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Representation by Aldington and Bonnington Parish Council (Aldington and Bonnington Parish Council)

Date submitted
12 September 2024
Submitted by
Parish councils

This is the initial response from Aldington and Bonnington Parish Council (ABPC). We represent the two parishes of Aldington and Bonnington. We wish to formally register our interest in the application, which falls largely within our parish (Aldington) and is of a size that will impact significantly on our community, our settlements, landscape and heritage. ABPC has recently prepared a Neighbourhood Plan for the two parishes of Aldington and Bonnington, which collectively make up the neighbourhood area. This successfully passed referendum on 15 August 2024 and will shortly be formally ‘made’ by Ashford Borough Council (ABC), at which point it will form part of the Development Plan for the Borough. We have examined the documents and know the site well. In the context of the national commitment to the net zero target (reducing greenhouse emissions by 100%) by 2050, whilst the Parish Council recognises the contribution that solar farms can make, as reflected in Policy AB10 of the Aldington and Bonnington Neighbourhood Plan (ABNP), we are concerned about the overall scale of the site in this location and of the potential impacts of the proposal as presented. We have set out our main issues and impacts below and would be grateful for the opportunity to discuss and expand upon these in more detail as the process progresses: 1. Location and size of development: Whilst the ABPC is not unsupportive of solar schemes (see ABNP Policy AB10), this application is of such a size and industrial nature that is considered inappropriate in the parish. The location is in a location currently categorised by ABC as green field/open countryside. ABC, in its overarching vision for the borough, states that “The identity and attractive character of the Borough’s rural area, with its range of attractive settlements, wealth of heritage assets and its expansive countryside, including the Kent Downs AONB to the north and the High Weald AONB to the south, will be conserved and enhanced” (Local Plan 2030 para 3,11). The principle of development is not established in this part of the parish. The topography of the site does not lend itself to development. This leads to point 2. 2. Impact on landscape character and visual impact: We consider that the development will have a detrimental impact on the rural landscape character of the parish. At a national level, NPS EN-1 para 5.10.7 is relevant in relation to protected landscapes, including National Landscapes (NL) (formally Area of Outstanding Natural Beauty (AONB)). Kent Downs National Landscape setting: The southern part of the neighbourhood area falls within the Kent Downs NL. The northern part where the application would be located, whilst outside the NL, forms part of its setting. Notably the Kent Downs NL Unit states that “the setting of the Kent Downs AONB does not have a geographical border. In most cases, the setting comprises land outside the AONB which is visible from the AONB and from which the AONB can be seen. The setting may be wider however, for example when affected by features such as noise and light”. The Kent Downs NL Renewable Energy Position Statement (https://www.folkestone-hythe.gov.uk/downloads/file/2221/9-18-kent-downs-aonb-renewable-energy-position-statement) states that “it is extremely unlikely that any location could be found in or within the setting of the AONB where the field-scale photovoltaics would not have a significant adverse effect on the landscape and the sense of remoteness, natural beauty and landscape character for which the Kent Downs are valued We do not believe this is the case for this application” (p.4, stress added by author). Furthermore Ashford Local Plan (2030) Policy ENV10 requires that for renewable energy installations, “the scale and design of renewable energy provision is compatible with the character and appearance of the area, having special regard to nationally recognised designations and their setting, such as AONB”. This is echoed in the ABNP Policy AB10, which requires applicants of solar installations to minimise and, where necessary, mitigate, their impacts on the local landscape. Aldington Ridge Landscape Character Area: The northern area of the parish (where the installation is located) falls within a number of Landscape Character Areas, as identified by Kent County Council. The Ashford Local Plan (2030) Policy ENV3a (Landscape Character and Design) requires development to demonstrate regard to such local landscape characteristics. Notably, the proposed application site coincides with Aldington Ridge Character Area, which runs north-west to south-east overlooking the marshes in places and straddling Roman Road. This high ridgeline topography, sloping away from Aldington village, allows for long distance views and, as expressed in the Aldington and Bonnington Design Guidelines and Codes (ABDGC) (underpinned by Policy AB8 of the ABNP), it is important that any impacts on landscape character are fully considered and that the landscape is preserved in any future development. Significant local views: Policy AB4 of the ABNP identifies 13 locally significant views in the neighbourhood area. These are views that have been identified by the community as important to them and which contribute significantly to local character. Several of these views would be severely impacted by the proposal. In particular the long-distance view (View 1) towards the village and ridgeline, which is