top of page
Search

Our Objection Is In – Submit Yours by April 12

 


There are just a few days left to object to the Staveley Solar Farm planning application before the deadline on April 12.


Please visit the Rutland County Council Website and quote Planning Application Reference: 2024/0300/MAF, or email planning@rutland.gov.uk using the same reference.

 

Here’s our objection letter…

 

Rutland Solar Group Ltd (RSAG) was established by a group of Rutland residents with aim of providing collective community opposition to the proposed Staveley Solar Farm development.

 

Our objective is to prevent what would be a wholly inappropriate large scale development industrialising more than 200 acres of one of Rutland’s finest rural landscapes, with the significant loss of important Best and Most Versatile (BMV) agricultural land.

 

RSAG has amassed over 1,000 signatures for our ‘Stop Staveley Solar Farm' petition in support of our campaign. (https://www.change.org/p/stop-staveley-solar-farm-rutland?source_location=search)

 

While recognising the need for renewable energy – actively promoting the solution of putting ‘solar panels on roofs, not farmland’ – RSAG objects in the strongest possible terms to the Staveley Solar Farm planning application and what appears to be the nothing other than a financially driven, self-serving scheme to benefit private companies including the landowner, Bluestone Energy (the developer) and Anglian Water (AW), all at the expense of local communities and Rutland’s valuable rural landscape and farmland.

 

We also believe that the development would lead to appalling and unacceptable noise, pollution and disturbance to the local community during the construction phase, with thousands of vehicle journeys, including more than 1,000 articulated lorry journeys originating from outside of Rutland passing through the village Morcott and along narrow country lanes and across a small bridge to the construction site.

 

We also believe that endangered red list species including skylark and lapwing will be disturbed during construction – leading to an inevitable offence under the 1981 Wildlife and Countryside Act. Based on post-construction studies of rare birds on solar farms, such species are unlikely to return to the site, if developed.

 

RSAG's objections are focused on what we believe to be significant material considerations which must be taken into account as part of the planning decision making process. There is clear precedent for Rutland County Council to refuse this application in the case of Berrington Solar Farm, which was refused permission by Shropshire Council, a decision supported by a Government planning inspector when it came to appeal in March 2024 citing: 1) Loss of BMV land 2) Impact on landscape 3) Negative impact on skylark population. (See: https://www.shropshirestar.com/news/local-hubs/shrewsbury/2024/04/04/shrewsbury-solar-farm-appeal-dismissed/#)

 

Our principal points of objection, which we detail below, focuses on:

 

1.     Loss of valuable ‘Best and Most Versatile’ farmland

2.     Overall size and dominance of the proposed development resulting in industrial intrusion in a high value rural landscape

3.     Threat to rare, red list species present on the proposed development site, including skylark and lapwing

4.     Noise, disturbance and pollution created as a result of traffic during the construction phase

5.     The negative amenity impact upon local people residing in properties within close proximity to the site

6.     Rutland County Council's (RCC) failure to require a full Environmental Impact Assessment (EIA) at the pre-planning 'screening opinion' stage of the proposal

7.     Misleading claims being made by the developer in terms of the 'brownfield' status of the site

8.     Use of forced labour in Chinese manufacturing

9.     An unsustainable development that will damage the environment, not enhance it

10.  The role of Anglian Water, a serial environmental polluter and a company that under the Government’s Environmental Performance Assessment ‘requires improvement’

 

 

1.     Loss of Best and Most Versatile (BMV) land

According to DEFRA 'Best and Most Versatile' (BMV) agricultural land i.e. that falling within land classifications 1 to 3a accounts for around 20% of the total land available. A similar proportion is estimated for the East Midland region as a whole.

 

As for the 85-hectare site identified for the Stavely Solar Farm, around 25% of it has been identified as being BMV land, some 20 hectares in total comprising mainly of grade 3a land.

 

Huge amounts of BMV land are being lost to development – and this unsustainable loss of agricultural land currently used for arable farming comes at a time when the National Farmers’ Union says the UK is “sleepwalking into a food security crisis”.

