Sirius Planning Ltd 4245 Park Approach Thorpe Park Leeds LS15 8GB

0113 264 9960 www.thesiriusgroup.com

Planning Department Borough Council of Swanspool House Doddington Road Wellingborough NN8 1BP

Date: 23/11/2020

Our Ref: ARM1010/SCR

Dear Sirs,

REQUEST FOR SCREENING OPINION - PROPOSED SOLAR FARM ON LAND TO THE SOUTH OF B570, GIPSY LANE, , WELLINGBOROUGH.

I write to request a Screening Opinion under Regulation 5 of the Town and Country Planning (Environmental Impact Assessment) ( and Wales) Regulations 2017 (the EIA Regulations), to establish whether or not a planning application for the proposed development is considered to be ‘EIA development’.

The EIA Regulations state that requests for Screening Opinions shall be accompanied by a plan to identify the land, a brief description of the nature and purpose of the proposal and, if possible, effects on the environment. The following commentary provides a description of the proposals and a location plan is attached for reference purposes.

Introduction In order to address the damaging effects of climate change, we need to move away from burning our limited fossil fuel reserves to using more sustainable, cleaner, renewable energy sources. Large scale deployment of renewables will help the UK to tackle climate change, reducing the UK’s emissions of

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carbon dioxide by over 750 million tonnes by 20301. The UK is committed to meeting the legally binding target of net zero emissions by 2050.

The English Government’s recently published National Planning Policy Framework 2019 confirms that: “The planning system should support the transition to a low carbon future in a changing climate…” Solar farms are a simple and established technology providing a source of safe and clean energy which produce zero emissions when in operation. Solar energy is not only sustainable; it is renewable meaning that we will never run out of it. Solar also enjoys the highest levels of public support of renewable energy in the UK, with 89% of the public in favour2. Solar farms are an effective and an unobtrusive way of creating the electricity for use locally, with the panels having a low visual impact on the local landscape and creating no noise, pollution, bi-products or emissions. Their non-intrusive nature means that the equipment can be lifted and removed from the site and the land returned to its previous use.

The Site The site boundary covers approximately 65ha as depicted by the blue line in Figure 1 below, however, only circa 25ha will be used for solar deployment as shown by the redline on Figure 1. Please note the configuration of the redline boundary may alter as detailed surveys are undertaken and mitigation is required, but below is the preferred area based on current understanding of the site. It is not the intention to deploy PV across the full 65ha.

Figure 1: Site Location

The wider site is known to have been worked for ironstone in the 1940s and then backfilled with inert material.

1 DECC (2011) Overarching National Policy Statement for Energy (EN-1) 2 DECC Public Attitudes Tracker March 2019 – Wave 29

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North Joint Core Strategy identifies the site as being part of the Green Infrastructure Corridors and the north western corner of the site as part of the Nene Valley Nature Improvement Area

To the north of the proposal site beyond Gipsy Lane is a caravan park, the Irchester Country Park and a 4.5MW solar farm. The A509 runs along the western boundary beyond which lies agricultural fields and the River Nene. Bordering the south-eastern edge of the site are several waterbodies beyond which is agricultural land. An agricultural field lies immediately adjacent to the eastern boundary beyond which is the B569 and the village of Irchester.

Access to the site is via an existing field gate on the western boundary of the site off the A509.

The Proposal Our client, Renewable Connections, is seeking to a develop solar farm across approximately 25ha of land with an export capacity of 26MW. The arrays will have a maximum height of 3m and will be aligned in east to west rows across the site. The mounting system will be either fixed south facing at an angle of between 10 and 35 degrees or the panels will be mounted on tracking units which whilst still south facing will slowly tilt to follow the sun’s path. The preferred option will be confirmed following detailed survey work.

The proposal will comprise:

 Photovoltaic (PV) panels;  Mounting frames – matt finished small section metal structure;  Inverter (accommodated on the mounting frames) and transformer (housed in prefabricated containers) and associated cabling (largely below ground);  Distribution Network Operator (DNO) substation, DNO meter point, customer substation and system;  Security fencing, sympathetic to the area, and infra-red CCTV (CCTV cameras would operate using motion sensors and would be positioned inward only to ensure privacy to neighbouring land and property);  Temporary set down area;  Internal service roads;  Site access during the construction and operational phases; and  Scheme of landscaping and biodiversity enhancement.

Part of the non-deployment land will be used as a temporary set down area during the construction phase. A proportion of the non-deployment area will be used for continued agriculture and also as an area for biodiversity enhancement. These areas will be confirmed as part of the planning submission.

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Whilst the deployment area will total approximately 25ha, the solar panels are distributed at a ratio of between 40 to 60% (ground cover ratio). This figure is dependent on local topography and other environmental requirements which will be determined through the survey and assessment work. Once operational the grassland will be managed through sheep grazing.