one of the first and most striking views visible when entering the parish from the A20 and travelling into Aldington Village. This traditional Kentish view of rolling fields and woodland would be significantly impacted by the extensive solar panelling, which are of a height that would be challenging to screen effectively and in an acceptable timeframe. Further work on impacts from different parts of the parish and nearby homes affected would be helpful. Industrialisation of the landscape: The installation could cover an area of landscape equivalent to approximately 250 football pitches. In a rural, undulating landscape such as within Aldington, this will inevitably and irreversibly alter the overarching nature and character of the landscape. The introduction of tall panels, high security fencing, metalwork, battery storage areas, concrete and lighting will serve to industrialise the rural parish. The narrow lanes, which contribute to the rurality of the parish will, in areas, need to be widened to allow for delivery and construction traffic. Where the installation abuts the rural roads, security fencing will need to be installed, which will effectively enclose those lanes from their current wider views. Examples include along Bank Road, where the ‘tunnel effect’ of tall panels and screening could continue for some distance. ABC Local Plan Policy ENV10 requires that for renewable energy installations, “the development, either individually or cumulatively does not result in significant adverse impacts on the landscape”. We consider that the application as presented would result in significant adverse impacts. 3. Flood risk: Some parts of the northern parish are within flood risk zones 2 and 3. The underlying soils here are clay, and residents frequently experience significant levels of mud and water particularly in the winter months. It is unclear how this has been factored into the proposals and how flooding will be mitigated against. Assessing flood risk is a requirement of NPS EN1. This is also relevant in relation to the construction phase of the proposed installation, with large heavy-duty vehicles spreading mud and debris along the rural lanes. Such issues will need to be carefully planned for mitigated so as not to have a negative impact on the day-to-day lives of residents. The terrain in this part of the wider area is complex in terms of its nature and topography and we are concerned about the feasibility of the proposals, notably in relation to the ability of the Aldington flood relief reservoir to not be put at risk. We do not consider that weather and ground conditions have been adequately considered and addressed and would like the opportunity to discuss these further. Traffic management including construction phase: ABPC is concerned about the impact of the construction phase on the community. The Applicant considers that construction will take 12 months, but there is no detailed plan to substantiate this. We note from other similar projects (for example Cleve Hill in Kent), that anticipated timings may be optimistic. The roads into and around the parish are extremely rural in nature. They are windy, often with few or no road markings and narrow in parts. They contribute significantly to the rural character of the area, hedgerow-lined roads being a feature of the ABDGC . It is concerning that the installation will have no choice but to alter the nature and character of these rural lanes in order to allow access to the site, both during the construction phase and for ongoing maintenance. It is unclear as to how construction related matters, such as holding areas for machinery and equipment, have been considered. Parts of the parish continue to be farmed and there is, as a result, a high incidence of agricultural vehicles on the road. Again, it is unclear how this has been considered in the application. ABPC is concerned about the detail and accuracy of the Traffic Management Plan as presented. The PC has carried out its own road traffic survey over a 4-week period on Roman Road, Goldwell Lane, Calleywell Lane and Station Road by the Mill to ascertain ‘typical’ traffic levels in this area of the parish. Comparing the findings to the data provided by the Applicant, there are numerous discrepancies in terms of when traffic flow rate and timings of construction traffic along Goldwell Lane would be considered acceptable by the Applicant, compared to what would likely happen in practice. Noting that there are a number of key community facilities along Roman Road, including the school, fire station, post office and village hall. Furthermore any increase in traffic on Goldwell Lane would have a knock-on effect to Calleywell and Station Road, as potential feeder roads. Other immediate concerns relating to potential traffic impacts include: • Proposed access to site compound from A20 is the principle route into the village. The entrance into the parish from the A20 is a challenging layout where there have been records of traffic accidents. • A20 junction with Station Road is an accident blackspot approach onto Station Road will take full width of Station Road potential conflict with vehicles looking to exit onto A20. • Station Road is C class which at points between A20 and the proposed site compound have insufficient width for cars to pass HGV’s. • Station Road insufficient width for two HGV’s to pass each other. • Table of anticipated vehicle types and frequency misleading as movements are quotes as average per hour over the course of twelve months. • No indication has been given as to the number / frequency of tractor / trailer movements across Station Road, • No