 

In its consideration of the Staveley Farm proposal, RSAG demands that RCC follows the national guidance which has been issued to local planning authorities in this regard. That is:

Ideally ground mounted large scale PV arrays should utilise previously developed land, brownfield land, contaminated land, industrial land or agricultural land preferably of classification 3b, 4 or 5. Whilst there is no ban prohibiting ground mounted large scale PV arrays on sites classified agricultural 1, 2 and 3a or designated for their natural beauty or acknowledged/recognised ecological/archaeological importance/ interest it is unlikely that planning permission will be granted where there is significant impact on these designations. (BRE: Planning Guidance for the development of large scale ground mounted solar PV systems)

 

The NPPF paragraph 112 requires the presence of best and most versatile agricultural land (defined as land in grades 1, 2 and 3a of the Agricultural Land Classification) to be taken into account alongside other sustainability considerations. The NPPF expresses a preference for development to be directed to land outside of this classification (3b, 4 and 5), but paragraph 28 also recognises the need to support diversification of agricultural land that helps to sustain an agricultural enterprise.

 

Within the context of the entire land holding and its current use, RSAG considers that the developer has not provided any evidence that its solar proposal is an essential requirement in order to help sustain the remainder of the agricultural operations that are taking place.

 

Most importantly, we object to the loss of BMV land which is a clear reason to refuse permission.

 

 

2.     The overall size and dominance of the proposed development resulting in industrial intrusion in a high value rural landscape

 

RSAG is of the view that the proposed large scale industrial development is wholly disproportionate in terms of its size and dominance within what is an entirely rural local landscape. 

 

The environmental quality of the County of Rutland, particularly of the landscape, is very high. It is widely appreciated by residents and visitors. It makes a substantial contribution to the quality of life in the County. (Rutland Landscape Character Assessment 2003)

 

The assessment emphasises the need to “conserve and enhance, the distinctiveness and the characteristics that make Rutland special and gives the County its sense of place.”

 

RSAG believe that the proposed solar installation will have the opposite effect on the area within, and immediately surrounding, the proposed site. An industrial power plant dropped into one of Rutland’s most rural areas can never be considered an enhancement and will destroy the distinctiveness and inherent characteristics of the landscape. This overtly utilitarian form of development would considerably erode the rural and pastoral character of the fields and diminish their contribution to the key landscape characteristics of High Rutland.

 

We understand that Rutland County Council has no firm policy on renewable energy however, Policy CS20 (Energy efficiency and low carbon energy generation, Core Strategy Development Plan) states that,

 

Wind turbines and other low carbon energy generating developments will be supported where they address landscape and visual impact, informed by the Rutland Landscape Character Assessment and the Rutland Historic Landscape Character Assessment.

 

The Landscape Character Assessment’s landscape objectives for High Rutland, which includes the Staveley Solar site, is to sustain the rural, mixed agricultural landscape with its historic stone-built villages that fit well with the landform. It also recommends protecting the landscape setting and conserving and enhancing the edges of villages whilst protecting panoramic views from the ridges.

 

RSAG believes that this proposal will achieve none of the above for the following reasons:

 

•      Solar farms do not sit easily within an agricultural landscape. They do not complement stone villages, including those with Conservation Area status, heritage assets or their setting.

•      This proposal will not protect panoramic views from ridges, country lanes or homes.  

•      At Pilton, solar panels encroach to the edge of the village, destroying the picturesque environs. Similarly, at North Luffenham Road, Morcott residential homes would have panels in close proximity and highly visible thus providing no enhancement to the edges of villages.

•      The setting for rural villages with a longstanding agricultural heritage cannot in any way be “enhanced” by an industrial installation that covers the land that brought about their very existence.

•      The most prominent ridge in the landscape surrounding the Staveley Solar site is the Welland Ridge, to the south. Parts of the site are visible along the A47 stretching from Glaston to Morcott. Once covered in tens of thousands of black glass panels they will greatly detract from the landscape.

 

Previous RCC policies advise that developments proposed for Rutland should have regard to the key characteristics of the landscape, within which they are situated. They should also consider the capacity of the landscape to accommodate the scale of the development proposed. The new draft local plan identifies suitable areas of “opportunity for ground mounted solar photovoltaic sites”. However, the site proposed for the Staveley Solar installation is not amongst those identified as “opportunity” areas for this type of renewable energy production.

 

Part of this plan was based on an extensive Renewable Energy Study. In 2023 RCC informed the Inspector at the Mallard Pass public examination that this study should be “considered as material considerations in the determination of the scheme”. Should this not equally apply to the Staveley Solar proposal, and should it still be considered as it falls outside of those areas identified for solar installations?