The arrays will be connected to inverter and transformer stations and cables will connect the transformer stations to the on-site substation. The Distribution Network Operator (DNO) will install the connecting cable from the proposed on-site substation via underground cabling in the highway using their permitted development rights as statutory undertaker. To secure the site, a fence approximately 2 metres high will be erected around the site and infra-red CCTV coverage will be provided. The fencing is likely to be deer fencing, or similar, so as to provide a visually recessive and less obtrusive visual element into the landscape; the exact specification will be agreed with the LPA.

The proposal will have a lifespan of 40 years, after which all equipment will be removed from the site and the land will be returned to its existing use.

The arrangement of the proposal will be informed by detailed environmental survey, however, to date preliminary ecology and landscape and visual surveys have been undertaken which have informed the indicative extent of the proposal site, as shown on drawing ARM1010/07/01 and Figure 1.

Initial Baseline Surveys Landscape and Visual

The potential impacts arising from the proposal on the local landscape character and visual amenity will be considered through a full Landscape and Visual Impact Assessment. The LVIA will be carried out in accordance with the Guidelines for Landscape and Visual Impact Assessment 3rd Edition (Landscape Institute and IEMA, 2013) (GLVIA 2013), tailored to whether an Impact Appraisal or Impact Assessment is undertaken, following the screening response.

A baseline landscape assessment will consider all national, regional and district landscape character assessments applicable to the study area. Effects upon the landscape resource of the site (a former mineral extraction area) and the wider study area will be considered. A series of visual assessment points will be identified and agreed with the Council's landscape / planning officer. At these locations a photomontage would be produced to illustrate the scale of the development and likely visual effects. Depending upon the sensitivity of other locations, further viewpoints could also be produced to illustrate the likely scale and landscape impacts of the proposal. Opportunities to provide landscape enhancements will be considered.

A previous screening response relating to solar development at the site (WP/19/00202/SCR) cited potential visual effects and the scale of the development as a reason for an EIA assessment, stating

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that the scheme …”would have a substantial visual impact (other issues would require scoping) due to its scale”.

It is unclear how these statements were previously concluded prior to any assessments being undertaken. To assist the council with this screening response a Zone of Theoretical Visibility (ZTV) and Viewpoint Photographs are supplied with this screening request.

The ZTV is a tool used to assist in determining areas where the development theoretically could and would not be seen. The ZTV serves to illustrate areas where it may be theoretically possible to view all or part of the proposed development. They are generated using survey height points of 3m above ground level set at representative locations within the deployment area. The ZTV takes account of the screening provided by buildings and woodlands (although hedgerows and scrub blocks are excluded).

The ZTV illustrates that visibility would be limited within the study area, focussed to the non-populated agricultural areas to the south and west of the site, and the road corridors which travel through. The viewpoint photographs illustrate some of the publicly accessible locations where visibility is to be expected, in many cases illustrating the actual limited visibility to the site from all but the areas immediately adjoining the site boundary. The scale of solar farm development in the locality is also evident in the views to the operational Wellingborough Solar Farm, located beside the large-scale prison site (under construction at the time of site visit). These views Illustrate how solar farms are visible within the local context. Due to the demonstrated restricted visibility and presence of existing near development, it is questioned whether the scheme would have a substantial visual impact overall.

Views into the proposed solar farm area are limited by mature boundary vegetation, a legacy of planting (and earth screening) implemented as part of the historic quarrying operations at the site.

The viewpoints attached to support this initial appraisal include:

 Viewpoint 1 – View north east from A509 at field access gate over the south western corner of the site area. Note open views expected to this small area only.  Viewpoint 2 – View south east from within site, close to Gipsy Lane over the north western area of the site. Road to the north bordered by mature trees and scrub, limiting visibility to the site from the road corridor.  Viewpoint 3 – View south from within the site, close to Gipsy Lane, over the northern area of the site. Road to the north bordered by mature trees and scrub, limiting visibility to the site from the road corridor.  Viewpoint 4 – View south east from gap in mature hedgerow at the junction of Gypsy lane and the A509. View over near field towards the site area, predominantly screened.

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 Viewpoint 5 – View north east from the A509 road corridor towards the site area which would be partially visible. Mature roadside and intervening vegetation is evident which limits views closer to the site.  Viewpoint 6 – Middle distance views north west to the site from public footpath close to Wollaston in the south. Partial visibility to the site area. Location illustrates views to operational solar (to give an indication of scale, in addition to views to Wellingborough and the prison site (under construction).  Viewpoint 7 – View west from Gypsy Lane on the western entrance to Irchester. Views to the site area screened by near variations in landform and intermediate hedgerows.  Viewpoint 8 – View east from crematorium site and adjoining Wellingborough Solar Farm. Location illustrates near scale of solar, developed in this visible location. Site partially visible to the east over the lower lying river corridor, a small scale feature in comparison.  Viewpoint 9 – View east from (footpath). Partial visibility to the site area, location illustrates the localised scale of the site, set within established features, views filtered by localised vegetation.

