from residences? 13.5.33 – Why has more work not already been done to comply with the Hedgerows Regs 1997? How can you define buffer zones, construction track routes and cable routes without identifying statutorily protected hedges? 13.8.1 – once again there are huge gaps in the evidence and information provided in this chapter – with the final paragraph repeating that it is not possible at this stage to identify all the significant likely environmental factors anticipated or identify residual impacts. How then are we supposed to give informed feedback on your proposals? 5.2.19 table 5.3 states ‘ Access – appropriate highway infrastructure is a material consideration as there needs to be appropriate provision to allow for the HGVs to access the sites during the construction process’ and table 5.7 ‘Access – vehicle to site for maintenance and construction and oversized loads to substation site’ There is no appropriate highway infrastructure to allow for HGV access to the sites at Cottam 1 Table 14.1 – in their responses both the Planning Inspectorate and Sturton by Stow Parish Council raised concerns about the weight restriction on Ingham Road/ Stow Lane, and the latter highlighted the local traffic chaos last year when a crane (whose driver followed his GPS rather than local road warning signs) tipped into the ditch on ‘the narrows’ – the section of Ingham Road that is single track road with passing places …. Your totally inadequate response (‘Weight restriction states “except for access’. Vehicles will not be through traffic) does not even acknowledge that the road and bridge structure/ integrity may not cope with the construction traffic (let alone the abnormal loads). Why consult with those who have local knowledge and then ignore their justifiable concerns? A report of the crane tipping off the road. https://www.lincolnshirelive.co.uk/news/local-news/giant-crane-stuck-ditch-causes-5462881 In addition a WLDC refuse lorry tipped into the ditch on Ingham Road in 2019 https://www.lincolnshirelive.co.uk/news/local-news/live-updates-police-rush-road-3023446 14.5.7 Cottam 1 - This is incorrect – there is a footpath alongside the A1500 alongside the eastbound carriageway from Thorpe Lane east as far as the right turn to Bransby. Table 14.5 – what about the Footpath from Coates, east towards Ingham onto Long Lane? What about the ProW along Green Lane from Ingham Road north to Coates Lane? Why have you not included these? 14.5.13 there are 2 Train stations in Gainsborough – Lea Road and Central 14.5.19 speed limit.speed limit (sic) not only is Ingham Road a single lane road, it is so narrow (with ditches each side) for a stretch that there are passing places. Where in the PEIR do you address or even acknowledge this? How can such a road be classed as suitable for construction traffic? 14.5.20 I presume you mean Fleets Lane and not Ingham Road at the beginning of the second sentence? Table 14.7 shows the results of an Automatic Traffic Count survey carried out in November 2021 :- including the figures of Stow Lane/ Ingham Road - 688 count, 25% HGV , Fleets Lane 63 count 25% HGV, Thorpe Lane 83 count, 37% HGV. Where is the definition of your traffic types? Does the count include pedal cycles and motor cycles? What defines an HGV in your survey? cars with trailers (including horse trailers)? Tractors? Along Thorpe Lane how would you know if it was maybe a tractor and trailer repeatedly leading manure to a heap, that was traversing your sensor and showing as an HGV? Anyone with local knowledge will know that the majority of that HGV % is likely to be agricultural vehicles, tractors & trailers, horse boxes & diesel deliveries etc, driven by locals and regular users who know the widths and restrictions on the roads. Similar considerations would have to be taken into account along Ingham Road and Fleets Lane. Would a horse box be classed as an HGV in your statistics? There are a number of equestrian facilities along Ingham Road and in Ingham and the surrounding area. Delivery drivers on regular routes, local residents and local farm workers are well aware of the passing places along Ingham Road and drive accordingly – anticipating needing to give way and knowing the size of their vehicles and whether they can fit into the length and width of a passing place. 14.5.29 the conclusion written by an obviously desk-based researcher who has never driven down Ingham Road or Thorpe Lane and has no local knowledge of the nature of the vehicles making up the figures in Table 14.7 is truly staggering. How on earth can anyone conclude ‘ The traffic flows recorded show that HGVs are already present on all local roads, which demonstrates a precedent for HGV use - AND SHOWS THAT THEY ARE SUITABLE FOR CONSTRUCTION TRAFFIC’ ? 14.5.31 – where was the data obtained from? Police Incident reports via a FOI request? Or Lincs Highways? There are 2 relevant points – the number of collisions (eg at the crossroads where Ingham Lane intersects the road into Ingham) appear to be under reported in your quoted statistics and maybe the low incidence of collisions causing injury is due to the fact that the majority of the users are locals and those who drive the roads regularly with an awareness of the potential hazards, and if 2 cars collide the likelihood of injury may be lower than if a vehicle is hit by a construction lorry or a minibus full of workers, driven by someone who does not know the roads. Appendix 14.1 – 3.11 describes Stow Lane but makes no mention of the single track stretch with passing places and the conclusion of the appropriateness of the proposed route at 3.27 is again unbelievable. App 14.1 4.2 – what do you mean by sustainable modes of transport for workers in this context? 