Dorset Council Planning File – P/FUL/2021/01018
LATEST:
Following the latest representations, it seems likely that the North Dairy Farm Solar planning application will be presented to the Planning Committee, possibly 19th June 2023
Strategic and Technical Planning Committee
Save Hardy’s Vale – Letters to the Planning Officers
Since the North Dairy Farm Solar application was submitted in 2020, the need to address the climate and ecological emergency has become even more urgent. The war in Ukraine has exacerbated a food and energy/fuel security and supply crisis – and Dorset homes and fields have been lost to fires caused, in part, by climate change. There surely cannot be anyone in the planning process who opposes the switch to low-carbon energy.
Recent Government papers, including the Energy White Paper (2020), the 10-point plan for a Green Industrial Revolution (2020) and the Net Zero Strategy: Build Back Greener (2021) all stress the need for renewable green energy, but they also underline that the change must: “not at the expense of the environment they are trying to protect.”
It seems years since the “huge” Industrial solar development at North Dairy Farm was proposed. That’s because it is years! Way back then many in the community took the time to write to the Dorset Council pointing out the material planning reasons why the proposed site is so unsuitable for development.
The Case Officer may soon present his report and recommendation to the Council’s Strategic & Technical Planning Committee.
IMPORTANT
The Council will notify everyone who wrote to them as soon as the date is confirmed and the Officer’s report is published on the planning file – usually a week before the meeting.
The meeting (Dorset Council Offices in Dorchester) is open, and you are welcome to attend and listen to the Committee Members’ debate. Should you wish to speak at the meeting (strictly relating to material planning matters, and very strictly 3 minutes) you will need to apply 2 working days in advance, in accordance with the Council’s Guidance.
Even if you do not wish to speak, simply your presence will help the Councillors better understand the near-universal opposition to the inappropriate industrial development of a highly sensitive and valued landscape.
Many in the community have kept informed about the pertinent material planning matters, by following the progress of the Application via Save Hardy’s Vale Facebook and Web pages. All our letters to the Council highlighting the faults in the developer’s proposals are available on the Council Planning File, or on our Letters Page.
As a New Year’s resolution, attending more meetings may not be top of your list – but this one is important – so we hope to see you there! We now await the Officer’s recommendation and confirmation of the meeting dates.
Our Interest: ‘Save Hardy’s Vale’ (SHV) is an unincorporated community association formed to protect 77 Ha of productive agricultural land in a ‘highly valued landscape’, within the impact zones of the Blackmoor Vale Commons and Moors Site of Special Scientific Interest (SSSI), the Rooksmoor Copse Special Area of Conservation (SAC), and the Alner Gorse Butterfly Reserve. The proposed Site is in the setting of the Dorset AONB and would impact the settings of two protected Conservation Areas, many listed buildings and heritage assets. It also would be in an area that the Dorset Council identified as very highly sensitive to large-scale development, and which it considers having the qualities of a National Park.
The expert Landscape Assessment identified that: “The Applicant’s Environmental Statement generally underestimates the Site’s visibility in the wider landscape and that the development would cause harm to the setting of the AONB and to the valued landscape of the Site and its surroundings in the Blackmore Vale.
Walking down from Hazlebury Bryan, heading for the footpaths that cross the proposed development, the red line illustrates the clear view of only four of the eleven agricultural fields that would be covered by the “incongruous industrial development in a valued agricultural landscape” as it was described in a recent Appeal Decision.
The North Dairy Farm application is for a major solar installation within the setting of the Dorset Area of Outstanding Natural Beauty (AONB). The Chair and Members of Dorset Council’s Strategic and Technical Planning Committee have stated that the setting of the AONB is a designation of national importance with the highest status of protection in relation to landscape and scenic beauty.
Decision-makers are required to pay attention to the national status of AONB. The Management Plan for the Dorset AONB states: “Where visible from the AONB, the surrounding landscape, which is often of significant landscape value, is an important element of the AONB’s natural beauty. Relevant local planning authorities must have regard for the landscape and visual impact of major development adjacent to or within close proximity of the AONB’s boundary.”
Solar Carbon costs!
By comparison with off-shore wind, solar farms are hugely inefficient. A 140-acre solar park is said to be capable of supplying electricity to about 9,000 homes. One wind turbine in the North Sea has the capacity to power 16,000 homes. In terms of efficiency rating i.e. the amount of power exported to the grid, Solar’s rating is between 11 and 15% whereas for off-shore wind the figure is 50%+. On one day last year, it has been reported that 78% of the UK’s electricity came from off-shore wind.
The Carbon Intensity of wind generation at 21 CO2-eq kg/MW-he is over five times lower than PV solar panels at 106 CO2-eq kg/MW-he, and wind turbines have a Carbon footprint some eleven times lower than PV solar. Of course, we need to utilise solar, but as the Government says, on brownfield sites, car parks and roofs etc. Dorset Council set out a host of good reasons to look after our ‘valued’ and designated landscapes.
SEE HOW OUR ENERGY IS BEING GENERATED RIGHT NOW
EXPERT OPINION IS OPPOSED
Council’s Landscape Architect
In her comments of 25/03/2022, Helen Lilley The Council’s Landscape Architect noted that “at 77ha the proposed development would be one of the largest solar PV developments in the southwest” and that the proposed development “would result in a significant change in the character of the local landscape and would also adversely affect the setting of the AONB, most particularly given the interrelationship between the clay/rolling vale character of the local landscape that the site is located in, and the chalk escarpment landscape of the AONB”. She also noted that “there would be significant adverse effects on views from Rights of Way to the east of the site, most especially where these extended across the site to Dungeon Hill Scheduled Ancient Monument/the AONB to the west”.
She stated that in her opinion the proposals did not comply with the requirements of paragraphs 154 and 170 of the NPPF (now 158 and 174 of the NPPF 2021) or policies 3, 4, and 22 of the North Dorset Local Plan and that as a consequence she could not support the application.
