‘Reasonable and Informed’

“In the case of the magnificent panoramic views from the Wessex Ridgeway, the impact on visual receptors will actually be magnified by distance”

“The site lies within an intimate valley landscape and an attractive rural area. It has high conservation interest, high recreational value, and high cultural and artistic associations.”

Over 40 farming families have written to Dorset Council objecting to the proposed North Dairy Farm solar development. Simon Hoare recently wrote: “I know, as your MP, the huge role our farmers play. We live in an area where the long-term future of farming is vital. Much of our landscape and views have been shaped and formed by man’s intervention on the land to produce our food and meld our environment, much of today’s North Dorset could still be recognisable to Thomas Hardy’s characters solely because of farming. 

3rd June 2021

A LETTER OF REASONED OBJECTION

Dear Mr McFarlane

RE: P/FUL/2021/01018 – Proposed Solar Park at North Dairy Farm

I write to object to this proposal in the strongest possible terms for the following reasons.

Severe Damage to the setting of an AONB

The viewpoints the Applicant has chosen in its Landscape and Visual Assessments as being representative of views of the site are but a small sample of the multitude of viewpoints particularly from the Wessex Ridgeway and Bulbarrow.  Where a view is acknowledged, its importance is minimised.   These extraordinary views both encompass the site and extend far beyond.  They are a highly valued landscape that must weigh heavily against such a large development.  The applicant prefaces their section on Types of Visual Receptors in Chapter 6 of their environmental statement with the statement “it is important to note that the sensitivity of a receptor would be modified by distance.”  In the case of the magnificent panoramic views from the Wessex Ridgeway, visual receptors will actually be magnified by distance, introducing a completely incongruous built form in to what is currently a delightful mosaic of fields, hedges and small villages, dotted with woods and isolated settlements. The fields will be blurred into one giant grey field as the highest point of the solar panels will overtop the hedges. The proposed solar power station would be, by far, the biggest industrial development in the upper Blackmore Vale in its history.  It will definitely be noticed and not in a sympathetic way. I took a full frame 35mm lens photograph from the footpath on White Hill (175m ASL) in the lower reaches of the escarpment below Rawlsbury Camp and painted in the fields affected.  It looks as if a vandal has spray painted the valley.  It is graffiti on a landscape scale.

The uninterrupted view from WHITE HILL – Public Footpath N52/6

It seems the Dorset Council Case Officer made the same point when writing to the applicant in September 2020 stating  “The development would also be highly visible in panoramic views from the Dorset AONB located to the south and south east of the site which includes Dungeon Hill Scheduled Ancient Monument. 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. The visual impact is likely to be significant given the scale of development. The significance of these views needs to be assessed in detail particularly as much of the area to the south is designated an AONB and is an important area of outdoor recreation. “

Severe damage to Local Viewpoints

As well as the local footpaths that would effectively be destroyed, the continuous views of the site along the Pleck Hill road from Mappowder  would severely detract from the value of the landscape.  The applicant says this journey would only have fleeting glimpses of the site.  Having driven, walked and cycled this road hundreds of times I know the views will actually be long and continuous.  I recommend planners check this route themselves to judge the Applicant’s claim.

Lack of Dorset County Plan

Due to the merger of the various district councils into a unitary Dorset Council it appears we are temporarily without robust terms of reference as to how the County intends to support Net Zero. I firmly believe that huge applications such as this should not be considered until that plan is approved. Certain parts of the country, such as the South West, also have a higher incidence of solar radiation and a greater theoretical energy potential.  As a consequence, areas like Dorset are likely to experience greater pressure for accommodating landscape-scale PV installations.  These landscape sized developments must be judged by clear criteria laid out by the County.

It seems clear that every area of Dorset and its coastal waters should contribute to net zero in a manner appropriate to the setting.  Dorset’s County plan, currently in consultation, must zone the county for the appropriate uses. I believe it has made a start by creating a zoned map of the county for potential wind turbines.