14.6.5 – is that ‘experience’ of the deliveries for the materials for tracking panels or fixed panels per MW? Presumably due to their different construction and different footprint, over such a large area there will be a difference? Table 14.9 shows 23 construction traffic movements (46 two way) HGV for Cottam 1 but appendix 14.1 para 5.5 says 23 including arriving and departing vehicles. Is the PEIR, rather than the appendix correct? Table 14.10 shows 150 (300 two way) LGV/ construction workers movements for Cottam 1, but then Table 14.11 (which claims to reflect the baseline plus construction traffic) adds only 30 HGV movements (rather than 46) and 200 car/LGV movements (rather than 300) onto the A15 (1) counts on the top line WHY the disparity in figures in each paragraph/ table? Looking in more detail at the figures in Table 14.11 they do not make sense. Firstly the table is headed Baseline Two-Way Traffic Flows – but then seems to add only single way traffic figures from Tables 14.9 and 14.10 Using the single direction figures, if you have 200 more car/LGV journeys and 30 more HGV journeys on the A15 servicing the sites on average each day (as per the figures on the top line), with 23 of these servicing Cottam 1, some will go up & down Stow Lane and the rest up & down the A1500?.. Looking at the HGVs, if 4 turn off at Ingham Lane/ Stow Lane as per line 6, and then 3 of those go down the road to the east of Coates that leaves 1 to go down Ingham Road – but line 2 says 4? If 4 go down the A1500 and turn onto Fleets Lane (line 3) and then that 4 continue up & down Thorpe Lane (line 7) – where do the rest of them go off the A15? Line 5 looks at Willingham Road traffic – 4 HGV movements, but which road(s) have they used to get there, according to Table 14.11? Whoever is responsible for cooking up the figures in that table has not factored in that ALL HGV journeys to Cottam 1 will go on either Fleets Lane or Stow Lane before going off onto whichever smaller roads or access tracks they need to use to get to Thorpe Lane, Willingham Road etc. If you use the 2-way traffic figures, as were used in the initial ATC figures, then, unless I’m missing something obvious TABLE 14.11 AND ALL OF THE CALCULATIONS NEED RE-DOING? 14.6.18 is therefore flawed as Table 14.11 does not give an accurate picture and further assessment IS required. 14.6.25 How does the use of the Ingham Road single track road with passing places fit into the IEMA definition? Will you put traffic lights at either end of that stretch? How else will you ensure safe passage of construction traffic and fellow road users? If you do use traffic lights the length of that stretch of road will mean considerable driver delay. 14.6.30 there is no evidence ‘above’ that the level of pedestrian activity around the site is very low – see my comment above at 8.7.42 Appendix 14.1 figure 3.1 shows that one of the intended construction routes is a track that is known locally as Green Lane. It is a grassy cart track that you occasionally see a tractor using, that goes north from Ingham Road up to Coates Lane, just to the west of what is known as Pooh Sticks bridge. The route from Normanby, east down Coates Lane to the bridge and then down Green Lane is a very popular route for dog walkers, ramblers, birdwatchers, runners and equestrians. It is so popular that Stow Recreation Fund installed a bench at the corner for people to sit on and enjoy the (current) view to the north-east, and sit under the pollarded oak that is an historic waymarker there. Why is this grass track public right of way proposed to be used, when there is a gravelled/tarmac road already that goes from Ingham Road north to Coates settlement (the one with the post box and the sign for Coates church at the junction)?.. It may be that the bridge would have to be strengthened but it would be much less invasive, and would allow the uninterrupted enjoyment of the traditional village walking route ..If it was to be used as a construction traffic route and retained as a maintenance track, its character will be irreversibly lost. Looking at the plans numbered SK05 and SK06(1) in Appendix 14.1, how can the Public right of way remain open with the track planned to be used for construction traffic and general site access? Also, do the drawings suggest that the bench at the north end of Green Lane will be affected? There is the added issue of the close proximity of Green Lane to residences – particularly the old cottage to the east of the lane which would have to be carefully surveyed before any construction works were to be started on the lane as it is so close. There is also an equestrian business alongside the track which would be directly affected by the noise and vibration of the construction and the use of the track. Additionally that area is a wonderful place to sit and watch bats flying at twilight. I have very strong objections to this public right of way being converted into a construction track. Appendix 14.2 – Abnormal Loads access The dimensions given for AL to Cottam 1 - 7240mm length, 5000mm width, 4778mm height, 157,000kgs Using a 16 axle girder frame trailer and 12 axle flattop trailer All four suggested possible routes from Immingham to the transformer location are currently unsuitable for such large and heavy vehicles and present difficulties. Use of any of them would require remedial works/ removal of hedges/ protection of verges/widening of entrances etc to make abnormal load transportation possible. The suggested location is NOT suitable as it is not currently accessible on existing highways and tracks. I note that Green Lane is considered as a final alternative, but for all the reasons already given for NOT using it as a construction access, plus the added issues with an AIL, that is obviously not a realistic proposal. 15.4.4 – once again, although (very low) noise levels have been measured in different locations using a combination of permanent and 15 minute temporary methods, in the absence of hard data as to the likely level of noise caused during construction and operation, the actual analysis seems to be desk-based as, the threshold having been established, you’ve looked at the construction activities with the most potential to cause ‘adverse’ noise eg construction of tracks and hardstanding, installation of mounting frames, installation of panels, then measured the distance between residences and the source of noise, to ‘calculate worst case noise levels’… these ‘predicted levels will then be assessed against’ statutory/ BS significance criteria. The only thing that appears evidence based at this stage is the finding that the whole site area is generally very quiet with very little ambient noise especially at night! If tracking panels are chosen then the noise generated needs to be included as there are many residences potentially affected. 