Save Hardy’s Vale – Letters to the Planning Officers
“WE WILL ADOPT A ‘BROWNFIELDS FIRST’ POLICY” Richi Sunak at Prime Minister’s Questions 20th October 2022, in answer to a question about development in the countryside.
“Finalised and fully justified”
The infiltration-based drainage system of swales, proposed in September 2021, has now been superseded, and the council’s flood risk management team have asked for a “FINALISED AND FULLY JUSTIFIED DRAINAGE SYSTEM” TO REDUCE THE INCREASED RISK OF DOWNSTREAM FLOODING THAT THE IMPERVIOUS PANELS POSE”.
The Prime Minister, in his COP 27 Statement to the House of Commons said “Community support is vital”. For onshore energy developments, the PM said: “It is right that we bring people with us as we transition to net zero. The worst thing we can do is alienate communities if we want to actually deliver on our climate commitments. As it turns out, we are lucky to have a very reliable and very affordable form of energy in offshore wind, which is also creating jobs domestically in the UK. It is right that that is our priority”.
As the recent House of Commons debate about solar demonstrates, many MPs (and Councillors) are now extremely concerned about the food ‘agricultural emergency’, and the loss of productive farmland, while also supportive of the change to the lowest carbon-cost energy generation – wind, which is targeted by the Government to supply all homes in the UK by 2028.
Here is the UK’s energy generation mix right now!
GOVERNMENT GUIDANCE
How can local planning authorities identify suitable areas for renewable and low-carbon energy? Where possible, ground-mounted Solar PV projects should utilise previously developed land, brownfield land, contaminated or industrial land.
In considering locations, local planning authorities will need to ensure they take into account the requirements of the technology and, critically, the potential impacts on the local environment, including cumulative impacts. The views of local communities likely to be affected should be listened to – while ensuring that adverse impacts are addressed satisfactorily (including cumulative landscape and visual impacts).
URGENT UPDATE – 12th SEPTEMBER 2022
“WE ARE REVIEWING THE SITUATION”
Significant revisions to the North Dairy Farm Solar Planning Application, brought about by the pre-March 2022 consultation responses of Dorset Council’s Landscape Architect, the AONB Officer and the representations from ‘Save Hardy’s Vale’, mean the Application will not be presented to the Council’s Strategic and Technical Planning Committee on the 11th of October. The latest significant changes are in addition to the major revisions made by the Applicant earlier in the year following the representations.
All those who wrote to the Council opposing the development will be notified of the delay, and (when known) of the new date for the Committee Meeting,
The Applicant’s revised and additional documents can be viewed on the Council’s Planning Register.
All your existing comments will be taken into account. Please note that any comments received will be published on the Council’s website. In the event of an appeal, it will also be copied to the Planning Inspectorate.
NB Comments should address the amendments to the Application. The points you have already made need not be repeated.
Green balance and the carbon cost
Recent Government papers including the Energy White Paper (2020), The 10-point plan for a Green Industrial Revolution (2020) and the Net Zero Strategy: Build Back Greener (2021) all stress the need for renewable green energy, but they also underline that the change must: “not at the expense of the environment they are trying to protect.”
Solar power from roof-tops and brownfield sites is encouraged by the Government. But, to suggest that “renewable energy has to take precedence over everything else” is simply wrong. Paragraph 155a of the NPPF says that local plans should provide a “strategy for energy…while ensuring that adverse impacts are addressed…including cumulative landscape and visual impacts.”
GOVERNMENT POLICY
In April this year the Government announced: “For ground-mounted solar, we will consult on amending planning rules to strengthen policy in favour of development on non-protected land while ensuring communities continue to have a say and environmental protections remain in place.”
Source: https://www.gov.uk/…/british-energy-security-strategy
There is a balance to strike between the need to secure our energy future, and clean up our energy sector – while preserving the UK’s productive agricultural landscapes and natural environment for future generations.’ Wind turbines can produce far more power than solar panels, and at significantly lower Carbon costs.
A large-sized wind turbine is able to generate the same amount of power as almost 50,000 solar panels.’ The energy produced by wind at night can be stored, or used to generate energy (e.g., pumped storage) or to produce clean fuel, for example, Hydrogen by electrolysis.
When it comes to reducing global warming, wind energy is the big winner. The Carbon Intensity of wind generation at 21 CO2-eq kg/MW-he is over five times lower than PV solar panels at 106 CO2-eq kg/MW-he. and, as noted previously, wind turbines have a Carbon footprint some eleven times lower than PV solar.
The government is committed to supplying energy to all the homes in the country from offshore wind by 2028*. The Secretary of State Kwasi Kwarteng has stated* that wind energy supply is being brought onstream quickly. The Ministerial Statement effectively brings the previous target date forward two years by increasing the offshore output from 40 to 50 GW. – at a much lower carbon cost than solar.
After very serious concerns about the North Dairy Farm Solar Planning Application were voiced by Dorset Council’s Landscape Architect, the Dorset Area of Outstanding Beauty’s Landscape Planning Officer and the Save Hardy’s Vale group, the Applicant has completely re-assessed the ‘Landscape and Visual Impacts’ the solar generating plant would have on the countryside around it. Sure enough, all the impacts examined caused effects that are “adverse“. Now, a host of additional “mitigation” proposals have been put forward in an attempt to cover up or hide 190 acres of an industrial power plant. The revised report has now been submitted to the Council, and is available on the Council Planning Portal, Remember to click the ‘Accept’ Conditions button at the bottom of the page, and then select ‘Documents’.
A copy of the main document is also available here.
March 2 Update:
Major changes to North Dairy Farm Solar, Environmental Statement
The key revisions stem from the additional landscape assessments asked for by the Council, and the extra mitigation planting proposed by the Applicant in an attempt to reduce the detrimental visual impact of the development that we (and the Applicant) have identified.