The Landscape and Visual Impact Assessment will guide any opportunities to provide landscape enhancements.

Ecology

A preliminary ecological walkover was undertaken in April 2020, a summary of the initial findings is presented below, and an ecology constraints plan accompanies this Screening Request.

GCN

The terrestrial habitat on site is potentially suitable for GCN as the fields were dominated by long sward grassland with patches of tussocky grassland and areas of tall ruderal vegetation. A Habitat Suitability Index Assessment of the water body adjacent to the southern boundary and the pond on the eastern boundary of the site was undertaken. The pond along the eastern boundary was identified as potentially suitable for supporting breeding GCN. There are also extensive opportunities for hibernating amphibians adjacent to the site boundary. Therefore, further GCN surveys will be undertaken.

Nesting Birds

The boundary vegetation (hedgerow and trees) provided suitable bird nesting opportunities, with nests observed across the site. In addition, the fields provided suitable opportunities for ground nesting birds, with species such as skylark particularly prevalent in the southern section of the site. Therefore, nesting bird surveys will be undertaken.

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Badgers

The walkover survey identified extensive evidence of mammal activity along the southern boundary of the site indicative of badger. Although no evidence of badger was found, mammal paths indicated there may be a sett to the south site of the water body. However, it was considered that works proposed would be far enough away from this to ensure there is no impact to a sett. In addition, there were numerous mammal holes along the embankment in the north of the site, although no signs that these were currently active. It was recommended that standard precautionary measures should be adhered to during construction works to protect commuting and foraging mammals as well as a pre- commencement of work checks.

Bats

Several boundary trees have potential bat roosting features and the site in general provided good foraging and commuting opportunities for bats. Trees will be retained and therefore there is no further recommendation for bat roosts surveys.

The information from the further ecology survey work will guide any mitigation and enhancement opportunities that can be worked into the proposals.

EIA Assessment Criteria The EIA Regulations contain two development schedules (Schedule 1 development and Schedule 2 development). Schedule 1 contains a list of development where an EIA is mandatory. The screening proposal does not fall within Schedule 1 development. Although solar farm developments are not specifically listed under either Schedule 1 or Schedule 2 developments of the EIA Regulations, Schedule 2 refers to “Energy Industry” categories and it is considered that the proposal falls within the category of “industrial installations for the production of electricity, steam and hot water (unless including in Schedule 1)”. The applicable threshold for EIA development in Schedule 2 exceeds 0.5 hectares, and, as such, the local planning authority must screen the proposal (by criteria listed in Schedule 3) to ascertain whether there are likely to be significant effects on the environment.

Schedule 3, the selection criteria for screening Schedule 2 development, is considered below.

Characteristics of Development a) Whilst the deployment site will cover an area of approximately 25ha, the limited height of the panels (up to 3m above ground level), their benign and ephemeral nature means it is unlikely that they will have an environmental impact. They do not have any complex or hazardous environmental effects either during construction or operation; b) The limited height of the solar panels and the likely scope of landscape planting (hedgerow reinforcement and tree planting) means there is limited opportunity for ‘significant’ visual cumulative impacts;

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c) The proposed development will have an anticipated lifespan of 40 years and requires limited maintenance, thus consuming limited resources; d) During the lifespan little or no waste will be generated during energy generation. Solar farms are at the leading edge of zero emission energy generation; e) The development would not create pollution or nuisance given the benign nature of the panels and proposal; f) The scale and nature of the proposal could not lead to major accident and / or disaster; and g) The development would not involve the application of substances or technologies that would create a significant risk to human health.

