Representation by Karen Anne Hewison
- Date submitted
- 29 March 2024
- Submitted by
- Members of the public/businesses
REASONS FOR NOT APPROVING RWE PROPOSALS FOR SOLAR FARMS and information from the NPPF provision paragraphs As a general rule, it takes about 200 acres to generate the same electricity by solar panels as ONE North Sea wind turbine. This represents a grossly inefficient use of precious land, whatever its quality. National England issued the GUIDE to assessing development proposal on agricultural land (February 2021). LPAs should use the NPPF to make decisions about the natural and local environment to: • protect and enhance landscapes, biodiversity, geology and soils • recognise soils as a natural capital asset that provide important ecosystem services • consider the economic and other benefits of BMV agricultural land, and try to use areas of poorer quality land instead of higher quality land • prevent soil, air, water, or noise pollution, or land instability from new and existing development The ALC have graded England and Wales land and given categories as Best and Most Versatile (BMV) and land with 1-3a and these ratings should be used when considering planning proposals. The areas proposed for Byers Gill fall within the top ratings. The proposed Byers Gill Site C, D, E and F and the small section south of Coal -Bank will completely surround the village of Bishopton which is a conservation area. The total area of the combined 6 sites is approaching 2000 acres of arable land resulting in a loss of fertile farmland thereby reducing the UK’s valuable food production capacity and exacerbating food insecurity (now also critically affected by the ongoing war in Ukraine). This issue alone should be sufficient reason to ban solar farms on fertile farmland. In addition, the construction of solar farms requires the removal of top soil to a depth of 25cm thus rendering 2000 acres useless as farmland after the 25 – 40 years of operation of the solar farms. Solar farms generate ‘ragged’ electricity because of the random incidence of clouds or overcast skies which restrict electricity generation from the panels. In addition the panels only work by day whereas demand for domestic electricity goes on for 24 hours. Hence the necessity for expensive battery storage which has very limited storage duration, as well as a propensity to burst into flames With hardly any electricity generated during the winter months, the average energy produced by a solar farm is only 11% of the installed capacity of the panels. This ia another gross inefficiency. In comparison, a wind- turbine generates over 40% of its rated output throughout the year. Being renewable does not mean being zero carbon. The embedded carbon footprint (ECF) of a solar panel is 50 gms of CO2 per kWh generated, while the ECF of a wind turbine is 7.5 gms per kWh. 50 gms is much further away from nett zero than 7.5 gms. Solar farms produce their maximum electricity in the summer when demand for electricity is at its lowest. Wind turbines produce their maximum electricity in mid- winter when demand for electricity is at its peak. Solar farms have no connectivity with the National Grid because they ‘hook in’ to the low voltage regional distribution network. In contrast, wind turbines have the following - two high voltage cables connecting with Norway’s hydro- electric system; two cables connecting with the French grid; one high voltage cable between a) wind farms in the northern part of the North Sea and b) those in the southern part of the North Sea to instantly balance UK supply and demand in the event of outages. The Government has already indicated its support for North Sea wind and its lack of support of solar farms by offering £225m of incentives for North Sea wind compared with £3.3m for solar at the recent Contract for Difference (CFD) auction. This indicates that Government is 7 times more confident in using wind power to meet zero carbon by 2050. Wind power expansion has been constrained so far by the depth of the North Sea. The recently announced Sea-Green project, just off the Scottish coast, set a world record for the length of the legs under their new wind turbines. But, now that floating wind turbines have been introduced, this opens up the whole of the North Sea for future wind turbine development. In comparison, the development of solar farms is seriously restricted by their profligate use of our scarce countryside. WIND POWER is the future for renewables. This proposal will be the largest close concentration of solar farms not only in the UK but in Europe. There are significant risks of fire and explosion from thermal runaway from Lithium-ion batteries. The storage for the Byers Gill sites combined will be one of the largest in the country. The explosion at the BESS facility at Carnegie Road, Liverpool was a result of a failure within one of the battery racks in one container which led to a thermal runaway which in turn produced gases within the container culminating in a large explosion with parts of the container being blown across the compound to a distance of 23m.The main fire took 6 hours to bring under control but the continual recycling of heat from the Li-ion batteries remained an issue and defensive fire-fighting continued on-site for a total of 59 hours. The fire and explosion were deemed to have been caused by the failure of one or more battery units, but the root cause of the battery failure remains unknown. The Liverpool site had only 3 BESS containers and this proposal will have significantly more. A fire suppression system had been fitted. The report stated there was a significant risk to emergency responders. Battery safety is a serious planning consideration for the Byers Gill submission. OTHER SIGNIFICANT CONCERNS During construction daily there will be a large number of HGVs on a minor road network. Over and above the construction plant traffic, there will also be a large volume of workers vehicle accessing the minor roads. Construction period time frame and daily working hours and how will impact on the metal health and wellbeing of the people in Little Stainton, Great Stainton, Bishopton and that of the local farmers. The nearby primary school in Bishopton will be impacted by the construction noise. Clearly the impact to all local residents will be significant. All the above implies the Byers Gill site proposals should not be granted a DCO on the basis they are not Carbon neutral, are relatively inefficient and do not accord with the government strategy as set out in the recent energy security strategy namely that large schemes should be sited on lower value land Mitigation effects on visual aspect will have little impact since trees any hedgerows or tress that maybe planted to try and limit the adverse impacts will have little effect through the early part of the scheme for at least 15 years. It would not be possible to mitigate every adverse effect due to requirements of the solar generation and it will have a major adverse and significant effect on the village of Bishopton which will be surrounded at every outlook. 4. NOISE Chapter 11 of the Environmental Statement – Noise & Vibration 4.1 Chapter 11 is prepared by AECOM. 