  • Brownfield sites such as the area surrounding Bournemouth Airport have been correctly chosen for solar parks – one of the UKs largest.
  • Numerous Dorset farms produce energy crops which are essential as back-up energy when the wind doesn’t blow and the sun doesn’t shine.
  • The waters off the Dorset coast could provide substantial wind energy and would supply energy at night and in the winter when demand is expected to rise and when solar can provide very little.
  • As part of the national requirement to plant 30,000 hectares of woodland per annum until at least 2050 – Dorset’s target will need to be 300 hectares per annum. The plan will need to suggest and encourage woodland planting in sympathy with the landscape.
  • Developing energy storage technologies such as green hydrogen and liquid air will also need siting. These will be vital because the massive build-out of offshore wind will periodically create huge excess capacity.

Finally it is to be hoped that Dorset continues to meet its renewable targets. However overshooting the targets would be a mistake for two reasons.  Firstly electricity demand has been actually been falling since 2005 and that is expected to continue for 5-10 years until the electrification of transport and domestic heating causes demand to pick up.  Secondly it goes without saying that renewables technology is moving extremely fast and installations built too early will simply become inefficient white elephants.   

Loss Of Agricultural Land

My wife and I own the farm that is the nearest point of the AONB to the site.  I have repeatedly been approached by solar companies requesting use of the land for landscape scale PV projects.  I have rejected them all because I believe solar, when it makes sense, should be sited in areas with little landscape value. The huge PV Park at Bournemouth Airport is a perfect example – flat land and completely surrounded by woods. I also believe this is an excellent area for dairy farming and, at a time when we import such a huge amount of food, we have an obligation to use this land to make excellent UK food.  We also operate within in a superb ecosystem of cooperating farmers and all the associated trades that support them.  Once we start plucking good land out of the mix this will start to unravel.

We have planted many acres of trees as well as wild birdseed mixes, and we maintain fields as permanent pasture under strict guidelines. All without building a power station on the land.  Indeed the government has a range of incentives for farmers to enhance ecosystems and ecosystem services, to increase biodiversity and carbon sequestration.  The Blackmore Vale is uniquely suited to nature-based solutions to climate change and these solutions have the potential to simultaneously help the UK tackle its multiple crises of climate, biodiversity and mental health.

One of these nature-based solutions is woodland planting which Dorset will have to embrace as part of Carbon Zero by 2050. The ministerial introduction to The England Trees Action Plan 2021-2024 made a number of statements that emphasise nature–based solutions.  He pointed out that “The events of the last year have led people to appreciate the difference nature makes to our lives in a new way. When we destroy nature, we undermine our very foundations.“ I couldn’t have put it better.

Questionable Need

I believe the applicants have dramatically overstated the ‘public benefit’ of the Development.  Solar photo-voltaic (PV) panels produce electricity from sunlight, but are relatively inefficient in producing energy compared to offshore wind power. In the UK, photovoltaics typically only generate 11-12% of their maximum capacity as opposed to sunnier countries. The Applicant’s figures that it will supply 13,000 households broadly back this up.  If the average household uses, as Ovo Energy report, 3,781 kwh (3.781 mwh) per year, that equates to 48,508 mwh output per annum for the whole PV site, approximately the same as the Applicant claims.  To double check this using load factor – multiply the capacity of the proposed development – 50MW x 8,760 hours per year x a load factor of 11.25% and you arrive at 49,275 mwh.  Very similar.

Why is the above important? Many objections have alluded to the government’s ambitions for Offshore Wind. It is worth drilling down in the data to understand this.   Offshore winds are generally stronger than on land, and capacity factors are higher on average – expected to reach 51% by 2022 for new projects. The largest 12mW turbines in the North Sea by this calculation would produce as much as this 190 acre solar park.  The energy produced by the wind turbine would also be a far better match for UK demand which is much greater in winter and will, with a rapidly expanding EV transport  fleet , be much greater at night when the vehicles  recharge. On both these metrics, solar fails.  And it destroys public amenity and the visual openness of the local countryside. An offshore turbine does neither.

Obviously in this case the main issue is whether the benefits of the proposal, including the production of energy from a renewable resource, outweighs any harmful impacts, having particular regard to the effects upon the character and appearance of the area.