 

We contend that all renewable energy developments should be located to minimise impact on the landscape and appropriate mitigation measures should be taken in order to reduce or ameliorate any potential effects. Unfortunately, the arrays of solar panels extend across the countryside, restricting views that have been enjoyed for hundreds of years. The developers were made aware that local residents were unhappy with the proximity to homes and resulting loss of visual and residential amenity. However, Bluestone have done little in response to these concerns. A few panels have been moved to reduce sight from Morcott village, but no improvements have been made at Pilton or North Luffenham Road, Morcott.

 

Also of concern is the siting of panels on both sides of Morcott Road, Pilton. Currently, the views from this country lane are long-range and scenic with a strong sense of place and agricultural history. The ridge and furrow on Morcott parish land bears witness to the areas agricultural ties dating back to the medieval period.

 

The solar panels west and east of Morcott Road will drastically change the character of this country lane, from remote and rural to industrial. Glass, metal, cameras and lights on miles of fencing are all incompatible with the current character of the area. The many users of the lanes that surround the site (walkers, joggers, cyclists and horse riders) will suffer loss of visual and recreational amenity due to the positioning of acres of equipment and the noise generated by inverters, transformers and motorised panels. No thought has been given to minimising the impact of this project other than to infill hedges with a few small plants in single use plastic tubing. There is no suggestion of soundproofing equipment around electrical equipment nor the use of earth banks or soil bunds to keep nuisance noise within the site.

 

RSAG does not consider the mitigation proposals to be sufficient with regard to planting

schemes. The proposed density of the planting and the size of the plants themselves will not sufficiently screen the solar panels. Obviously, in winter their contribution would be reduced. Planting of this type takes decades to establish to a point where it could afford decent cover.

 

This point was reinforced by an Inspector for the Planning Inspectorate, Mr Callum Parker, who stated (when refusing an appeal) that although planting had the potential to mitigate some visual impact, it would need time to sufficiently establish and would not completely screen sight from public vantage points. He also stated that the appearance of the landscape would be drastically altered by the “introduction of an overtly utilitarian industrial infrastructure.”

 

There is concern from locals regarding the location of the site on top of a Groundwater Source Protection Zone. (GWSPZ). RSAG had already identified this geological feature, but it has been confirmed in the Geo- Environmental Assessment in the application. The site is also located on top of a Principal Aquifer. The aforementioned report states that “the risk to controlled waters is considered to be significant based on the potential for landfills to be present beneath the site, as well as the aquifer status of the solid geology below” and recommends further intrusive investigation. It is unclear whether this has been done. Consideration of the application should not progress until all investigations are complete.

 

The proposal claims that the planned solar installation is temporary. However, the application includes information on the decommissioning, after which the substation will remain as part of the local grid network. This is therefore a permanent structure. We question what else will be left once the power plant has ceased to operate? Who will pay the full cost of decommissioning and ensure the complete removal of panels and associated structures from the landscape? Will agricultural land become brownfield or simply be reused for another form of energy generation?

 

In May 2023 an application for a 49.99MW solar farm in Essex was refused. The Inspector stated as part of his grounds for refusal that, in his opinion, the use of the land for 40 years was not temporary, and this formed part of his grounds for refusal. In his opinion the industrial infrastructure, due to its scale and size, had the potential to give rise to significant visual effects, which in time would be perceived as permanent. This proposal was similar in acreage and power output to the Bluestone application and also located in open countryside.

 

We also believe that consideration must be afforded to the cumulative impact on the wider Rutland landscape of all permitted, or planned, industrial solar plants. There are solar installations at Seaton and Ketton, another permitted at Langham; three in the planning process (Mallard Pass, Staveley and Exton) and developers looking for yet more land within the county at St Georges Barracks and around Market Overton and Barrow.

 

RSAG does not feel that matters of landscape and visual impact have been adequately addressed, or sufficient mitigation offered in this planning application. Neither do we feel enough weight has been given to the area as a valued landscape. We note that objections are being lodged by both residents and visitors to the county, all of whom value the countryside that makes up this uniquely preserved landscape. Tourism is an important industry to Rutland’s economy. Indeed, RCC is actively marketing the lanes around Pilton as a recommended walking route of special interest and has printed a leaflet. Our tranquil, unspoilt landscape is our unique selling point. We must not sacrifice this in the mad race for renewables.

