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Mapperton Solar Farm Mapperton Farm, Mapperton Almer, Blandford

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Mapperton Solar Farm Mapperton Farm, Mapperton Almer, Blandford Mapperton Solar Farm Mapperton Farm, Mapperton Almer, Blandford Forum, Dorset East Dorset District Council reference 3/13/0681/FUL Objection response by the Mapperton Preservation Group May 2015 Charborough Tower The Robert J Barfoot Consultancy Environmental & Planning Consultants Huckleberry, East Knowstone, South Molton, Devon, EX36 4DZ Telephone: 01398 341623 Contents Introduction and background Page 1 Failure to consider alternative sites Page 1 Use of Best and Most Versatile Land Page 2 Landscape and visual Impacts Page 4 Impacts on heritage assets Page 5 Community Benefit Page 12 Planning policy Page 12 Conclusions Page 15 Appendices Appendix 1 The David Wilson Partnership Review Appendix 2 The South Torfrey Farm Consent Order Appendix 3 Plan of Charborough Park RPG Appendix 4 Photograph from Charborough Park RPG 1 Introduction and background 1.1 I was commissioned by the Mapperton Preservation Group (MPG) to produce a response to the Mapperton solar farm, along with Pete Leaver, Director of the David Wilson Partnership Ltd who dealt with the landscape and visual impacts. My relevant experience over the last 10 years includes evaluating and responding to over 150 renewable energy planning applications, both at the desk and in the field, along with taking part in numerous public inquiries on behalf of local residents. I also act as the assistant to a leading Queens Counsel in such public inquiries. The David Wilson Partnership review is at Appendix 1 of this MPG response and the review is summarised at Section 3 below. 1.2 MPG was formed by residents with concerns over proposals to install inappropriate renewable energy developments in the area. 1.3 MPG objects to the proposal for the Mapperton solar farm for the reasons set out in this response and requests that planning permission be refused. 2 Failure to consider alternative sites 2.1 The Town and Country Planning (Environmental Impact Assessment) Regulations require at Schedule 4, Part I and Part 2 that an Environmental Statement (ES) should contain an outline of the main alternatives studied by the applicant and an indication of the main reasons for the choice made, taking into account the environmental effects. 2.2 The only reference to any assessment of alternative sites is at 3.10 of the Environmental Statement (ES) where it is stated inter alia that: ‘Some consideration of other sites has also been undertaken. Solar PV is highly constrained by the requirement to be close to a suitable grid connection point. A 1 suitable grid connection point will have the capacity to accept the requisite additional load onto electricity transmission lines. At Mapperton, the overhead electricity transmission lines that cross the site do have the ability to accommodate the additional load of energy that would be generated by the solar photovoltaic farm and, therefore, the site meets this critical requirement.’ 2.3 It can be seen that the applicant states that alternative sites have been considered. However no details are provided of these sites and why they were rejected in favour of the Mapperton site. 2.4 Such an approach is contrary to the EIA Regulations, and the ES should have set out the alternative sites that were considered along with the reasons that they were rejected in favour of the Mapperton site. 2.5 The Council should request that the applicant provides the required information on alternative sites that were considered along with the reasons that they were rejected in favour of the Mapperton site. Failing that the Council should refuse planning consent on the basis of lack of adequate environmental information. 3 Use of Best and Most Versatile Land 3.2 At 2.4 of the Planning Statement it is stated that ‘The Project is located on agricultural land, consisting of grade 3a (good) and 3b (moderate) under the agricultural land classification (ALC) system. The land is currently used for arable crops.’ 3.3 At 7.23 it is then stated inter alia that ‘Applying the relevant policy advice to the Project: • The agricultural soil classification for the site has been identified as primarily grade 3b with some smaller area of grade 3a in the centre of the site. The Project does not lie within agricultural land classified at grades 1 and 2. The site selection demonstrates that the hierarchy of agricultural land classifications has been influential in identifying the application site for the Project, to seek to avoid where possible agricultural land of the highest classification.’ 3.4 Reading Agricultural Consultants Ltd produced a document entitled Agricultural Land Classification and Soil Resources on behalf of the applicant. 