Response to Green Hill Solar PEIR Consultation

Introduction

We are extremely disappointed that Green Hill has chosen to ignore our request to ensure that this consultation was not timed to occur while people are distracted by Christmas preparations and activities.  This is however not inconsistent with previous consultations with Green Hill where they have only really shown interest in identifying potential pitfalls that may hamper their proposal.  As a consequence we have not had as much time as we would have liked to assess the PEIR as we are volunteers that have to undertake such activities in our spare time.

We are also disappointed that the PEIR does not include the viewpoint that we requested on the Three Shires Way from which there are views as far as Leicestershire.  We note that on the Augmented ZTV diagram there is a location in the area that we have requested that is marked as showing between 50% and 75% of the scheme.  We hope that this will be included in the DCO.

General

We are concerned that in several places it is proposed that aspects of the scheme should be determined by professional experience.  Professional judgement or experience should never be used where a standard metric exists.  Where no metric exists, professional judgement or experience must be supported the rationale by which it has been concluded and the evidence upon which it is based should be included in the DCO.

Our concerns are reinforced by the contents of the PEIR such as where we feel that the metrics proposed seem to be designed to undervalue the perceived impacts of the scheme or where information is been presented in a way that does not fairly represent the impact of the scheme.

A 60 year permission is significantly greater than we have seen for other solar PV installations.  Such a long permission precludes returning the land to food production should the needs of improved food security increase as is predicted as a result of the effects of climate change.  The DCO should justify why such a long permission is necessary.

Although it is unlikely that it will occur within our lifetime, we are concerned that there should be a secure mechanism to ensure that at the end of the scheme’s life that decommissioning actually takes place.  Decommissioning will be a substantial and expensive project and unless a bond or other similar mechanism is put in place there is a significant danger that the owners of the scheme at this time will not have the resources to return the land to its former use.

We are similarly concerned that promised community benefit schemes do not always materialise and so would wish to see any such scheme set up in a way that cannot be lost when the scheme changes owners.

Chapter 2 EIA Process and Methodology

Para 2.4.13 suggests that the LVIA will only assess the scheme at 15 years.  This is not acceptable because this will not reflect the conditions that the community will experience for many years while the screening is ineffective.  We have seen solar schemes containing photomontages representing conditions at years 1 and 5 in addition to those for year 15 and we would expect the DCO to contain a similar level of detail.

It is very worrying that Table 2.1 suggests that sensitivity of “local” impacts should be Low.  This is bizarre and if there is any basis to justify this it should be presented in the DCO.

In 2.4.50 there is not specification of what is meant by “smaller schemes”.  Any schemes that have been omitted should be listed and the reason for their omission given.

Chapter 7 Climate change

There is little consideration of the adverse climate impacts of the scheme.

This scheme is proposed on primarily Best and Most Versatile land that is currently in use for food production.  In another NSIP that we have seen the loss of 20ha was deemed a significant loss and 20ha is a small fraction of the loss from this scheme.  We note that, like every other solar farm promoter, Green Hill suggest that the land can still support grazing but we are also aware that there are very few sites at which this takes place.  Under the Rochdale Envelope this suggestion should be discounted.

Since there is no less demand for food, the food currently produced onsite will have to be grown elsewhere.  This is likely to result in land currently not used for food production being ploughed up releasing sequestered carbon and reducing the biodiversity at the replacement site.  If the replacement food is imported then there will be substantial carbon costs incurred in transportation.

Users of their local PRoWs are unlikely to choose to walk through an industrial installation and are instead likely to travel by car to unspoilt countryside incurring a carbon cost in the process.

Chapter 8 LVIA

It is difficult to draw any conclusions from the PEIR on the likely level impact because the photographs showing the extent of the scheme do not indicate where the panels will be located within the view.  The photographs that contain outlines of the BESS are of more value but we are concerned that some contain isolated vegetation that hides views of the BESS and that had the camera been better sited these views would not been hidden.

The proposed study areas seem unduly restricted and not comparable with the areas used in other solar applications where a 10km study area seems more common.