Location of Development a) The proposal site comprises agricultural land to the west of the village of Irchester. Whilst the deployment site of the proposal covers circa 25ha, the limited height of the panels (up to 3m above ground level), their benign and ephemeral nature means it is unlikely that they will have an environmental impact; b) The site has a rural setting located to the west of the village of Irchester and east of the A509. The proposal will have a lifespan of 40 years, after which all equipment will be removed from the site and the land will continue to be used for agriculture. c) The nearest statutory ecological designation is Irchester Old Lodge Pit SSSI located approximately 250m to the east of the site. The Upper Nene Valley RAMSAR, SPA and SSSI is located approximately 850m to the west, beyond the A509. In addition, a Local Wildlife Site is located to the south of the site. The detailed arrangement of the proposal will be guided by environmental survey work. Based on preliminary survey work to date drawing ARM1010/07/01 show the indicative extent of the proposal site. Providing preventative measures are implemented during the construction phase, potential impacts on identified ecology designations are not anticipated. A number of protected species surveys have been recommended from the preliminary ecological walkover and will accompany the planning application. The site is located within Flood Zone 1 which is of little or no risk of flooding. The nearest Listed Building is the Grade II listed Poplar Barn located approximately 820m to the north of the site. In addition, there are two Scheduled Ancient Monuments located within 1km of the site. However, given the separation distance and the nature of development, the proposed scheme is unlikely to have direct or indirect impact on these cultural heritage features. Under the Natural England Agricultural Land Classification Map the site is identified as Grade 4 (poor) with an area of Grade 3 (good to moderate).

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Characteristics of the potential impact a) Whilst the deployment area will measure c.25ha the construction of and the operational nature of a solar farm is unlikely to significantly affect an area of population; b) Due to the benign nature of the proposal impacts are not considered to be significant; c) The development site does not cross or impact upon local authority boundaries as impacts beyond the site boundary would be limited in extent; d) The magnitude or complexity of any impacts resulting from the proposal would not be significant; e) The appropriate technical assessments to accompany any planning application will demonstrate that any potential impacts will be limited; f) Following the operational period of the solar array, the site can be fully restored to reflect the context of the surrounding area; g) The site has a rural setting located to the west of the village of Irchester and east of the A509. Given the low-lying nature of the proposal, there is limited potential for cumulative impacts with other existing or approved development. Furthermore, environmental assessments to accompany the planning application will consider other potential impacts from the proposal and provide mitigation, where necessary; and h) The proposal is for a solar farm which will generate a significant amount of renewable energy and a scheme of biodiversity enhancement will form part of the proposal. Any potential impacts of the proposal are likely to be minor in nature; however, mitigation, such as screening planting or buffers to sensitive ecological areas will be incorporated into the design.

It is therefore considered that the characteristics of the proposed development (as detailed in Schedule 3) are not likely to have the potential for ‘significant’ environment effects and thus would not constitute EIA development. It has been demonstrated that an EIA is not required in connection with the above proposal.

Notwithstanding, the planning application submission documents will consist of the following:

 Application form and certificates  Planning Statement and Design and Access Statement which will include the following: o Description of the site; o Details of the proposed layout, appearance and scale, details of finished and specification; o Planning Policy Appraisal  Drawings including: o Site Location Plan;

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o Application Boundary Plan; o General Site Layout; o Panel Layout and Mounting Systems; o Infrastructure Details (elevations of transformers/inverter/substation cabins); o Fencing and Security Arrangements; and o Surface Water Drainage Provisions.  Appropriate technical and environmental assessments will be provided to support the planning application including:

Landscape and Visual Impact Assessment

The potential impacts arising from the proposal on the local landscape character and visual amenity will be considered through a full landscape and visual impact Assessment. Selected viewpoints will be agreed to demonstrate potential visibility of the proposal. Opportunities to provide landscape enhancements will be considered. Preliminary Ecological Assessment To understand the biodiversity value and potential of the sites and immediate vicinity a PEA has been carried out. This will inform the need for further survey work and also opportunities to improve biodiversity value. Cultural Heritage Assessment A desk top appraisal and site visit will identify potential heritage resources within the study area and the need for further survey work. Consideration will be given to potential impacts from the proposal on any identified resources. This will help inform future decision making, design solutions and potential mitigations strategies. Construction Traffic Method Statement Traffic generation is solely through the development construction phase. Details of vehicle numbers and routing will be provided within the application. A Traffic Management Plan will also be produced detailing mitigation and management measures. Flood Risk Assessment The development does not lie within any higher risk flood zones, but as the site is over 1ha then a flood risk assessment is required. Based on the FRA appropriate mitigation measures will be proposed where necessary. Noise Assessment of specific noise sources, in relation to appropriate guidance and standards (i.e. BS4142: 2014, BS8233:2014 and WHO guidelines) will be undertaken. The magnitude of impact and significance effects would be determined at nearest noise sensitive receptors. These receptors will be agreed in advance.

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Community Engagement A Statement of Community Involvement describing stakeholder engagement will be provided.

In conclusion, and having regard to all aforementioned factors, we respectfully request the Council’s formal response in the form of a Screening Opinion.

We look forward to receiving an acknowledgement of this request. If you would like to discuss any of the above matters, please contact the undersigned.

Yours faithfully,

James Cook Principal Planner For and on behalf of Sirius Planning Ltd

ENC: ARM1010/07/01 – Site Location Plan ARM1010/07/03 – Viewpoint Images 1-9 Ecology Constraints Plan

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