Representation by The British Horse Society (The British Horse Society)
- Date submitted
- 30 March 2023
- Submitted by
- Members of the public/businesses
Consultation Feedback re Cottam Solar Farm proposal The response below is from the British Horse Society however our volunteers in the county may also respond at a local level. The British Horse Society is the UK’s largest equestrian Charity, representing the UK’s 3 million horse riders. Nationally equestrians have just 22% of the rights of way network and are increasingly forced to use busy roads to access them. Between 01.01.2022 – 31.12.2022 • 2,943 road incidents involving horses have been reported to The British Horse Society • Of these, 66 horses have died and 129 have been injured • 126 people have been injured because of road incidents • 13% of riders were victims to road rage or abuse • 85% of incidents occurred because a vehicle passed by too closely to the horse • 75% of incidents occurred because a vehicle passed by too quickly This illustrates the importance of protecting, improving and extending safe off-road provision to help to prevent these numbers from increasing in the future. New development plans present threats and opportunities for all vulnerable road users: equestrians, cyclists, pedestrians, wheelchair users and mobility scooter users. The NPPF para 100 states: Planning policies and decisions should protect and enhance public rights of way and access, including taking opportunities to provide better facilities for users, for example by adding links to existing rights of way networks. The equestrian industry generates £4.7 billion of consumer spending, £5,548 per horse (BETA, 2019) is contributed to the economy benefitting local economies where equestrian activities thrive. DEFRA has recorded 5,599 horses in the immediate DN10, DN22, LN1 and DN21 postcode areas (2021), making a total of £31,063,252 contribution to the economy. There are livery yards in the area creating employment and using equine services (vet, farrier, feed, instructors, etc) as well as growing interest in equestrian tourism (‘take your horse on holiday’). Why is the permissive path described as ‘footpath’ rather than a multi-user route? The bridleway and byway network in this area is fragmented (with more provision in the Nottinghamshire side than the Lincolnshire side), therefore leaving limited access for equestrians unless they ride/lead/carriage drive on the main roads to reach the safety of off-road provision. The DAS 3.9.5 mentions consideration of permissive routes (as requested by the BHS in July 2022) although limits this to walking and cycling, a very limited offer considering the size and scale of the development; ways to include equestrians rather than excluding them should be the starting point otherwise the ‘community benefit’ does not benefit the whole community. How would risks on the highway during the construction period be managed? The construction period for a development of this scale is considerable – 2 years. HGV return journeys at the height of the construction period will impact on the volume of traffic on the road network locally. Already mainly 60mph roads with some sections of 30mph and 50mph, the additional traffic and the added complication of vehicles regularly turning into the access road will make the road higher risk for vulnerable road users in the absence of speed restrictions or other traffic calming measures. It is positive that the operation hours for construction are limited to avoid evenings although Saturday mornings would coincide with times that equestrians would be active on the lanes and PRoW. It is also positive that banksmen will be used for the access points for HGV’s. Any abnormal loads which may be transported should be notified in advance to allow equestrians to choose to avoid the area on that day. HGV’s are generally 2.5m wide and 4.5m high (some vehicles for component transportation significantly larger) which, on the road network local to the site, would sandwich a horse and rider between the vehicle and the hedgerow or ditch along the route with little room for refuge which may cause panic. Appropriate information/training should be provided to drivers/ development workers to give priority to users of the PRoW and country lanes. The additional signage during construction to warn traffic of equestrians and other vulnerable road users in the area, and ensure they are considerate in terms of vehicles stopping if necessary and allowing vulnerable road users users to pass safely, as suggested by the BHS in July 2022, is welcomed. The ‘Pedestrian Amenity’ (C6.2.14 ES Chapter 14_Transport and Access) has been amended to include cyclists but not equestrians – why have this group been excluded when horses/riders/carriage drivers can also be subject to fear and intimidation from MPV traffic? Layout The position of the inverters should ensure they are installed away from the highway. Sudden noise and continuous levels of noise can be a hazard for equestrians as horses are flight animals, therefore the further these elements can be located from the highway, the better it will be for safety. The potential use of tracker panels must consider the direction of glare from the panels in relation to the PRoW network and lanes/UCR’s in the vicinity used to ride, walk and wheel. The community benefit mentions walking and cycling networks at the exclusion of equestrians. According to BETA two-thirds of equestrians are women and Church et al (2010) found 37% of women who are horse riders are over 45 years of age and over a third would pursue no other physical activity. Developers should be looking at how to include this group, not how to exclude them. How will the design protect and enhance the existing public bridleways, byways and UCR’s and ensure they remain accessible during the project lifetime? Table 14.6 (C6.2.14 ES Chapter 14_Transport and Access) has counted walkers and cyclists on the bridleway but have equestrians been considered? The low usage from all users may be the result of poor access to the off-road routes, low density of PRoW and that often the routes are disconnected therefore not offering circular or longer distance trails. Surely riding, walking and wheeling should be encouraged in the area, not dismissed. Damage to surfaces of the PRoW (CTMP document) should be repaired within a timeframe, not open-ended. Also damage to the highway eg verges should be repaired in a timely manner to ensure that the whole width of the highway can be used by vulnerable road users. The PRoW Management Plan drawings are poor, using colours to annotate the PRoW that do not stand out clearly.