 

Taking all of this into consideration, the application stands contrary to established policy. There is quite simply insufficient material to demonstrate that the proposal would not be harmful. There is little consideration given to the current quality of the landscape, how highly it is valued and its capacity to accommodate change. These are fundamental characteristics to be considered when judging the impact of this project on the Rutland landscape.

 

Furthermore, RSAG strongly believes that the proposals being put forward are actually for a much larger capacity installation than the 40MW that is being cited.

 

The basis for this is RSAG's consideration of the headline claim being made on the developer's website that the installation will generate sufficient power for 15,500 homes. According to OFGEM, the average UK household consumption is 3,300 kWh / year. This would require the proposed installation to output approximately 51 MW of energy. This would in the process make the installation a 'Nationally Significant Infrastructure Project', rather than one that simply requires a local authority decision.

 

All along, RSAG has held the view that the developer is deliberately understating the full generating capacity in order to avoid the much greater level of scrutiny that would go 'hand in hand' with a NSIP scale development. Evidence that has been obtained by Alicia Kearns MP has shown that this practice of understating the true capacity of industrial solar developments is commonplace, whereby unscrupulous landowners and developers are deliberately setting out to circumvent the planning rules.

 

It is imperative therefore that this discrepancy is fully investigated by RCC prior to any planning decision being taken which could ultimately be challenged further down the line. 

 

If approved Staveley would be one of the UK's largest solar installations, covering over 0.21% of England’s smallest county's land area.  Staveley Solar Farm would comprise of over 87,000 solar panels – more than two panels for every single resident of Rutland.

 

This should be considered in a national context where at present around only 0.1% of the UK land mass is covered with solar panels, a figure predicted to rise to around 0.3% by 2050 as part of achieving 'net zero'.

 

RCC has already approved a 52-hectare solar installation (Ranksborough – 0.14% of county land area). Alongside this further consideration, albeit still at a pre-planning stage, is currently being given towards an 80-hectare site at Exton, which would account for a further 0.2% coverage of the county's land area. 

 

A final Secretary of State decision on the proposed NSIP development – the Mallard Pass Solar Farm that would straddle both Rutland's and Lincolnshire's borders, is imminent. Regardless of all the aforementioned sites, this on its own would see more than 1.5% of Rutland's land area covered in solar panels. It would be the largest solar site within the UK. 

 

The cumulative effects of all of the above in a 'worst-case scenario' would be huge – over 2% of Rutland under the cover of solar panels against an eventual predicted post 2050 national coverage of just 0.3%. 

 

As an indication of the scale of this concentrated solar coverage – it would amount to an area approaching 80% of that taken up by Rutland Water.

 

RSAG is therefore strongly of the view that planning officers and elected councillors MUST NOT consider any proposals for large industrial scale solar developments, such as Staveley, in isolation. To do so will present a considerable risk that the very character and nature of Rutland as a place could be changed dramatically over the next few years.

 

It should also be stated that solar is highly inefficient in comparison to offshore wind. In terms of efficiency rating i.e. the amount of power exported to the grid, solar’s rating is between 11-15% whereas for off-shore wind the figure is more than 50%. One wind turbine in the North Sea has the capacity to power 16,000 homes – more than Staveley Solar Farm.

 

 

3.     Threat to rare, red list species present on the proposed development site, including skylark and lapwing

 

The developer claims that 7.63 ha of dedicated Biodiversity Enhancement Areas will result in a Biodiversity Net Gain across the whole site. This has been calculated by desktop. RSAG disputes this claim amid mounting evidence that real world industrial scale solar farms are, in fact, damaging to the environment and biodiversity, despite mitigation measures, and are responsible for dangerous levels of pollution, including waterborne pollutants and petroleum hydrocarbons, while reducing biodiversity, with legally protected species, especially red-list ground nesting birds, failing to return to open arable fields where they once nested.

 

A number of species that are included on the Government’s list of rarest and most threatened species (England) – Section 41 (S41) of the 2006 Natural Environment and Rural Communities (NERC) Act – are present on the Staveley development site and have been regularly observed. These include skylark, lapwing, song thrush, yellowhammer and dunnock. Disturbance of nesting birds would constitute an offence under the Wildlife and Countryside Act 1981. The applicant offers insufficient assurance that disturbance will be avoided. While site clearance and habitat management works are said to take place outside the breeding season (defined as March 1 to August 31), this is unlikely to be possible when there is a year-long development phase which will involve thousands of vehicle movements. Simply putting up fences around targeted areas will not prevent skylarks and lapwings failing to breed on arable fields which will have been cleared ahead of construction. Disturbance will be unavoidable and development cannot be permitted.

