Representation by roy clegg
- Date submitted
- 28 March 2023
- Submitted by
- Members of the public/businesses
Objection to the provision of Solar Farms in the application entitled “COTTAM SOLAR PROJECT”. Please find below my objection to the above application: 1. Comments of the last three Prime Ministers It will be disappointing and disturbing if the Planning Inspectorate fails to recognise the significant comments of the last three Prime Ministers: Rishi Sunak, PM, has committed to link up with the Global Offshore Wind Alliance, which was highlighted at the recent COP 27 summit. The Prime Minister said “Offshore wind is the thing we are focussing on, along with nuclear, and we are now a world leader in offshore wind. It is providing cheap forms of electricity and energy for households up and down the country and, alongside nuclear, that is how we will transition to a cleaner grid.” Liz Truss, PM, Liz has said she believes solar panels should not be placed on land that could be used for livestock or crops to boost food production and security. Boris Johnson, PM, “If we’re going to get energy prices down and keep them there for the long term, we need a flow of energy that is affordable, clean and above all secure. We need a power supply that’s made in Britain, for Britain – and that’s what this plan is all about”. We are delivering on the 10-point plan, highlighting: - 1. Advancing offshore wind, 2. Driving the growth of low carbon hydrogen, 3. Delivering new and advanced nuclear power 4. Accelerating the shift to zero emission vehicles, 5. Green public transport, cycling and walking, 6. Jet zero and green ships , 7. Greener buildings, 8. Investing in CCUS, 9. Protecting our natural environment, 10. Green finance and innovation, “All of these steps will accelerate our progress towards net zero, which is fundamental to energy security. This is a transition which reduces our dependence on imported oil and gas and delivers a radical long-term shift in our energy with cleaner, cheaper power and lower energy bills”. 2. 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. 3. Sheer Size There are currently four proposals for industrial-scale solar farms in the area, covering over 10,000 acres of land. This is 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 almost 2 million solar panels mounted up to 4.5m high spread across 10,000 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. 4. 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 schemes in the area will take around 10,000 acres out of agricultural production for 50 years and will likely stay in. This will decimate local agricultural work force but will have a much wider 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. Evidence exists which identifies a 400-acre brown field site adjacent to Cottam Power Station, available to purchase without enquiries from a solar farm developer. 5. 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. Batteries will be housed in large containers. Faults can occur due to mechanical damage, heat, internal short circuits, and poor battery management. When a fault occurs it causes a chemical reaction that does not need oxygen to burn and is therefore very difficult to put out. The only way to stop the reaction is to cool it with vast amounts of water, more than is ever likely to be available at the site. 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. There currently exists other large scale Solar Farms in the planning process of all within a very small-time frame, and with overlapping of physical boundaries. 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. Solar Farms on a large scale is relatively new technology, and it is increasingly being operated by non-experts. The developers have failed to identify and deal with issues in respect of fire and Battery Equipment Storage Systems (BESS). Although we recognise that the likelihood of a fire or explosion occurring may be relatively low, the hazard is extremely high and potentially devastating. 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. This may well Change with the emerging regulations arising from Dame Maria Miller, MP, Bill No 152 to read a second time on the 24th of March 2023. Bill to make local fire services statutory consultees for industrial lithium-ion battery storage planning permission applications; to make provision about the granting of environmental permits for industrial lithium-ion battery storage; and for connected purposes. The Bill would ensure that industrial lithium-ion battery storage facilities are correctly categorised as hazardous, so that the Environment Agency, the Health and Safety Executive and the fire and rescue services would be statutory consultees when planning applications are considered. But HSE's existing role, under the PHS Regulations, the presence of hazardous chemicals above specified threshold quantities requires consent from the Hazardous Substances Authority (HSA), which is usually also the local planning authority (PA). HSE is a statutory consultee on all hazardous substances consent applications. Its role is to consider the hazards and risks which would be presented by the hazardous substance(s) to people in the vicinity, and based on this to advise the HSA whether or not consent should be granted. The BESS being proposed by the developers use Lithium-ion batteries which are innocuous when they function normally. But if they fail, a process called thermal runaway—what we would call a battery fire—occurs, and there is a complex chemical reaction. It can occur for many reasons: the battery may be overcharged, there may be outside interference, or the battery may have a design fault. The only way to stop a battery fire is to cool it down with a constant stream of water and wait for the fire to go out, which might take days, creating huge quantities of water containing highly corrosive hydrofluoric acid and copper oxide—by-products of battery fires. The larger the BESS, the greater the risk of a runaway fire. In the event of a fire, lithium batteries emit a cloud of highly toxic and dangerously high Hydrogen Flouride, which can spread over distances of 1-2 miles, potentially causing death or permanent visual defects, blindness or chronic lung disease and long-term illnesses to residents. Hydrogen fluoride goes easily and quickly through the skin and into the tissues in the body. There it damages the cells and causes them not to work properly. The gas, even at low levels, can irritate the eyes, nose, and respiratory tract. Breathing in hydrogen fluoride at high levels can cause death from an irregular heartbeat or from fluid build-up in the lungs. At lower levels breathing hydrogen fluoride can damage lung tissue and cause swelling and fluid accumulation in the lungs (pulmonary oedema). Eye exposure to hydrogen fluoride may cause prolonged or permanent visual defects, blindness, or destruction of the eye. People who do survive after being severely injured by breathing in hydrogen fluoride may suffer lingering chronic lung disease. 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 Health and Safety Executive, Local Authority and the Fire and Rescue will be responsible for the safety aspects. Especially dealing with Transportation, Storage. Recycling and Disposal. Contamination and size of water pond etc 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.” 6. Health and Wellbeing If you enjoy walking, cycling or riding through the countryside, and experiencing the health and well-being that it brings, then imagine the impact of being surrounded by solar panels and associated equipment on public rights of way and quiet country roads. Public rights of way may be moved or closed during the construction phase, which is anticipated to take between 24 and 36 months. 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. 7. The Impact of EMF on Marine Life, Flora and Fauna and Human Life in the Cottam Solar Project. The developer, Cottam Solar Project, has not made any consideration of the impact of Electro Magnetic Fields (EMF) on: o Marine Life. o Flora and Fauna. o Human Life. o Biodiversity Net Gain A separate document will be submitted to support the statement. 8. 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’. Bio-diversity improvements can only be achieved through careful design and on-going management, with each area requiring a bespoke approach rather than a 'one-size fits all'. The construction process will take up to 36 months during which time there will be disruption and damage to local habitats. Deer will no longer be able to run freely as they will be faced with miles of security fencing blocking their natural routes. Faced with a reduced grazing area, the deer will cause additional damage to ancient woodland, impacting other species, as well as inflicting more concentrated damage to crops. Natural habitats will be lost for a generation, or more. 9. 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. It should also be noted that the UK solar demand is part of a major global uptick in Photovoltaic. This means that there is a fight for solar products globally and ultimately most countries do not make their own materials including the UK. 10. 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. 11. Traffic The construction phase will take between 24 and 36 months. HGVs, abnormal loads and construction traffic will pass through local villages during this period. This will create 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 bio-diversity 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. 12. Financial Due Diligence It is evidently clear form the Financial Returns that neither Cottam Solar Project Limited nor its parent company Island Green Power have direct capital to support the estimated £880 - £890 Million pounds to develop the project or deal with the decommissioning of the Cottam Solar Project. The likely outcome is that if and when approved the Project will be sold or 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 land owner being made responsible for the identified decommissioning.