indication has been given as to the number / frequency of tractor / trailer movements on Goldwell Lane • No indication has been given as to the position of where the cable will cross Station Road to the sub station or the size of trench required or width restriction during • No indication as to the routing of the cable on Goldwell Lane or width of trench required. • Inaccurate information given as to the port of entry, Folkestone has no freight facilities or linkspan for ferries. • No contingency route given in the event of the M20 or A20 being closed due to an incident. • The proposed booking system does not take into account deliveries to Evegate Business Centre, the Villages of Aldington or Bonnington or farm traffic. • Station Road is principle route into / out of the village of Aldington for the emergency services. • The Baseline traffic summary is limited in its information as data was only collected over a period of one week. • Outline CTMP implies that Calleywell Lane could cope with increased traffic if delays or restrictions on Goldwell Lane • Haul Road traverses flood plain what contingencies to prevent compaction of soil / sinking of protection plates. • Mention is made of avoiding peak times for Caldecott School at A20 end of Station Road, no mention of school traffic for Aldington Primary School or the worker commute. • Outline CTMP traffic flows does not show any vehicular movements for construction plant, tracked plant tends to be wider than standard lorry width which would prevent oncoming vehicles being unable to pass. • Outline CTMP traffic flows do not show any fuel tankers, regular visits would be needed. • Outline CTMP traffic flows show no movements for vehicles servicing welfare facilities. We would like the opportunity to explore these matters in more detail. 4. Heritage Impact (above and below ground): NPS EN-1 note that “the construction, operation and decommissioning of energy infrastructure has the potential to result in adverse impacts on the historic environment above, at and below the surface of the ground”. The parish has a great number of heritage assets, both above and below ground. This includes a large number of nationally listed heritage assets, a number of which are located within the proposed site area. It is vital that the significance of such assets is not detrimentally impacted, as per national policy and ABNP Policy AB11. ABPC is particularly concerned that part of the proposed development will have a significant detrimental impact to the setting of St. Martin's Church, a Grade 1 heritage asset. There is an area of archaeological interest along Roman Road; 3m piling of solar panels could destroy such archaeological sites. It is vital that adequate investigations are undertaken. 5. Safety and security: The Parish Council is concerned about the impact of locating an industrial site in the rural parish in relation to crime levels. Our understanding is that such site do attract criminal activity (e.g. “Police in the UK observed a 93% rise in reports of solar-related crimes from 2021 to 2022” https://www.pv-magazine.com/2023/04/15/weekend-read-solar-crime-on-the-rise/) and this is a cause of concern for residents. Designing out such crime would inevitably require surveillance methods, such as cameras, which in turn will add to the industrialisation of the area. We would welcome the opportunity to discuss this in more detail, including how the Applicant plans to mitigate against crime, without impacting detrimentally on the landscape. 6. Lighting: Following on from the point above, lighting will potentially form one deterrent against crime. ABNP Policy AB5 (Dark Skies) supports the need for lighting to be carefully considered in all developments in terms of its impact on health (promoting better sleep patterns and reducing stress), enjoyment and appreciation of the night skies, wildlife (nocturnal and diurnal animals) and energy efficiency (reducing energy wastage). It is unclear how the Applicant plans to meet the ABNP requirements on this matter. 7. On-site battery storage: ABPC is concerned that no meaningful consultation on battery storage devices, particularly regarding fire risk, fumes, noise and visual impact, has been documented generally. This lack of evidence means that there could be heightened risks posed to the community, especially those living near to the site. The majority of the battery placements proposed by the Applicant are within 300m of residents’ homes, including Quarry House Care Home. There appears to be no justification provided as to why the battery placements are scattered in these locations, as opposed to in a single enclosure. This adds to the overall potential risk of containing any issues as well as the industrial nature of the scheme. 8. Alternative sites for this installation: In the context of this site being within the setting of the Kent Downs NL, we are concerned that alternative sites have not been fully explored. The ABPC would like the opportunity to discuss this in more details. Panels located in areas 20, 21 and 22: ABPC would like to register a particular objection to the inclusion of these ‘outlier’ sites in the overall proposal. Remote from the rest of the site, they are located in approximately 38 acres of good quality farmland. They are adjacent to Public Right of Way AE474, which is one of the most important footpaths in the parish connecting Aldington village and St Martins Church. This will impact the visual amenity of that historic footpath. Their construction will specifically impact Goldwell Lane for many months to allow machinery access and cable laying. This is a narrow lane with no road marking and which has a pinch point and blind bend at Woodleas Farm. The route is identified as a regular circular walk utilised by parents and dog walkers in the ABNP. There is no pavement so is identified as suitable for a shared use scheme and reduced speed limit. Finally, this area lies directly behind allocated housing sites ( S51, S52) in the Ashford Local Plan 2030 so, when built out, will be in close proximity to residential property. It is unclear as to why this detached site is included and considered necessary to the overall scheme. 