 

Skylarks

In March 2024, a planning inspector rejected an appeal for a 30-MW solar farm near Shrewsbury after it had already been refused permission by Shropshire County Council, due to loss of agricultural land, landscape visual harm and, specifically, skylark nesting sites. The Planning Resource website reported: “Effects on skylarks weighs against solar farm. A proposed 30MW solar farm in Shropshire refused against officer recommendation for reasons of loss of best and most versatile agricultural land, landscape visual harm and loss of skylark nesting habitat has been denied permission by a planning inspector.” (https://www.planningresource.co.uk/article/1866832/effects-skylarks-weighs-against-solar-farm)  

 

Lapwings

Post-construction monitoring at the Llanwern Solar Farm by Gwent Wildlife Trust found that no lapwings used the “Lapwing Mitigation Area”. Numbers of breeding lapwings fell from eight pairs pre-construction to two pairs post-construction, with only one nest found on site. Lapwing are a red list species with numbers dropping by more than 50% since 1967.

 

Bats

The same study found that diversity of bat species decreased markedly, and for the majority of locations, abundance of species dropped dramatically (95-100%). Bats are an important indicator of biodiversity and their disappearance from constructed solar farm sites is alarming.

 

Biodiversity Net Gain across the whole Staveley site is a dubious claim by the developer. Bird and bat deaths are common in solar farms as they can mistake panels for water. The addition of 15 bird boxes across the site, 15 bat boxes, 10 hedgehog boxes and 10 insect hotels will not compensate for what is likely to be catastrophic damage to the environment and biodiversity.

 

Pollution

The post-construction monitoring report for the Llanwern solar farm also revealed levels of several waterborne pollutants arising from the constructed solar farm had risen hugely since construction. Very high levels of total petroleum hydrocarbons TPHCWG were also recorded inside the solar farm site.

 

The report concluded there had been a, “Catastrophic failure of mitigation measures.”

 

There is no mention in the application of the chemicals that will be used to clean the solar panels and the significant effect of runoff. There is also the risk of toxic chemicals leeching out from the panels manufactured in China.

 

Resonsibility

Responsibility for the Biodiversity Enhancement and Management Plan (BEMP) is with the developer, according to the Landscape and Ecological Plan (LEMP) submitted as part of this application. However, RSAG understands Total Energies will be appointed operator of the site. Clarification and guarantees over the responsibility, implementation and management of the BEMP is required.

 

The LEMP submitted as part of the application states that “The Ecological Mitigation Measures section of the Biodiversity Enhancement and Management Plan (“BEMP”) included at Appendix 2 of the Ecological Assessment Report outlines the protection requirements for ecological features within the Site. This includes measures for birds, bats, amphibians, reptiles, hedgehogs and brown hare.” (Frustratingly – and unacceptably – the BEMP, Appendix II was unavailable to view on the RCC planning website at the time of writing and so RSAG cannot be confident sufficient protective measures would be put in place. This requires clarification.)

 

The Screening Opinion document (Pegasus Group November 18, 2022, Ref P22-1447) Appendix 1, Site Location Plan, clearly shows a Special Protection Area covering half the site. This had already been erroneously overlooked by the Council in the developer’s EIA screening submission. The SLP has subsequently been revised within the full planning submission, which raises questions of credibility of the entire application.

 

The developer’s claim that there will be a Biodiversity Net Gain is fatuous. A huge industrial solar plant on arable fields will not enhance biodiversity or attract more of this country’s rarest ground nesting farmland birds – it will simply accelerate species decline with catastrophic long-term consequences.

 

 

4.     Noise, disturbance and pollution created as a result of traffic during the construction phase

 

We object to the appalling and unacceptable levels of noise, disturbance and pollution which would be generated as a result of the construction of Staveley Solar Farm.

 

Based on the developer’s Traffic Management Plan, the contractor's intended route to the site is from A47 via 'Cockpits' then into the Morcott Conservation area through Fydells Row with a left onto the unclassified, single carriageways of Wing Road towards Pilton terminating at Pinfolds Lane. 