We have very serious reservations about some important omissions, judgments and the findings presented in the revised document, and with the conclusions drawn by the Applicant that, given time, the 190-acre generation plant would hardly be seen!
But it now is clear the development would be in full view from the North Dorset AONB, on productive agricultural land, that is prone to flash flooding, which, in places, is a threat to life.
The site is in a highly valued landscape that Dorset Council is considering should be designated as a National Park. It is within the impact zone of the Blackmoor Vale Commons and Moors Site of Special Scientific Interest (SSSI), Rooksmoor Copse Special Area of Conservation (SAC), and Alner Gorse Butterfly Reserve. It is also an area that Dorset Council considers to be very highly sensitive to large-scale development.
A past Secretary of State said: ‘Meeting our energy goals should not be used to justify the wrong development in the wrong location and this includes the use of high-quality land. Protecting the global environment is not an excuse to trash the local environment.’
The proposed development, by reason of its size and scale, and taking into account the topography and contours of the application site and surrounding land, would be highly visible, and be an incongruous addition, out of keeping with the rural landscape character of the area.
The Applicant’s revised assessment identifies the area to have medium to high landscape value and medium to high susceptibility and sensitivity to the proposed development.
The landscape character
The Blackmore Vale Landscape Character Area and Clay Vale Landscape Character Type have – high sensitivity to development. South Blackmore Rolling Vale has – high sensitivity, and for landscape receptors within the Dorset AONB, the Blackmore Vale and Clay Vale LCT have – high sensitivity, due to their key visual and perceptual characteristics of, ‘vast open skies with a strong sense of rural tranquillity.’ The North Dorset Escarpment and Chalk Ridge/Escarpment also have – high sensitivity, due to their key visual and perceptual characteristics.
Site visibility underestimated
The SHV Landscape Assessment identified that the Applicant’s original Environmental Statement generally underestimated Site visibility in the wider landscape. We believe that has not significantly changed.
The Blackmore Vale is a valued landscape for the purposes of the National Planning Policy Framework (NPPF), Paragraph 170a. This is mainly, because of its perceptual qualities. It is a robust and intact landscape with a pastoral and tranquil character. It has longstanding dairy farming traditions, the historic association between escarpment-located Iron Age hillforts which have directed the evolution of the Vale’s agriculture and settlement patterns, and internationally renowned cultural associations of Thomas Hardy and William Barnes. The related tourist trade is strong.
The application is for an industrial scale of development alien to the highly sensitive, undeveloped and rural location. The Site covers a total of 77 Ha, of which approximately 55 Ha would contain solar panels, fencing, numerous ancillary buildings and structures, a substation, large pylons, 3-metre-high security cameras and vehicular access tracks.
However, these highly visible ancillary structures are hardly mentioned in the revised assessment. In fact, they are omitted from the images and almost ignored as simply ‘energy infrastructure’ comparable to the four existing “wooden” powerline pylons which traverse part of the proposed site, as evidenced by the Applicant’s images, which are barely visible in the landscape. The “wooden” pylons are actually metal!
Landscape
Planning Practice Guidance (PPG) advises that the deployment of large-scale solar developments can have a negative impact on the rural environment, particularly in undulating landscapes. The area is identified by the Applicant as “undulating”.
The proposed mitigation enhancements are still meagre in relation to the scale of the proposed development. They provide ecological benefits no more extensive than might be expected as the good husbandry of a responsible farm landowner. They also do very little in terms of protecting the visual amenity in respect of the development proposals, as partly confirmed by the Applicant’s submitted photomontages.
Though all Applications have to be considered on their own merits, the ‘Tithe Barn Lane’ Appeal Decision is very pertinent to the NDF proposals. The Inspector notes: “Significant mitigation measures are proposed.” And “Additional planting “would itself be visually intrusive by undermining open views across the site. Furthermore, vegetation, even if standard plants are used, would take some years to become effective. In the interim, there would be clear views from the footpaths and roads of the many rows of solar panels, which would be no lower than 2.6 metres in height and which would block all views across the site. Their industrial appearance would be alien in this countryside location and the solar panels, in views from footpaths and roads around the site, would have a significant adverse effect on the visual amenity of the area.” The same can be said for the NDF site.
1750 and on!
The Applicant suggests that significant changes to the field boundaries have taken place since 1888 and that the fields “generally have lost their historic hedge field boundaries” This is overstated, misleading and not the full story – see 1888 map (left) and 2022 (right).
Despite the more recent change, a comparison between the modern fieldscapes and the 25-inch Ordnance Survey map, and the three relevant tithe maps shows that the pre-1750 post-medieval field patterns are still highly legible within the site.
We believe it is unreasonable for the Applicant to suggest that the “energy infrastructure” shown in Viewpoint 1, from Footpath N49/11 (below) contributes to a “significant utilitarian element in the wider landscape.” However, ironically, the development application proposes all of these features in vastly increased quantities over 77 Ha of the receiving landscape.
While smaller developments might potentially be effectively screened, it is close to certain that a 77 Ha development cannot be hidden, as the location includes some exposed undulating slopes which are visible in the same context as more distinctive parts of the chalk escarpments in the south. From there, the proposed infrastructure would detract from the green, patchwork character of the landscape, as observed from other elevated viewpoints close to the proposed Site, and from within the setting of the AONB. The landscape sensitivity is also higher because some of the NDF eleven fields are ‘small and irregular’ and ‘uniformly pastoral’.
We agree that the views gained from the higher-lying vantage points on the high escarpments are so extensive that, by comparison, the size of the proposed site would form a “very small part” of the wide uninterrupted panoramic views across the Blackmore Vale. However, from those high viewpoints, it is possible to see across the county into Devon and Somerset and on to the Mendips, some 36 miles north-west. In that context, 77 Ha might well be considered just a small part within such an extensive uninterrupted panorama – but, the proposed industrial site of glinting reflective glass, a small village of 37 transformers and inverters and a sub-station, would certainly be seen, and despite the extensive mitigation proposed, would cause adverse effects.
