Application No. 13/05244/FUL, Solar Array at Poulshot Lodge Farm
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Wiltshire Branch, Kennet District Group Chairman: John Kirkman, Witcha Cottage, Ramsbury, Marlborough, Wiltshire SN8 2HQ Phone: 01672 520429; e-mail: [email protected] Application No. 13/05244/FUL, Solar array at Poulshot Lodge Farm For the attention of Morgan Jones, Case Officer. “The introduction of the PV panels on aluminium frames up to 3m high will introduce a new form into the agricultural landscape that will jar." Simon Robertshaw, Inspector of Historic Buildings and Areas, English Heritage, Letter 26 November 2013 We have commented previously (9 December 2013 and 9 January 2014) that the undulating and sloping site at Poulshot Lodge Farmis unsuitable for a large-scale ground-mounted solar array. As far as we can see from the new landscape section map and indicative layout map, the revised scheme has not, by any means, removed all panels from the higher parts of the site. Many will still stand prominently in views. We therefore contend that the revised proposal at Poulshot Lodge Farm would still, in terms from the GLVIA1,"introduce new, non-characteristic or discordant or intrusive elements into the view (6.44)", which would have alike ly significant impact on the landscape and landscape character, and on visual amenity. Judgement of the magnitude of the visual effectsof a proposal needs to take into accountthe degree or contrast or integration of any new features or changes in the landscape with the existing or remaining landscape elements and characteristics in terms of form, scale and mass, line, height, colour, and texture (GLVIA 6.39). The LVIA submitted originally, and the Assessment of Cumulative Landscape and Visual Effect (ACLVE) in the additional material substantially understate and undervalue the magnitude of the proposed development's landscape and visual impacts and effects. For example, little attention is paid to the contrast in the landscape of the mass and colour of the regimented strings of panels with the rural greenness of the open countryside around. The virtual filling of four fields with panels and associated control buildings would transform a 32.2 ha area of the landscape. There is no way of mitigating this harm to the landscape, which would alter its perceptual and aesthetic aspects for a period ofat least 25 years. The GLVIA suggests 25 years is "long-term (5.51)". The transformation of the landscape would be in place for virtually a generation2, which the applicants consider 'temporary'; it is noteworthy, however, that their claim that "the land will revert swiftly to agricultural use (DAS 3.5)" is hedged with the condition "if this was considered appropriate", which discloses an aspiration that the site’s use for generating electricitymight be extended. In any case, we hope your judgement of the claimed reversibility of the impact of this application on the land would be consistent with the judgement of a colleague elsewhere in the county: "where harm cannot be adequately mitigated a temporary consent should not provide justification3". The landscape in which the development would sit is not nationally designated or judged to be of equivalent value, but is nevertheless valued at community and county level, as witnessed by its inclusion in the itinerary of walk 23 in the Wiltshire sectionof 'Walkers Web', Walking Routes in the UK (see website). It is also one of 31 local footpath walks recommended on the Poulshot Parish website. We are unable to share the applicants' generous assessments of the impact on visual amenity of users of roads and public rights of way. For example, we challenge the notion that, for users of theA361, the effect of seeing the proposed development to the south of the road would be influenced by the existence of the Kennet and Avon Canal to the north of the oad.r We stress that travellers along that road currently (February 2014) can see the site easily through and over the 'screening' hedgerow. At present, the character of the landscape of the site and its immediate surroundings is rural, agricultural. Even a transitory glimpse of the glass and steel of the array would be enough to make the receptor aware of a change in the surroundings. The introduction into the surroundings of the single Poulshot array would transform the land within the site, but would be seen as a limited change in the larger area usually considered in description of a landscape character area. People moving through the countryside of the larger area would see the Poulshot electricity-generating apparatus as an anomaly in the area. (According to their personal interests and values, their reactions would range from enthusiastic, through indifferent, to hostile.) But the creation of a Poulshot array would add to the anomalous patches of energy-industry development already permitted or proposed for development within, say, 10 miles of Poulshot, or within a more limited area such as 5 miles of