 

The developer estimates in excess of 1,200 two-way movements of large goods vehicles, and various items of plant equipment. This will include 1000 movements of 16.5m, 44 tonne articulated lorries and 200 movements of 10m, 20 tonne 'tipper' trucks.

 

The site will be in operation for six days per week (Mon through to Sat noon) and will be staffed by a minimum of 60 workers. Construction phase is a minimum of 12 months as stated in planning documents.

 

The developer has concluded that “the level of traffic during the temporary 12-month construction phase is not considered to be material and it is considered that this will not have a detrimental impact on the safety or operation of the local or strategic highway network”

 

We disagree on this point and object.

 

The developer is proposing a parking restricted zone in front of the cottages at Tyler's Row in order to prevent residents parking outside of their properties. This is to enable the largest of the vehicles to use the full width of the road at the 'T' junction.

 

All goods vehicle deliveries will commence outside of Rutland – therefore travel distance to site from nearest border (A43 Collyweston) approx 13 miles (two-way) for a 'best case' scenario. Obviously, vehicles heading to site from the South, West or North will travel a far greater distance within Rutland i.e. 'worst-case scenarios'.

 

Majority of site workers will be from outside of the area so it can be reasonable to assume assume the same minimum travel distance – either in crew buses or private light vehicles and vans. This has not been given any consideration within the plan. A reasonable assumption would be as many as 30 two-way light vehicle movements per day, 6 days per week.

 

 

Considerations & Impacts

Morcott is a Conservation Village. The area around the junction between Fydells Row and Wing Road will bear the full impact of these vehicle movements and all that this will entail such as pedestrian safety, pollution, noise and vibration from heavy vehicles.

 

Residents of Tyler's Row (some elderly) would face having to walk elsewhere within the village in order to access their cars. This will entail considerable difficulty for some.

 

The CO2 emissions and other toxic emissions from the huge increase in relatively slow-moving heavy goods vehicle traffic through Rutland would be considerable. According the DoT, an average 44 tonne lorry emits around 1.5kg for every mile travelled. A full calculation using the DoT figures for CO2 emissions to cover all of the vehicle types listed within the plan, plus the daily travel impact of site workers, could amount to as high as 33 tonnes of CO2 emitted during the construction phase.

 

To put this into perspective it takes 6 mature trees to absorb just one tonne of CO2 during one year. This fact alone should call into question some of the highly exaggerated claims that the rational for this project is linked in any way to the environment.

 

The site chosen for Staveley Solar Farm is unique in many aspects not least of all is its remoteness. When compared to other industrial scale solar installations of a similar size, what stands out is its distance from the main road network as well as from its proposed connection into the electricity grid. Together these aspects make the whole scheme far more disruptive than it otherwise would be.

 

The roads identified for the site traffic are simply not suitable for this kind of traffic and not least of all because the chosen route will pass close by to residential properties, which also happen to form part of a conservation area. 

 

Some of the route in question is in a less than a satisfactory state of repair even before it is subjected to what would be a huge increase in the passage of heavy vehicles. In some place there is only room for one vehicle to pass in either direction. During the winter months Wing Road in particular, suffers from excess water running off the surrounding fields resulting in a significant amount of mud and debris on the roadway.

 

 

5.     The negative amenity impact upon local people residing in properties within close proximity to the site

 

The developer's submission has recently been updated to include a 'Residential Amenity Impact Plan' upon which it has shown the 250m 'buffer zone' around the site perimeter.

 

A review of this clearly shows the number of residential properties that will be significantly impacted by this development due to being within this zone. This includes the entire conservation village of Pilton including a number of listed buildings and heritage assets.

 

The computer-generated landscape images that the developer has included in an attempt to demonstrate the lack of any significant longer term visual impact all appear to show the site as viewed from relatively long distances and from various locations. It is reasonable to assume that in future years and when viewed from afar, the visual impact could be minimal.  This is hugely different to the close day to day close proximity ground level views that will be experienced by those residents who live or work in the area along with those who either travel through or visit this hitherto unspoilt part of the County.

 

Arguably worse than the visual impact of swathes of solar panels and associated steel framework, the developer proposes to erect over 6km of 2.4m high steel mesh fencing around the site perimeter along with up to 150 4m high pole mounted security cameras spaced at roughly 45m intervals along the fence.