It is important that the photomontages that form a part of the DCO should model the complexity of types of panels planned for each site and the inverters and other structures that will be present on each site.

Chapter 9 Ecology

So much of this chapter is uncertain that we do not feel able to comment upon it.

Chapter 12 Cultural Heritage

We are very concerned that the term “comprehensive change” seems to indicate the impacts will have to be extreme to be considered as a high level of harm.  This is not a term that we have come across before and seems to be designed to ensure that will not be met.

Chapter 13 Transport and Access

We are vehemently opposed to the proposed access route through Bozeat.  Access to site F is available through two other access points on the A509 and it is wholly unnecessary and unjustifiable to have a third route that will create a major impact upon our village and its residents.  This route can only be proposed for the convenience of the developer and should be removed.

The levels of sensitivity set out in Table 13.2 are unduly lenient and do not take into account the current traffic conditions.  Receptors that enjoy low levels of traffic are much more sensitive to increased traffic than those that already suffer high levels of traffic.  Bozeat has low levels of traffic and in our view are highly sensitive to traffic and we consider that the same would be the case for other receptors categorised in the Medium category.

The list of assessed traffic effects should be extended include the impact on residential amenity from noise, vibration and fumes when traffic volumes increase.

Route 80 is incorrectly categorised as of Negligible sensitivity even though it passes through residential areas within Bozeat and passes by residential dwellings and a Spa just beyond the village boundary.  This route is also commonly used by walkers, cyclists and horse riders for leisure and so should anyway be categorised as of High sensitivity.

We contest the rating of Route 81 as of Medium sensitivity because it has low traffic volumes and it passes through residential areas.

Chapter 14 Noise

The greatest noise nuisance to our residents is likely come be from the traffic if the proposed access through the village is retained.  The next most significant noise nuisance is likely to be to users of the footpaths and bridleways that pass through or by the sites.  We did not see any assessment of noise that would be experienced by users of PRoWs and the DCO should indicate predicted noise levels on the PRoWs.

We did notice that the noise modelling proposes a ground absorption factor of G=0.8 (soft ground) which will overestimate the noise absorption in summer and winter when the ground is hard.  The modelling should be based on hard ground.

Chapter 15 Glint and Glare

Glint and glare is most likely to be experienced by our residents when travelling, walking, cycling or riding horses on the local roads and when using PRoWs.  Horse riders or more importantly their horses will be particularly sensitive to glint and glare and so PRoWs and roads used by riders should be carefully assessed.

Slow users on country roads can be particularly vulnerable to collisions if faster users are temporarily blinded by glint or glare.  We are aware of a case where a cyclist who was fatally injured because a driver was blinded by the sun and the driver did not see them.  This means that country roads should be considered more sensitive than larger roads because of the nature of the conditions that they are likely to encounter.

Chapter 16 Air Quality

During construction we are concerned about the impact on air quality of the route through Bozeat is not removed from the scheme and this should be assessed in the DCO if the route is retained.  During operation we are concerned about pollution in the event of a battery fire we believe can last for several days and not the few hours claimed in the DCO.

Chapter 17 Socio-Economics, Tourism and Recreation

Agriculture

Although the farms based in Bozeat are not participating in the scheme, the lost jobs are local jobs and could also affect the local contractors, downstream processors and suppliers.  We find it difficult to believe that so few jobs will be lost and feel that this estimate should be evidenced.

The payments to landowners will not enter the local economy as they are absentee owners.  Thus they cannot be considered as mitigating local losses.

Affect on equestrian businesses

These local businesses rely upon the quiet rural nature of this area and the PRoWs which this will be lost if this scheme is developed; this poses and existential risk to these businesses.  The impact on these businesses during construction, repowering and decommissioning will be even greater than during the scheme’s operation and it is unlikely that they would survive the disruption even if they might be viable while the scheme was in operation.

The suggested levels of impact upon highly sensitive receptors set out Table 17.16 are not credible perhaps because they fail to account for the value of the rural nature of PRoWs.

Job creation

The DCO should detail the how skills training and qualification opportunities will be made available to the local population.  Unless these are actively promoted it is likely that skilled staff will be brought in from outside the area.