We believe the Applicant’s assessment underestimates that harm, and that we are supported in that conclusion by many of the images presented in the revised Environmental Assessment.
The Applicant concludes in the revised EA Chapter 6. That there: would not be any significant adverse or visual effects in the longer term caused by the proposed development. Our considered opinion, informed by the evidence presented in the revised Applicants EA/LIVA, the SHV Landscape Statement, and the Wyvern Heritage and Landscape Submission, lead us to echo the words of the AONB Landscape specialist in regard to the original assessment: “the (Applicants) conclusions are not based on evidence sufficient to clearly justify these conclusions.” and are therefore unjustified.
Temporary and reversible?
The Applicant suggests the proposed development is temporary (35 years). However, in the Tithe Barn Lane Decision, the Inspector effectively demolished the “temporary” nature of a similar scheme, noting: “25 years, however, is about a third of a person’s lifetime and is the span of a generation. Furthermore, there is no guarantee that planning permission would not be granted, after 25 years, for the replacement of the solar panels for a further period. Very little weight is therefore given to the reversibility of the scheme.”
Lastly, and from the same Appeal Decision: “Significant mitigation measures are proposed” and “but that would itself be visually intrusive by undermining open views across the site. Furthermore, vegetation, even if standard plants are used, would take some years to become effective. In the interim, there would be clear views from the footpaths and roads of the many rows of solar panels, which would be no lower than 2.6 metres in height and which would block all views across the site. Their industrial appearance would be alien in this countryside location, and the solar panels, in views from footpaths and roads around the site, would have a significant adverse effect on the visual amenity of the area.”
We contend that this opinion is equally applicable to the North Dairy Farm Solar proposal.
You can write to:
Case Officer: Rob McDonald – Major Projects Officer Planning Team D Development Services South Walks House
South Walks Road
Dorchester
Dorset
DT1 1UZ
planningnorth@dorsetcouncil.gov.uk;
Remember to include the application number: P/FUL/2021/01018
A copy of the Applicant’s amended document is also available here. The main changes include:
• Updated Landscape and Visual Impact Assessment (LIVA) methodology;
• Supplementary details on existing local views towards the Site and the existing character of the Site and the local landscape;
• Supplementary details on existing views to/from the Site and the Dorset AONB and the existing landscape character of the Dorset AONB;
• Updated landscape and visual receptor sensitivities;
• Supplementary details on the magnitude of landscape and visual effects;
• Updated assessment of the significance of landscape and visual effects; and
• Updated summary and conclusions.
For ease of reference, the key updated parts of Chapter 6 have been highlighted in yellow.
In the meantime…….
Flooding, hydrology and drainage
You may have read (below – January 2022) that we had written to the Council again about the very serious concerns we have about the Applicants ‘Flood Risk Assessment’ of the proposed site. We commissioned Hydro-gis Ltd to assess the flood issues at, on and around the Site, and asked them to also examine the technical aspects of the Applicants ‘Flood Risk Assessment.’ That ‘Hydrological Review’ is now with the Council, and available here. Our summary of the Review is posted here.
The key points of the Review are:
The Review finds the Flood Risk Assessment lacks necessary detail and presents no results of site investigations. The background information is limited, with no predicted flood levels identified, and the assessment of risk from the development is based solely on the Cook and McCuen findings, which are not appropriate for the local conditions at the site. The impact that the impermeable PV panels have, on surface runoff rates and times to peak flow is considered in our previous comments and Letters of Representation.
Estimates of greenfield surface runoff in the ‘Flood Risk Assessment’ are based on an outdated method that is conceptually and mathematically wrong. The results of drainage design software are not properly discussed and remain highly questionable.
Proper estimates of greenfield surface runoff, using the ReFH2 software in accordance with Sustainable Drainage System (SUDS) guidelines will be needed, along with field measurements of soil infiltration and groundwater measurements, to inform the detailed design of any proposed drainage features, should also be included.
The Review also highlights the cause, source, nature and intensity of the flooding which is significant in this area i.e., “unpredictable rapid discharge and flash flooding” primarily caused by the exceptionally high rainfall and runoff from the high escarpments overlooking the Blackmore Vale, which in places is a risk to life at the site.
Critically, the FRA does not demonstrate that the existing surface runoff rates can be matched or reduced, and the risk of downstream flooding is not appropriately considered.
The EA Flood Zone Mapping is not considered (by the Environmental Agency) as suitable for detailed flood risk assessment, and therefore, ‘hydraulic modelling’ should be undertaken to better define flood extents and more accurate flood levels.”
It is also suggested in the Review that a revised Flood Risk Assessment is needed, which must include estimates of the design flood levels at the site, based on detailed hydrological and hydrodynamic modelling.
TURNING A BLIND EYE TO ODOROUS COMPARISONS
Water, and hiding large objects!
We all have read news reports which compare surface area or volume to tennis courts, football pitches or Olympic swimming pools. Maybe reporters assume we would not recognise a square metre if we were given one, but that somehow, we are all very familiar with Wimbledon, Wembley or Adam Peaty!
So, with tongue in cheek, and to help the Spetisbury Parishioner, who, according to the Daily Mail, recently considered it quite possible to hide a 190-acre solar power station behind a hedge, in a “dip in the landscape” – we offer this nautical comparison:
A 190-acre solar power development site, with 37 three-meter high-security camera posts, a small town’s worth of inverter and transformer cabins, and an electricity substation, surrounded by an impenetrable security fence, would cover an area of productive farmland equivalent to 47 and a half Queen Elizabeth Class Aircraft carrier flight decks! The deck in the image represent just 4 of the solar power station’s 190 acres.
If you really do know of an effective way to hide the deck of one of the Royal Navy’s carrier strike group ships behind a hedge, or in a “dip”, then the Admiralty camouflage department would love to hear from you!