3.5 Table 2 of that document is produced below and it can be seen that in fact 24% of the site area is Grade 3a land. 2 3.6 The NPPF states at paragraph 112 that ‘Local planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality.’ 3.7 The Glossary to the NPPF defines best and most versatile agricultural land as ‘Land in grades 1, 2 and 3a of the Agricultural Land Classification.’ 3.8 It is noted that at 2.4 of the Planning Statement it is stated that the land is currently used for arable crops. Chapter 9 of the ES states at 9.135 that ‘it is expected that the land beneath the solar panels will be grazed by sheep and the panels themselves will offer shelter and shade for these animals during adverse weather conditions.’ From this it is clear that the use of the land will change from arable to the grazing of sheep, a much less productive activity in terms of food production and one that is usually undertaken on land that is unsuitable for other agricultural activities. 3.9 The UK Solar PV Strategy refers to Solar Trade Association: Solar Farms: 10 Commitments one of which is ‘We will focus on non-agricultural land or land which is of lower agricultural quality.’ The Strategy then states that ‘ These best practice initiatives are important as they help address the perception that solar farms are diverting significant amounts of land from agricultural use and domestic food production. This, alongside the effects on the landscape and communities of the rapid growth in the deployment of large-scale solar PV installations, might erode public support for the sector overall.’ 3.10 Bearing in mind that 24% of the site is Best and Most Versatile Land, the words of the Inspector in dismissing the Rogers Farm, Sudbury appeal 1 are relevant: ‘The appeal site, with regard to the aforementioned advice in the NPPG, would remain in agricultural use for the 25 year life of the development, probably for the grazing of sheep, and proposed perimeter planting and other measures would enhance biodiversity. However, the solar farm development would be on BMV land and, of greatest significance, no assessment has been made of the possibility of locating the development on 26 hectares of the more than 16,000 hectares of Grade 3b agricultural land in the District. The development would be reversible at the end of its life and the land could revert to being used for growing arable crops. However, it must be concluded that the development would result, if allowed and implemented, in a loss of BMV agricultural land.’ 1 APP/D3505/A/14/2218072 3 3.11 The words of the Inspector in dismissing the Landthrone appeal 2 are also relevant: ‘A subsequent analysis prepared by Kernon Countryside Consultants for the appellant in December 2012 and correspondence from Luscombe Maye in October 2013 indicate Grade 3a across the majority of the site on which panels would be located and Grade 3b on most of the remainder. There is no question that the land remains in agricultural production. Whether the eastern portion is actually Grade 2 or 3a is of marginal significance because it remains undisputed that the site essentially comprises best and most versatile agricultural land which the NPPF indicates has benefits and should be safeguarded in the long term. Having regard to the most recent planning guidance, the land is demonstrably not of poorer quality and is being used. Indeed, the conservative yield figures indicate that barley yield from the eastern portion would be above average. There is nothing to suggest that this area (field 1) needs to be managed for a lower grade. The loss of agricultural production on best and most versatile agricultural land is a material consideration that weighs against the scheme. Some weight attaches to the likelihood that the site would continue to be used for grazing while panels are in place. However there would be a great deal less grass under the panels than there is currently. The 25 year temporary nature of the proposal is a consideration, but that is a long time in which in which an attractive area of productive land would be used essentially for a non-agricultural purpose.’ 3.12 Although all of the site in the Sudbury case was Best and Most Versatile Land and in the case of the Landthrone case the majority of the site was Best and Most Versatile Land the fact that 24% of the Mapperton site would be Best and Most Versatile Land must weigh heavily against the proposal. 4 Landscape and visual Impacts 4.1 The David Wilson Partnership review is at Appendix 1 of this MPG response and can be summarised thus: The development would have an adverse moderate/substantial overall effect on the host Landscape Character Area.
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