 

RSAG requests that further details and information is provided so that the full amenity and visual impact of this proposal can be assessed.   

 

 

6.     Rutland County Council's (RCC) failure to require a full Environmental Impact Assessment (EIA) at the pre-planning 'screening opinion' stage of the proposal

 

RSAG made an initial complaint after RCC failed to require the developer to submit an EIA, in spite of the developer's stated intent to size the development right up to the threshold limit of 50 MW for local proposals.

 

The quoted 49.9 MW threshold should have at least been a trigger for RCC to further investigate this particularly as the initial screening exercise had clearly overlooked or simply disregarded numerous sensitivity impacts. These included the proximity of residential properties and conservation areas, nearby heritage assets, existing nature and biodiversity aspects, and the overlap with the site and a Special Protection Area (SPA).

 

RSAG made a formal complaint to the Council at the time (66/23) seeking a review of the decision not to proceed with an EIA. In RCC's response (April 3, 2023), Justin Johnson, Development Officer, wrote: “Whilst I have concluded that the overall decision not to require an ES was the correct one, I do acknowledge that the internal matrix used to record the Council’s assessment could have contained a more detailed summary of the assessment and this is an issue that I will pick up with the team and provide further training on.”

 

RSAG remains unsatisfied with the RCC's response to its formal complaint. 

 

 

7.     Misleading claims being made by the developer in terms of the 'brownfield' status of the site

 

RSAG is of the opinion that the developer is deliberately attempting to mislead RCC and the communities of Rutland through its claims that the land in question was previously an industrial site as opposed to an agricultural one.  RSAG is of the view that this is a somewhat crude and cynical attempt to distract attention from what would otherwise be seen as a wholly inappropriate development in a rural landscape. Moreover, it would be a development that is contrary to the guidance provided within the National Planning Policy Framework (NPPF). The NPPF expects local authorities to protect and enhance valued landscapes and sites of biodiversity.

 

Whilst RSAG fully acknowledges that some of the site was previously used for ironstone quarrying, the developer has misrepresented the extent of this. Using information obtained from local historical resources, including photographs and Ordnance Survey (OS) maps, RSAG estimates that around only 10-15% of the site was subjected to disruptive quarrying operations. This assessment is based upon a consideration of the type of quarrying that was necessary to obtain ironstone as opposed to the more commonplace and highly disruptive aggregate quarrying practices seen elsewhere within Rutland and surrounding counties.

 

The developer's attempt to reinforce its argument through the inclusion of LiDAR data is inconclusive: conversely it seems to simply reinforce the greater clarity of detail provided in the OS map extracts (see p19 of developer's Heritage Statement). Within this document it states: “A review of aerial photographs indicates that there was quarrying undertaken within the site as shown on images from 1946 and 1971. The photographs have not been reproduced although the area of disturbance as transcribed on plate 17.”

 

RSAG contends that if the aerial photographs confirm the extent of the quarrying operation, then they should have been included as part of the submission. RSAG therefore requests RCC to ensure that the Heritage Statement is amended to this effect in order that due consideration can be made with regard to the claim that entire site was previously used for industrial purposes.

 

The fact of the matter is that this land was farmland before a fraction of the site was used for historical quarrying before subsequently being returned to farmland, with the majority of site used today for arable crop production.

 

 

8.     Use of forced labour in Chinese manufacturing

 

Over 80% of solar panels are sourced from China. In addition to the pollution caused by the manufacturing process, it must be recognised that these panels are all too often made using cheap forced labour in which workers are exposed daily to an unacceptable level of toxic chemicals during manufacturing.

 

RSAG understands that the developer has selected Winning Enterprise Group Co. in China as its supplier.

 

Sheffield Hallam University’s report,  In Broad Daylight: Uyghur Forced Labour and Global Solar Supply Chains (https://www.shu.ac.uk/helena-kennedy-centre-international-justice/research-and-projects/all-projects/in-broad-daylight) found that 90 Chinese and other international companies have supply chains impacted by what Rutland and Melton MP calls ‘Uyghur blood labour’.

 

RSAG urges RCC to demand that the developer provides legally binding guarantees that the solar panels or their parts will not be sourced from companies or organisations that use forced labour within their supply chains. RCC cannot give permission to a development and business enterprise fuelled by blood labour.