4.2 There are a number of NPPF, NPS, EN3 and EN1 guidelines NPPF state “proposals should demonstrate they mitigate impacts such as noise”, “prevent new developments from contributing to or adversely affected by unacceptable levels of noise pollution”. The properties most affected by the noise are near Bishopton. Apart from the during the construction phase taking place over a long period, noise and vibration will come from inverters, transformers and switch gear. This is an adverse effect of the scheme. Taking all the above in to account how detrimental will this noise pollution be to the “Mental Health” of the residents of the farms and villages and the surrounding area. IN ESSENCE, THERE IS NO JUSTIFIABLE REASON FOR CONSTRUCTING SOLAR FARMS ON PRIME ARABLE LAND. FOOD SECURITY IS PARAMOUNT (NPPF) THE PRESUMPTION IN FAVOUR OF SUSTAINABLE DEVELOPMENT See NPPF paragraph 11, sub paragraph (d) for decision taking when there is no up to date development plan. (d) promote and support the development of under-utilised land and buildings, especially if this would help to meet identified needs for housing where land supply is constrained and available sites could be used more effectively (for example converting space above shops, and building on or above service yards, car parks, lock-ups and railway infrastructure. Clause 1 Permission should be granted unless the applications of policies that protect areas of particular importance provide a clear need to protect fertile farm land in order to maximise home food production unless something better could be done with this land. OUTCOME 1: LEGITIMATELY REJECT SOLAR FARM PROPOSAL Clause 2 Permission should be granted unless any adverse impacts of refusal would significantly and demonstrably outweigh the benefits, when assessed against the policies taken as a whole. The benefits of not having solar farms would mean that, first, fertile farmland for necessary food production would be retained and second, the countryside in the UK would not be unnecessarily industrialised and desecrated. OUTCOME 2: LEGITIMATELY REJECT SOLAR FARM PROPOSAL NPPF Paragraph 15 – Section - Conserving and enhancing the natural environment – 174 (b) (b) recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland Solar Farms can cause significant habitat degradation. To produce solar power on an industrial scale, you need a vast amount of land. Building solar farms usually means displacing large numbers of mammals, birds, insects, and other wildlife OUTCOME : LEGITIMATELY REJECT SOLAR FARM PROPOSAL All the above implies the Byers Gill site proposals should not be granted a DCO on the basis they are not Carbon neutral, are relatively inefficient and do not accord with the government strategy as set out in the recent energy security strategy namely that large schemes should be sited on lower value land. All of the above suggestions and details were provided by one of our residents helping. With the objection. • In addition we would suggest the following headings under which you could expand in your own words. • Cumulative effect of Multiple solar power generation schemes within a small radius most of which will be visible either from each other or all at the same time. • We all know the sensitivity of flood risk in our area this has not been adequately explored by RWE documentation and needs much more detailed consideration. • Huge effects on sensitive local equine businesses. Horses will not react well to the massive intrusion caused by highly reflective panels surrounding the area ( I am sure there are experts locally who can provide data to support this.) • Health & safety implications of large 40+ metre battery storage systems in very close proximity to both residential properties and the school. • How much is too much ! We seem to be targeted disproportionately simply due to the fact that there is an access point to the grid and willing landowners ready to rent their land and profit from the development at the direct cost of local residents many of the landowners are not locally resident so do not care. The landowners are the only people who will gain from these developments there is no advantage whatsoever t the local community and the proposed community fund is insulting given the effects this will have on the local environment. • Local heritage is being completely disregarded, conservation village status and changes to the area are being ignored. • The developments will inevitably lead to increased crime. This has been proven at other Solar power plants across the UK as criminals seek to benefit from the expensive infrastructure being installed. • RWE have been deceptive throughout the application refusing to meet with the community and being economical with the truth to suit there own ends. An example could be the battery storage systems full details of which have only just been released after the submission of the DCO documentation. There are many many more. • The Gold rush mentality of Solar power station applications seems to be out of control. If all of the developments currently submitted were approved then the publicised target would be massively exceeded. • It is clear from actual power generation publicly available that large scale solar power generation is extremely inefficient and regularly fails to achieve the advertised generation capacity. It will also be a power consumer in order to maintain battery charge during darkness / winter hours, again this is factual and can be proven. • The government has regularly announced that prime agricultural land will not be sacrificed in the drive to achieve nett zero. Whilst some of the land in Byers Gill development may not be prime agricultural land it is more than suited to the production of cereal crops which will be lost for ever. • Property values have been proven to fall as a result of close proximity solar power station development. Other NSIP which directly affect residents provide compensation or in some cases compulsory purchase agreements. For example HS2. This has not even been considered with solar power stations as they remain hidden behind the curtain of greenwashing something which the developers continually rely upon. • The notional bio diversity gains are regularly being disproven and ridiculous statements such as the grazing of Hens amongst the solar panels highlight the ignorance of solar power developers. • There are very few if any solar farms which have successfully incorporated sheep grazing amongst the panels. It doesn’t work and there is not legal requirement for landowners to do this. Why would they when the rental incomes from the solar farm surpass those which can be achieved from natural farming. • The developers advertise that the power stations will bring local employment. Once again this has been proven over and over to be inaccurate. The construction teams tend to follow the work around the country and are generally not local residents. • The panels and infrastructure equipment are largely imported and have dubious manufacturing origins in the Chinese slave trade. Given recent events why are we supporting countries who may well be trying to interfere with our own government. • The overall carbon footprint of solar power stations been proven to be highly dubious when considering the entire lifecycle of the development from construction to ultimate decommissioning and the use of rare natural resources. • If the solar power stations are so attractive why are developers actively discouraging/ stopping people from taking photographs surely the opposite should be true.Ref Whinfield solar power generation.