15.4.7 – yet another formula to predict vibration levels 15.6.3 – are we really supposed to believe that all these BPM measures will actually be implemented – seriously? ‘unnecessary revving of engines will be avoided’, ‘drop heights of material will be minimised’ 16.4.13 and 14 – why are your definitions of Medium and High magnitude for residents the same? ie if solar reflections experienced more than 3 months per year and more than 60 mins a day? Which is correct? 16.4.33 you are very dismissive of the impact of glint and glare on users of ProW. Not all users of ProW are pedestrians – some are cyclists or horse-riders and the impact on them is not addressed. If all of the proposed local solar projects go ahead it will become increasingly difficult to ‘move beyond the solar reflection zone with ease with little impact upon safety or amenity’ 16.5.4 How many dwellings do you predict as suffering a ‘medium’ impact due to glint and glare, with moderate and significant effect? No numbers are given. Is this based on Fixed South facing or tracking E:W panels as surely the impacts will be different ? 16.6.1 How high would the screening need to be to obstruct views of potentially reflecting panels (that are themselves up to 4.5 metres high)? 17.6.4 You admit there is a potential fire risk associated with lithium ion batteries. I am very concerned that you are using these for storage in the light of the June 2021 report ‘Safety of Grid Scale Lithium-ion Battery Energy Storage Systems’ by Dr Edmund Fordham, Dr Wade Allison and Professor Sir David Melville. Sources of wind and solar electrical power need large energy storage, most often provided by Lithium-Ion batteries of unprecedented capacity. Incidents of serious fire and explosion suggest that the danger of these to the public, and emergency services, should be properly examined and I am not convinced by your justification efforts to date. Where are the batteries you intend to use being manufactured? 17.7.4 Where in the PEIR do you consider the impact of dust on animals eg horses, sheep, bats, dogs and other pets, watercourses and domestic fishponds etc? 17.7.11 I’m sure that asthma sufferers and other ‘receptors’ affected by the dust are reassured that you conclude that the significance of the effects from dust will be negligible! 17.9.3 will this fire impact assessment report include an evacuation plan in the event of a fire on the Site, as there are many residences in close proximity 18.4.12 This conclusion is again desk-study based – just looking at reported statistics and projections. Have you actually looked on eg Rightmove in the areas of the Sites? There might be lots of large multi-bedroomed houses on the market but the supply of smaller homes is severely limited. Local developers are building far more executive homes than smaller flats and 2-3 bed homes. If construction workers are going to look to buy properties then I wonder which types of property they will be able to afford? And therefore reduce the pool of affordable properties for locals even more. 18.4.20 The majority of Cottam and West Burton sites fall within WLDC – where your research shows there are considerably lower than the average number of GPs per 100,000 population. An influx of working population during especially the construction phase will add to the pressure on our already overburdened local surgeries. 18.4.34 as the data from 2011 is irrelevant now, why use it? 18.4.45 Are these further soil test results available yet? 18.4.46 during a consultation session one of your representatives said that there will be no grazing between panels in Cottam and West Burton sites. Is that correct, as you argue agricultural land resource will not be lost .. with (grazing sheep and other small livestock below and between solar panels) ? and repeat that at 18.4.50 and 18.5.24 18.4.47 How much of the CRC is likely to be BMV land? 18.4.55 As the local ProW network is agreed to be important to the local population, why are you considering Green Lane as suitable to be converted into a construction route for Cottam 1? 18.5.7 The local schools may not agree with this assessment as, like the GP practices, they are struggling to cope with current populations 18.5.8 Look on Rightmove / Zoopla etc. There is NOT an excess of local housing certainly in the Cottam 1 area. Any properties that go up for rent – other than student accommodation – are taken very quickly. It is already very difficult for local people to find affordable housing. 18.5.9 Not just ‘tourists’ but family and friends of locals, looking for somewhere to stay when attending weddings and other community gatherings and events. 18.5.15 – how do you guarantee that the land will not lose any future potential ? that compaction or contamination will not affect it? 18.5.19 at 14.6.31 and other places in the PEIR it is promised that ProWs will remain open throughout the construction phase. Here it is threatened that the scheme could lead to the temporary change in character, diversion or closure of ProW near or on the sites or cable route.. This would definitely impact on local human health and wellbeing and I would strongly object to this 18.5.32 why can you not undertake to remove all hardstanding and concrete foundations on decommissioning so as not to degrade the quality of the soil? 18.5.35 have you made interested parties aware that permissive paths opened for recreational use may be liable to closure? The suggested permissive path in Cottam 1 area is of little benefit as it does not connect with any other PROW and is very short.