 

 

9.     An unsustainable development that will damage the environment, not enhance it

 

RSAG strongly contest many of the environmental benefits that are being put forward by the developer in support of its planning submission.

 

The manufacture of solar panels requires a considerable input from fossil fuels – in the case of Staveley Solar Farm and in consideration of the number, type and size of the panels, it would require the burning of approximately 29,000 tonnes of coal. This would result in CO2 emissions of over 70,000 tonnes during the manufacturing process. Likewise, the hundreds of tonnes of steel framework that would be required for the panel mounting system would result in considerable level of CO2 emission in its manufacture.

 

The consequence of this is that it would be a number of years in operation before the Stavely site became in effect 'carbon neutral'.

 

The Staveley Solar Farm Installation is cited to be 'temporary' albeit with an initial life circa 40 years. Taking the actual panels alone and disregarding all of the other elements of this installation, this would require the disposal of almost 2,000 tonnes of waste or in landfill terms some 6,100 m3 – equivalent to 24,400 standard size 'wheelie bins'. An obvious alternative to land-fill would be recycling. However, currently the state of solar panel recycling in the UK is relatively limited, with a few companies providing services and inadequate infrastructure to manage the predicted volume of solar waste over the next 30 – 40 years.

 

RSAG is of the view that claims to sustainability and the temporary nature of the installation cannot be accepted without the submission of a fully validated 'end of life' decommissioning plan. 

 

The claim that the land could be returned to agriculture after 40 years is inaccurate and should be challenged. Work by Professor Mike Alder, Emeritus Professor of Ecological Sciences at the University of Essex, concludes that it is highly unlikely that land used for a solar farm can be returned to agriculture after 40 years. (The Problem with Solar Farms, CPRE Hertfordshire. https://www.cpreherts.org.uk/wp-content/uploads/sites/30/2021/10/The-Problem-with-Solar-Farms.pdf)

 

RSAG demands that RCC reviews it sustainability policy to ensure that a wholistic view of sustainability takes into account the environmental cost of this proposed development.

 

 

10.  The role of Anglian Water

 

RSAG believes that wider consideration and scrutiny should be directed to the role of Anglian Water and the credibility and trustworthiness of the exaggerated sustainability claims made in the application.

 

As has been widely reported in both national and local media, Anglian Water is a serial environmental polluter. According to the Environment Agency’s Environmental Performance Assessment (2022), Anglian Water was responsible for 255 pollution incidents, its status is ‘Amber’ and the ‘Company requires improvement.’

 

Given its history of prosecutions and considerable fines paid out for its core business failings, RCC cannot afford to simply take this company's claims at face value.

 

Staveley Solar Farm would represent a huge financial investment for the organisation – solar industry figures suggest a figure of some £15 - £20 million for the installation plus network connection charges which would add a further £3 to £4 million for a 33 kV cable to be laid all the way from the site across to Oakham. RSAG holds the view that given Anglian Water’s other obvious priorities this kind of investment is more indicative of reducing operating costs and thereby improving profits than protecting the environment. If it was concerned with the latter then it would be perhaps more focused upon improving its core business performance. 

 

RSAG has been made aware of concerns that Anglian Water has been developing its electricity generating infrastructure in order to gain a larger and more lucrative slice of the National Grid's 'capacity market'. This has yet to be investigated and therefore verified by RSAG. Instead RSAG has focused its attentions towards the present planning application rather than upon any previous applications such as that concerned with the installation of a large-scale diesel generator at the Wing / Morcott Water Treatment Works. 

 

With this in mind it is difficult to overlook a key aspect of the Staveley proposal – namely the 33 kV cable connection from the solar installation all the way to the 33kV substation at Oakham at which point the power would enter the national grid. This part of the installation, as well as costly will be highly disruptive during the construction phase. The cable laying will involve a distance of almost 11km. According to experts within the power distribution industry this distance is highly unusual. In almost all circumstances 33 kV connections from solar plants tend to need to be less than 5km so as to keep the connections costs as low as possible so as not compromise the financial viability of the site. 

 

The financial viability of course becomes less of an issue where the Solar Farm will form part of a wider power generation infrastructure set-up in support of the National Grid's capacity management network. This crucial aspect must be investigated further as part of RCC's consideration of the planning application so as to properly identify the rational for such a highly disruptive industrial scale project.

 

 

 

205 views0 comments

Recent Posts

See All

Comments


bottom of page