the Seend ridge. It would add to the cumulative impact of those developments on the landscape, and consequently affect not only receptors' judgement of the scenic attractiveness of the area (very important to Wiltshire's tourist industry) but also their accumulating sense of the dominant concerns of the area. The ACLVE concludes that, when considered in isolation, the solar parks it has described would have a "minor" impact on the character of the wider landscape; the Poulshot array therefore "should not contribute to any (our italics) current or foreseeable cumulative impact on the character of the landscape when taken in the wider context". That is a logically unacceptable assertion. And we argue that the Poulshot documents have not supported this view. In any case, as the GLVIA points out (7.19) "the landscape effects of the main project may be judged of relatively low significance when taken on their own, but when taken together with the effects of other schemes, usually of the same type, the cumulative landscape effects may become more significant". We deplore the fact that the ACLVE presents conclusions on cumulative effects of solar schemes on landscape character only; cumulative effects on human receptors, the effects of visual impact, are ignored. The effects on human receptors during the 'journey' described along the A361 and A365 past Poulshot are confined to the extent to which receptors may perceive change in the landscape or landscape character of the Poulshot site and the other sites in turn. Even the recognition that sites at Craysmarsh and Sandridge are very close to one another is dismissed: "the reduced visual effect due to the vegetation would mean that recognition of solar parks in the landscape would be indiscernible with little/no perceived change in the landscape character [sic]"; and the impact of the closeness of the Broughton Gifford site to Craysmarsh and Sandridge is summed up as "no combined cumulative effects upon the upon the local landscape character". The ACLVE makes no assessment of the gradual accumulation of emotional and interpretive responses in human receptors to the features and qualities of their surroundings. It is predictable that a few residents of Seend would be able to see the Poulshot site and/or Craysmarsh or Sandridge from their properties (repetitive or combined cumulative impact). Of greater significance would be the number of people who, while moving in the area as residents, on business, or as tourists, would see one or two solar sites in addition to seeing Poulshot — thus sequential cumulative impact. In our opinion, omitting to evaluate sequential cumulative impact and effects is a gross inadequacy in the Hive Energy application at Poulshot Farm. Sequential effect is additive. As we move through an area, our impression of that area develops. There are now 13 arrays proposed or permitted within seven miles of Seend — enough to create a growing sense of creeping industrialisation of this agricultural area. While we do not suggest that anyone is likely to make a deliberate tour of the 13 sites to experience the cumulative effect, we think the time has come for the Council to put considerable weight on the additional sense of industrialisation each new proposal would bring, to the disadvantage of residents in and visitors to our area. At present, there is a space of about four miles between the Coulston and Craysmarsh developments : a development at Poulshot would intervene, leaving c.3.0 miles between Coulston and Poulshot, c. 2.0 miles between Poulshot and Craysmarsh, and c. 2.0 miles between Poulshot and the proposed site at Sandridge. We recognise that Government guidance emphasises4 that separation distance plays only a part in deciding whether to allow the accumulation of solar arrays in an area; other parts are played by the local context, including topography, the local environment, and nearby land uses. In our view, the impact of a proliferation of solar arrays on the local context of the Poulshot site, and of other sites around the Seend ridge — which are valued for their natural attractiveness, maintained by agricultural activity— is not and cannot be made acceptable (NPPF 98). In the planning balance, the sole positive weight is the generation of some electricity to add to the total national production each year. In nationalterms, that production would be uneconomic, as solar energy is more expensive than most other types of generation5. Also, that addition would do little for energy security, as solar arrays produce energy only intermittently, at an unpredictable rate, necessitating expensive standby capacity. On the negative side, contrary to popular opinion, generation from solar panels is not carbon-emission-free: emissions from solar are greater than from onshore and offshore wind6. This proposal would have a major adverse impact on an area of valued landscape for a long term, and would contribute to a growing sense of unnecessary industrialisation of our countryside.