As Horatio said “I have only one eye. I have a right to be blind sometimes”
January 2022
Surface runoff underestimated
We believe that, just as with the visual impact of the Site, the Applicant has ‘generally underestimated’ the surface runoff and offsite flooding, and ignored the effect of the predicted reductions in the time to peak flow from the proposed development, The Applicant suggested from the beginning, that perfect grass would avoid the need to provide Sustainable Drainage Systems (SuDS) for the PV panelled areas. They also said that sustainable drainage, and undertaking soil infiltration tests, would be unnecessary. Following the SHV representations last September (2021), about flooding and surface runoff, the Applicant finally changed tack and proposed an infiltration-based ‘Sustainable Drainage System (SuDS), incorporating swales. Apparently, this proposal has been “approved?” However, the applicant appears to have ignored the clear warning in their ‘Flood Risk Assessment’ (FRA), in paragraph 4.33, that: “The reported hydrological characteristics of the Site suggest that infiltration may not be feasible”.
Imperative to test
The Council’s ‘Strategic Flood Risk Assessment‘ also states: “For proposed developments, it is imperative that Site-specific infiltration tests are conducted early on as part of the design of the development, to confirm whether the water table is low enough to allow for SuDS techniques that are designed to encourage infiltration”. Without the results of these tests, it is impossible to be confident that the “outlined” drainage system would comply with the Guidance, to avoid, reduce, delay and manage surface water flows, or mimic the existing greenfield surface runoff volumes, and critically, reduce downstream flooding at the times of peak flow.
Time to call in the experts
We have again written to the Case Officer and also engaged an appropriately qualified hydrologist. We hope to have an independent expert report and findings by mid-February, and we will, of course, forward it to the Council.
Our latest comments to the Council are here
December 2021
THE DEVELOPER ASKED TO ‘LOOK AGAIN!’
In our Letters of Representation to the Dorset Council, objecting to the North Dairy Farm Solar proposal, we made the point that the developers had consistently, and significantly, underestimated the detrimental visual impact the solar generating plant would have on the surrounding valued landscape,
The SHV expert assessment noted: “The site is located in a landscape that is highly sensitive to large-scale solar PV development and although the proposals include mitigation measures, I do not consider that these measures would satisfactorily offset the moderate-high adverse magnitude of change which would occur. This would result in a significant change in the character of the local landscape and would also potentially adversely affect the setting of the Dorset Area of Outstanding Natural Beauty (AONB)”.
The applicant has now been asked by Dorset Council to provide some additional images, taken from public viewpoints, to widen the scope and inform their Landscape and Visual Impact Assessment (LVIA). This means that they will need to wait to take some more photos during the winter months. So a decision on this controversial application is not likely until the early part of 2022.
We understand that in the event that the Case Officer recommends the development be approved, the application will be presented at the Dorset Strategic Committee for the Council Members to consider.
The ‘Save Hardy’s Vale’ Landscape Statement and Letters of Representation are available below.
The Save Hardy’s Vale community group has written letters of representation to Dorset Council opposing the solar development, on material planning grounds. The documents are also available here:
1. SHV LOR ( MAIN DOCUMENT) with Annex 1. Landscape Statement Report Summary
2. SHV Landscape Statement A prepared by Phillip Hanson CMLI of The Landscape Practice
3. SHV Landscape Statement B prepared by Phillip Hanson CMLI of The Landscape Practice.
4. Heritage Submission – Wyvern Heritage and Landscape – Emma Rouse MCIfA MA BA Hons
5. SHV Memorandum on Flooding and Run-off
6. SHV Memorandum on Ecology and Biodiversity
7. CPRE Report Renewable Energy Projections – David Peacock
8. Cook and McCuen Hydrologic-Response-of-Solar-Farms
9. SHV Memorandum to the Case Officer ( BSR Rebuttals & flooding and drainage issues ) Sent 14th November.
10. SHV Comments about flooding – to the Case Officer – January 2022 – Case Officer Rob McDonald
11. Hydro-GIS Ltd Hydrological Review February 2022
12. Save Hardy’s Vale Summary Response to Hydro-GIS Review
13. SHV Representation – Chapter 6 of the Environmental Assessment Revisions
14. SHV Comments about the Flood Risk Assessment March 2022
15. SHV Comments about the Application updates (September 2022)
16. SHV Additional comments about flood risk – October 2022
17. SHV Additional comments about the ‘settings’ of protected areas December 2022
18. SHV Impervious surfaces of the panels leads to increased surface runoff – email 29/10/2022
19. SHV Comments about the Applicant’s Alternative Site Assessment February 10th 2023
20. SHV Note – The Site is in a “highly valued” landscape in NPPF 174a terms, and should be protected
21. Introductory email to Members of the Strategic and Technical Committe 10/4/2023
22. SHV Memorandum highlighting material planning matters 10/4/2023
TLP Viewpoint 5
Nature of the View: Minor Road at the head of public bridleway N52/5, Dorset AONB and Wessex Ridgeway
From a minor road on the north side of Bulbarrow Hill on the chalk escarpment by Rawlsbury Camp iron age fort scheduled monument and within the Dorset AONB. The very popular and well-used Wessex Ridgeway long-distance path follows the lane at this point. Forming part of a panoramic view, the proposed development site is viewed at a distance but it lies centrally within the vale which is the focus of the view northwards. This view is taken approximately 400m northeast of the applicant’s submitted Photo Viewpoint 5, the only illustrated view from the escarpment, which shows an unrepresentative glimpsed view towards the Site.
Recreational users and motorists – the former will most likely be walking the long-distance footpath for the recognised views over the vale.
The 190-acre industrial-sized electricity generation plant would be in full view from the highly protected North Dorset Area of Outstanding Natural Beauty, and on agricultural land which is prone to flooding. The proposed site is in a highly valued landscape that Dorset Council is considering should be designated as a National Park. It is within the impact zone of the Blackmoor Vale Commons and Moors Site of Special Scientific Interest (SSSI), Rooksmoor Copse Special Area of Conservation (SAC), and Alner Gorse Butterfly Reserve. It is also an area that Dorset Council considers to be very highly sensitive to large-scale development.