Formal recreation facilities (including sports, equestrian, and aviation): some individual businesses will suffer from significant impacts because will lose the attractive countryside upon which they rely.

The local highways network will suffer a major impact during construction, repowering and decommissioning.

Chapter 18 Human Health

The health assessment in the PEIR is only really relevant during construction and does not consider impacts over the 60 years of operation which is the majority of a lifetime.

The deterioration in the nature of the local PRoW network and country roads is likely to change behaviours and reduce their use for taking exercise.  This will reduce the level of healthy exercise of taken by residents because they will have to travel to more attractive locations which would require more time and effort than directly accessing the local network.

Chapter 20 Agricultural Circumstances

The scheme would substantially impact upon existing farming businesses particularly where tenant farmers have land removed from their landholding.  It is likely that some farms will be left with such a reduced acreage that they are no longer viable.

We do not find credible the suggestion in paragraph 20.8.6 that “It is assumed that where possible, the land required for solar panel fields remain functional during operation of the Scheme, with options such as grazing being considered therefore the 684.90ha (471.10ha BMV) required for panels has been excluded from the total infrastructure land take”.  It is common for solar schemes to argue that the land could be used for grazing but it is extremely rare for this to happen.  As such it is unsafe to give any credence to this claim.

There is no mention of cleaning during the operational phase.  The method and frequency should be specified since this could result in compaction and contamination of the soil.  It is noted in Chapter 26 that deionised water will be used and this should be required by condition to ensure that the ground is not contaminated by cleaning fluid.

A notable omission the condition to which the soils will be restored after decommissioning.  Appeals have found that soil quality is degraded by the operations involved in construction, maintenance and decommissioning.

Chapter 23 Major Accidents

The PEIR suggests that BESS fires would only last for a few hours.  The Liverpool fire lasted for nearly three days and the DCO should include a safety plan that could cope with a fire of that duration.

Chapter 25 – Cumulative Impact

The scheme will be perceived as at least 8 solar schemes and a BESS in a limited area.  This means that the cumulative impact should be assessed between the different elements of the scheme as well as with other schemes.

Sequential cumulative impact is not mentioned in the PEIR but this is a significant issue and will be particularly notable when travelling along the A509 where between the Warrington roundabout and Wellingborough where receptors will encounter Site G, three separate blocks of Site F and two further solar schemes at Irchester and Doddington.  When travelling north on this route the Burton Wold wind farm is also frequently dominant on the skyline which would reinforce the impression that the area has been handed to renewable energy generation.  Travelling from Bozeat to Lamport is another route where receptors would pass by many separate elements of the scheme.  Sequential cumulative impact should be assessed in the DCO.

A useful tool when assessing concurrent cumulative impact that we have seen used for windfarms are ZTV diagrams similar to the ZTV maps in the PEIR that use colour coding to indicate how many schemes are visible from each location.  We would expect this to consider each of the sites of this scheme as individual schemes.  Such diagrams should form a part of the DCO.

The proposed study areas for cumulative impacts are inadequate especially when assessing sequential impact where the area should be extended each time a scheme is encountered.

For Ecology and Biodiversity this needs to be considered according to the range of the species that would be affected.  In terms of aquatic species this should incorporate locations that could or would be affected by precipitation and/or pollution that originates from the sites.  This would mean that downstream risks need to be assessed particularly for potential pollution incidents.

Hydrology, Flood Risk and Drainage similarly needs to consider downstream risks and should not be scoped out.

Cumulative impacts for Climate Change, and Minerals also should not be scoped out because the cumulative loss of productive agricultural land reduces resilience to climate change and the sterilisation of multiple mineral extraction sites could lead to shortfalls and failure to meet needs.

Conclusion

Our greatest concern is that a route for construction traffic is proposed that would pass through the village.  We find this completely unacceptable and we do not see any justification for creating such an adverse impact on the village when the site has two other access points.  This route should be removed.

All the feedback that we have received from the parish is negative partly because of the proposed access route but universally because residents do not wish to see such an adverse change to our local environment.