Whilst the planning system is required to support the transition to a low carbon future and support renewable and low carbon energy – this needs to be tested against individual applications.

The applicant states (R007 1 1.2)  that the photovoltaic panels “would supply up to 49.99MW of clean renewable electricity to the National Grid, providing the equivalent annual electrical needs of approximately 13,000 family homes. The anticipated CO2 displacement is around 13,000 tonnes per annum.”

That suggests each family produces 1 tonne of CO2 per annum from use of electricity which given they use on average 3,781 kwh per year, means the carbon intensity of the electricity displaced by this new facility is assumed to be 268 grammes per kwh  (1 x tonne = 1,000,000 grams divided by 3,781 kwh = 268 grams per kwh.)  That was roughly correct in 2018 but the earliest this plant will go on stream is 2022. 

The National Grid’s figures as reported in December 2020, indicate the UK is on track for another new low in 2020 after a 15 per cent reduction in carbon intensity compared to 2019.   In 2013, each kilowatt hour of electricity resulted in 529 grams of CO2 compared to just 181 grams so far in 2020. So the 13,000 tonnes claimed Co2 savings per annum  would actually be at most (13,000 x 181/268 = 8,780) 8,780 tonnes in 2022 and in 2030, using government target projections to reach grid carbon intensity of 100g per kWh by 2030 would be  (13,000 x 100/268 = 4,851 ) 4,851 tonnes a year.  So what we see is that the claimed per annum savings would be much lower in the year of first year of export to the grid and shrink dramatically every year thereafter.  That’s because Solar can’t knock coal out of the grid mix anymore because it is already virtually at nil.  It would actually be knocking some gas but mainly other renewables out of the grid.   That would lead to the lunacy of some renewable sources being required to shut down in periods of excess capacity such as a windy sunny summer day.  In other words – a subsidy.

And even those much smaller than advertised carbon savings shrink further when taking into account the carbon embedded in the manufacture of 150,000 solar panels and the carbon cost of building the site.  And then we have to consider the refrigerated food miles for the dairy produce that would no longer be produced on those 190 acres and would have to be imported. Probably just about still a public benefit but far, far smaller than the figures promoted.

Flooding

Others have made excellent points about the potential flooding risk in an already badly affected area. Dorset Council generally take a stringent view of flood risk in developments so I would expect them to do so here.  I would make one further point that I don’t believe has been covered.  Anyone who lives in the valley will regularly see the frost shadow cast by trees and hedges.  Obviously when land is frozen, soil impermeability is absolute.  Solar panels permanently shadow the ground and hence will dramatically extend periods of frost under the panels and hence soil impermeability.

Biodiversity

I believe, as stated above, that many of the mooted biodiversity benefits of fencing off 190 acres of land are illusory and that farmers have access to a wide selection of government mandated greening measures that do the job better. The flora and fauna of the Vale have developed in tandem with its mixture of arable and pasture fields. Indeed six ploughs are mentioned in the Doomsday Book entry for Mappowder implying a nine hundred year history of mixed arable and pastoral farming.  Many species benefit from this diversity of ground. Many insects benefit from the muck from animal husbandry.  A natural recycling has occurred for hundreds of years and that now stands to be brought to a shuddering halt.

Conclusion

In short the site lies within an intimate valley landscape and an attractive rural area. It has high conservation interest, high recreational value, and high cultural and artistic associations. This is part of a landscape that exhibits the demonstrable physical attributes of a ‘valued landscape’.  From the AONB, the rows of solar panels and some of the ancillary buildings would appear as conspicuous and incongruous additions to the valley floor and detract from the appearance of this part of the countryside. It would lend a discordant and industrial aspect to the current visual unity of the valley. It would disrupt the farming ecosystem and tourist economy. And upon closer scrutiny of the figures, the Application doesn’t supply anything like the anticipated CO2 displacement it promises. On all these grounds the Application should be refused.

Regards

Mark Bentley

Mappowder Court Farm

© 2021

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