‘RUNNING OFF’ Dorset planning policy 4.27 requires that “hard surfaces should be avoided and wherever possible removed through development.” It is proposed by the developers to increase the hard surfacing on the site by installing approximately 71 acres of impervious PV panels. That is approximately equivalent to the hard surfaces of 3800 new homes. (On average 2300 are built-in Dorset each year.) Imagine all those homes without drainage systems, on a greenfield site that surface floods, surrounded by high-risk flood zones and roads that are often made impassable by unpredicted flash flooding. It just would not be allowed – would it?
The viewpoint is located on the public footpath on a small knoll just south of the proposed development Site. A wide view of the Site is
visible over a wide area and in varying degrees over approximately 600m of the footpath. The view angle shown is approximately 135
degrees. Boywood Farm is located on the right-hand side of the photograph. The image only shows 4 of the 11 fields of panels.
The application P/FUL/2021/01018 and support documents are available on Dorset Council’s planning register Please note that when visiting the register you first have to ‘accept’ the Council’s Copyright and Disclaimer conditions at the bottom left of their web page. You can then select the ‘View Documents’ tab.
Here are some example letters of objection
Another letter of objection to the North Dairy Farm Solar development, sent to the planners by the Dorset Ramblers about their concerns, is an excellent example.
Case Officer: Rob McDonald – Major Projects Officer Email: robmcdonald@dorsetcouncil.gov.uk
Support Officer Mrs Jackie Witt – Planning Technical Support Team Leader – Northern Area Email: planningteamd@dorsetcouncil.gov.uk Tel: 01305 838336
Or you can write to:
Case Officer: Rob McDonald – Major Projects Officer Planning Team D Development Services South Walks House
South Walks Road
Dorchester
Dorset
DT1 1UZ
Remember to include the application number: P/FUL/2021/01018
Please visit ‘ ‘Writing to the planners‘ and ‘Why refuse the application‘
Planning an objection If you want to write a good quality planning objection letter, the best place to start is with all of the facts. The best place to find them is in the planning application, which is held (online) in the Council’s planning office.
Next, you’ll need a basis of objection founded on valid, material planning reasons. Hearsay, speculation, allegation and rumour need to be completely ignored – focus on the facts and you’re halfway there! Remember, a strong opinion does not make it a fact!
It is the soundness of the points, particularly regarding material planning considerations, that are raised, rather than the number of comments, which are important in the planning Case Officer’s assessment of the application and the final decision.
In writing a letter of objection, the biggest mistake can be making your letter too personal. It is tempting to do that when you feel strongly or outraged about the proposal. But it will only weaken your case if you include points that have no relevance to the lawful planning guidelines that planners will weigh the proposal against.
More information about writing a letter of objection to the planners
Here are some example letters of objection
Wind generation costs us less carbon than solar
On a windy, dull April morning, wind accounted for 51% of UK electricity generation (coal at 0%) with a remarkably low overall carbon intensity of 35 gCO2/kWh – and Solar is providing 7%. – at a carbon cost of 110 gCO2/kWh. – 4.4 times as much.
The proposed site is in a landscape area that Dorset Council is considering designating as a National Park.
It’s the ‘biggest’ Hardy called it the Vale of the little dairies. The proposed solar power station cannot be called ‘little’. In fact, it would be ‘a a giant’. A mile from north to south and two-thirds of a mile east to west. Covering green fields equivalent in area to nearly 105 Wembley Stadium football pitches! But, the developer’s claim that ‘it will hardly be visible in the environmentally sensitive landscape is completely at odds with Dorset Council’s opinion that “The development is likely to result in a marked change to a significant area of the Blackmore Vale landscape when viewed from high viewpoints in the AONB.”
In and out of the AONB The proposed giant solar plant, with nearly 9.5 kilometres of perimeter and internal security fence and 123 x 6-metre high camera posts (every 50 metres or so), if approved, would cause visual harm to the surrounding highly valued landscape, to the setting of the nationally protected Dorset Area of Outstanding Natural Beauty and to two Conservation Areas. The site would be completely changed from a rural to an incongruous industrial one.
The numerous uninterrupted panoramic views from public roads, footpaths and bridleways which run through the site and along the escarpments above the vale, (views from within and into the designated areas) would suffer significant visual harm. The high escarpments of AONB also form the backdrop to the proposed site and the surrounding villages – two of which are Conservation areas peppered with significant heritage assets.
Our cultural heritage Thomas Hardy called the area surrounding the proposed site the Vale of the Little Dairies. It is not just Angel Clare who walks the paths and byways of the beautiful Blackmore Vale! Many come from around the world, carrying their thumbed copy of ‘Tess’. and following Angel’s path. There are plenty of good lines from Hardy describing the vista from the escarpment which the traveller is “surprised and delighted to behold”. Those looking out from the high footpaths which surround the site will be suppressed to see 14 inverter and transformer units dotted about what was green fields!
The wrong time? – and definitely in the wrong place! Increasing the amount of energy from renewable and low carbon technologies is helping to make sure the UK has a secure energy supply and reduce greenhouse gas emissions to slow down climate change. Planning has an important role in the delivery of new renewable and low carbon energy infrastructure in locations where the local environmental impact is acceptable – Hardy’s Vale is not an environmentally acceptable location.
“There is a balance to strike between the need to secure our energy future while preserving the UK’s natural environment for future generations.” Offshore wind is an important clean energy source for the UK and can provide a considerable source of ‘home-grown’ energy with minimal CO2 emissions. The energy produced is also significantly cheaper per kW than solar.
Coal generation has fallen by close to 60% and accounted for just 2% of UK electricity last year – less than solar. Some 54% of electricity generation in the UK is now from low-carbon sources, including 37% from renewables and 20% from wind alone.