9. Public Rights of Way: There is an extensive public rights of way network in the parish. The proposed scheme would affect at least 12 ancient public rights of way, with some being extinguished and many diverted. The enjoyment of walking along Public Footpaths will be greatly diminished by the 3m high solar panels, mesh fencing and CCTV cameras. This will potentially have a detrimental impact on tourism in the parish. ABPC is very concerned that the documents, as presented, do not clearly show where existing footpaths would be diverted (existing footpaths are not shown at all on the maps), which makes it difficult for residents to understand the likely impact of the scheme. One of the proposed footpath diversions would lead through the proposed biodiversity area; it is unclear what the impact on wildlife/habitats in that area would be, notably with dogwalkers for instance. Policy AB10 of the ABNP seeks to encourage schemes of this sort to retain existing public rights of way where possible and to incorporate linkages to neighbouring settlements (for instance Mersham). It is not clear that such opportunities have been considered by the applicant. Equally how cycleways through the site might be supported. The important footpath link from Aldington village to the church (AE474) is proposed to be closed for 12 months. This is a major footpath and this length of closures is considered unacceptable. 10. Biodiversity and Biodiversity Net Gain: ABC’s Renewable Energy Guidance (Version 2), advises that opportunities to improve biodiversity must be taken where possible to create and improve connectivity of habitats. This is underpinned in clause A iv of ABNP Policy AB10 (Renewable and Community Energy). Policy AB1 of the ABNP maps out key biodiversity features in the parish, many of which are located in the site area (see Figure 5 of ABNP). Parts of the proposed site are important documented habitats for a range of species(Redacted). Particular concerns include: • The impact of mesh security fencing that surrounds all areas of solar panels on the (Redacted) • The impact of solar panels on the higher ground in terms of skylark nesting sites. • The significant numbers of trees and hedgerows highlighted for removal in the Vegetation Removal Plan, all of which contribute to the green and blue infrastructure network noted in the ABNP (Policy AB1) • The ability of habitats – and related species - to flourish below the compactly arrange solar panels. 11. Noise impact: ABPC have concerns about the level of additional noise that will stem not only from the construction phase of the scheme, but also the ongoing management, for instance the battery storage. 12. Impact on tourism: The ABNP supports rural tourism in the parish (Policy AB15), which largely relies on the natural environment as the key ‘pull’ factor for visitors. The industrialising nature of the proposal will directly impact this. There are many bed & breakfast businesses, several camp sites, including one on Goldwell Lane, and a public house that would be directly impacted. This will have a knock on effect on the overall economy of the area. It is unclear as to the economic benefit to the area of this proposal – experience shows that job creation at such schemes is very limited outside the construction phase. 13. Decommissioning of the site: The decommissioning phase will have all the same issues as the construction phase for the community, bringing additional traffic, especially HGV vehicles onto rural roads. It is vital that the site is returned to its current states following decommissioning and at present, it is unclear as to how this would be guaranteed. 14. Inadequate consultation: ABC’s Renewable Energy Guidance (Version 2), advises that the local community should be fully engaged in shaping renewable energy proposals and schemes should offer direct community benefits. Whilst there have been two rounds of consultation and meetings of a Community Liaison Panel (CLP) set up by the applicant, the ABPC consider that these interactions have been unsatisfactory. The CLP meetings had a one-way flow of information, with many questions closed down or deferred by the Applicant. The Chair of those panels did invite items for the agenda but coverage of any issues raised was often dismissive. ABPC has requested a full set of Examination documents to be made available for viewing in Aldington Village Hall, which is a recognised community hub. A small subset was delivered but, with the majority of the detail contained in the circa 180 online document, those supplied by the Applicant did not fully represent the detail of the application nor explain what it will look like or how it would be made. With an aging population, a number of our residents either do not have access or do not actively access online materials. When printed, the keys to the maps are virtually impossible to read even when printed at A3 size. Some information, for instance the existing public rights of way network, is missing from the maps. We consider this a major barrier to participation locally.