What bad timing! The Prime Minister announced (6th October) that, in future, off-shore wind turbines will provide for the green energy needs of all homes in the country. How foolish it would be to trash 190 acres of food productive farmland when Government has announced this policy change. The Green Party puts offshore wind at the top of its list of low carbon energy production. The high-cost solar power station proposal comes at the wrong time – and certainly would be in the wrong place!
The MacKay Carbon Calculator
The levels of ambition
Teacher resources
The project
Contact us
Reduction in carbon intensity.
The carbon intensity of electricity generation decreased by 55% between 2008 and 2018, from 535 gCO2/kWh to 245 gCO2kWh. That reflects a shift away from coal towards gas and renewable generation). Nuclear also contributes to low-carbon electricity generation. In 1990, coal generated 80% of UK electricity. Following the ‘dash-for-gas’, that share dropped to 30% where it remained stable until the early 2010s. The introduction of the carbon price floor in 2013, alongside air quality legislation, initiated the phase-out of coal-fired generation. This has contributed to sustained emissions reductions in the sector of 14 MtCO2 per year on average since 2013.
Energy generation is now low carbon Low carbon energy has helped the UK to almost eliminate the use of coal for electricity generation over the last 10 years. The carbon intensity of generation decreased by 55% between 2008 and 2018, from 535 gCO2/kWh to 245 gCO2/kWh. That reflects a shift away from coal towards gas and renewable generation – and offshore wind is set to supply low carbon energy to all UK homes by 2030.
As I write (on a windy, dull Sunday morning) wind accounts for 51% of UK electricity generation (coal at 0%) – with a remarkably low overall carbon intensity of 35 gCO2/kWh – and Solar is providing 7%. – at a carbon cost of 110 gCO2/kWh. – 4.4 times as much.
Here is the UK’s energy generation mix right now!
Buildings and transport – the biggest sources of greenhouse gas emissions But, our drive for carbon net-zero is being undermined. “Emissions from buildings and transport have flatlined over the last 10 years. If we don’t have effective programmes to tackle this, we have no hope of meeting the net-zero target” and will waste the huge low carbon ‘gains’ made by the generation industry.
Biodiversity is key to the survival of life on Earth. Its loss deprives future generations of irreplaceable genetic information and compromises sustainability. The recent National Ecosystem Assessment also shows just how much nature provides for us in this country. For example, the enormous value of the countryside to water quality., the value of pollination to agriculture, the health benefits of experiencing nature and, not least, how nature and wildlife enrich all our lives. The proposed site is surrounded by the river catchment area which feeds the Stour.
Bournemouth University studies have shown that of four future scenarios, ranging from high investment in natural recovery to high agricultural intensification, the highest economic returns are found by investing in nature.
Reduction in people’s emotional connection to nature Fencing off 190 acres depletes ‘nature’ and would create an industrial landscape.
Nature depletion is also making it harder for people to connect with nature. Forming an emotional connection with nature and retaining memories of the enjoyment of nature are important factors in maintaining mental health. It is also an important determinant in forming pro-environmental behaviour, essential for the wellbeing of future generations.
Good quality natural landscapes, which have a high ecological value, have also been shown to reduce stress and sadness, lift poor mood, and make us feel better, with the relationship being strongest for anxiety disorder and depression.
In terms of physical health, our use of our natural world, particularly greenspace, is associated with lower rates of disease, reduced risk of developing type 2 diabetes, and cardiovascular disease. People who frequently visit high-quality green spaces are more likely to be physically active and less likely to be overweight or obese. The health benefits of green spaces have been known across the world for time immemorial.
Our fabulous countryside is under pressure from climate change and inappropriate development. Your interest is vital if the towns, villages and very special landscapes of North Dorset are to be protected and enhanced for everyone to enjoy into the future.
Unacceptable harm The National Planning Policy Framework (NPPF) paragraph 98 states that when determining planning applications for renewable energy developments, local authorities should not require applicants for energy development to demonstrate the overall need for renewable or low carbon energy and also recognise that small-scale projects provide a valuable contribution to cutting greenhouse gas emissions and approve the application if its impacts are (or can be made) acceptable.
This is not a small scale project and we believe the proposed solar development would cause unacceptable and, in the light of the Government’s low carbon energy policy, unnecessary harm the setting of the Dorset Area of Outstanding Natural Beauty and the valued landscape surrounding the proposed 190 acre site.
Greening North Dorset Dorset’s farmers play a vital role in helping the county to produce more green energy. Biomass technology has and continues to be an effective way to produce green energy and green fields. Whether it is energy crops such as Miscanthus or maize or agricultural by-products such as manure or slurry; all can be transformed through the use of anaerobic digesters into energy. Green energy for a green planet and a green Hardy’s Vale. The Government already provides financial incentives for landowners to improve the biodiversity of the countryside.
See how much green energy (including Biomass) is being produced now.
Greta is right! Most of us know that the climate crisis is real. We recognise the urgent need to switch to renewable energy and to continue the rapid move away from fossil fuels. But, like many who care about the Dorset countryside and its cultural heritage, we also believe that photovoltaic panels should be on roofs, and brownfield sites, saving on transmission costs by being near main roads and close to where the generated energy is needed. We should not be covering productive farm fields and harming highly valued Conservation Areas and protected landscapes, especially in the astonishingly beautiful countryside of North Dorset.
‘There is a balance to strike between the need to secure our energy future, and clean up our energy sector – while preserving the UK’s agricultural landscapes and natural environment for future generations.’
‘Wind turbines can produce far more power than solar panels. A large-sized wind turbine is able to generate the same amount of power as almost 50,000 solar panels.’
‘We may not have Mediterranean clear blue skies, but the UK is blessed with coastal wind.’
‘Energy produced at night can be stored or used to generate energy (e.g., pumped storage) or to produce fuel, for example, Hydrogen by electrolysis.’
Offshore wind: part of the UK’s energy mix – GOV.UK (www.gov.uk)
The end of coal! In recent years, offshore wind has been a remarkable success story; the UK is a world leader, with around 10 gigawatts now deployed and operational. Offshore generation costs have plummeted. Some of the Contracts for Difference Auctions saw bids of under £40 per megawatt-hour so helping keep the electricity costs for UK consumers under control.
Low carbon energy has helped the UK to almost eliminate the use of coal for electricity generation over the last 10 years. The carbon cost (carbon intensity) of electricity has fallen dramatically during the past decade and that trend is set to continue.
For today’s energy mix and carbon-intensity see: UK Generation (rensmart.com)
Let’s go green! When viewed from above (e.g. from the surrounding escarpments ) the Blackmore Vale appears quite uniform – a large expanse of green, lush, low-lying land which Dorset Council notes is “highly sensitive to larger developments”. The Vale’s fields (as Hardy said) should be green – not shiny black!
Here are links to more information about Dorset’s AONB and ‘Hardy’s ‘Tess’ and the Vale Of the Little Dairies’.
A glaring mistake! The developers, who hoped to apply for planning permission in February (now submitted) suggest in their preliminary landscape assessment, that the solar arrays would hardly be seen – just glimpsed here and there! This is simply not so. The huge development will be seen from many public viewpoints in the surrounding, and highly protected Area of Outstanding Natural Beauty (AONB). At its closest, the AONB is only 1250 metres away. The visual harm the development would cause, to the Conservation Areas and the AONB’s setting in the landscape, are considerations in law the Council simply have to give ‘great weight’ to in the planning balance.
A glint in the eye! Pretending that 151 acres of Photovoltaic glass panels will not be obviously seen is a bit daft! Some solar arrays can be seen from space and anyone who has (in pre COVID times!) looked down from an aircraft will confirm, that when the sun reflects off the solar panels – even those with ‘non-reflective’ coatings, The glare can be easily seen from 12.5 kilometres and more!
Despite the developer’s claims, we believe that walkers, or horse riders using the bridleways to the south, will have a clear view of the very large, incongruous industrial development – especially when the panels glint in the sunshine – or moonlight! From the public footpaths that run through and close to the site, the character of the views and tranquil soundscape will be destroyed!
The views of Bulbarrow, Nettlecombe Tout and Dungeon Hill, from the footpath N46/20 that runs across the site will be obliterated by huge 3-metre high solar panel metal supports, inverters, fencing and a small forest of over 120 x 6-metre high pole-mounted security CCTV cameras.
Well, we could screen! Attempting to hide the visual harm is possible. Screening by vegetation though can be seasonal and may not be effectively in place for the lifetime of the scheme —particularly if not under the control of the same owner. But, no amount of screening will hide 190 acres of black glass and security fencing from the public viewing places along the AONB ridges that surround Hardy’s Vale and the proposed development site.
Harms the setting of the AONB The management team, of Dorset’s Area of Outstanding Natural Beauty, have the overall objective of conserving the patterns and features that contribute to the rural, tranquil landscape of small-scale pastoral fields, winding lanes and small scattered settlements. Without a doubt, the proposed solar farm would cause significant harm to the setting of the protected landscape.
Greater weight to local landscape issues Renewable energy targets should not be allowed to override concerns about the damage solar farms can do to the landscape. As Mrs Justice Lang ruled: ‘As a matter of law it is not correct to assert that the national policy promoting the use of renewable resources negates the local landscape policies’.
The CPRE report (30the June 2019) by D E Peacock (Bsc (Eng) ARSM AMIME CIC PhD showed that North Dorset had exceeded its 2020 renewable energy target.
An expert view The proposed development cannot be successfully assimilated into the receiving valued landscape. It will be visually intrusive because of its industrial character and scale and will be harmful to the setting of heritage assets and to the character of the wider landscape.
Email: planningteamd@dorsetcouncil.gov.uk
An objection – What should I say?
It is important that each response is seen as separate and the view of an individual objector, rather than a recycling of a template letter or pre-determined objections.
Here is our guide to writing a letter to the planning Officers.
If you want to help protect the countryside, in and around the Vale of Blackmore, do let us know via Email at; friends@savehardysvale.com or send us a message here
Planning your objection – one more time! If you want to write a good quality planning objection letter, the best place to start is with all of the facts. The best place to find them in is in the planning application, which is held (online) in the Council’s planning office.
Next you’ll need a basis of objection founded on valid, material planning reasons. Hearsay, speculation, allegation and rumour need to be completely ignored – focus on the facts and you’re half way there! Remember, a strong opinion does not make it a fact!
It is the soundness of the points, particularly regarding material planning considerations, that are raised, rather than the number of comments, which are important in the planning Case Officer’s assessment of the application and the final decision.
In writing a letter of objection, the biggest mistake can be making your letter too personal. It is tempting to do that when you feel strongly or outraged about the proposal. But it will only weaken your case if you include points that have no relevance to the lawful planning guidelines that planners will weigh the proposal against.
More information about writing a letter of objection to the planners
Learn more about the Blackmore Vale here
Being a ‘Friend of Save Hardy’s Vale’ is easy! Just let us know about your interests in the Vale and Dorset Area of Outstanding Natural Beauty. You can contribute to our Web site or Facebook page or simply just keep yourself informed by following our Posts.
To help protect the countryside in the Blackmore Vale just send us an email at; friends@savehardysvale.com – or send a message here.
How much solar energy is being produced right now ? – by wind, nuclear, gas etc.
Guidance from Dorset Campaign to Protect Rural England
Local Generation and Storage of Electricity
Dorset CPRE Report on Dorset Local Authorities Renewable Energy Projections 31 December 2019
Dorset CPRE – Dorset Council Local Plan 2021 Renewable Energy Issues – minor update 13th March 2021
The developer’s preliminary assessments
Ink & Sketches – Anna Ventura Artist
Save Hardy's Vale 