How is it possible for an experienced developer to choose an area of farmland that is so unsuitable for an industrial solar plant? Well, it seems their own site selection process and expert advisors may be partly to blame.
An economically attractive view!
The ‘Head of Energy’ for ‘British Solar Renewables’ explained the reasons for developing an industrial solar power station at North Dairy Farm in the heart of the Blackmore Vale (Hardy’s Vale) when he spoke at a disorganised, and sparsely attended, online community consultation event in October 20201., He said: “the grid connection is the key reason for picking the farm site” as it already has 132 000 Kva power lines running above the fields.
1. View the BSR Zoom consultation
Forget the spin “we are doing this for Dorset Council” – the Rate of Return of 10 to 20% is the real reason for wanting to develop the 190 acres of productive farmland – remember the Spetisbury energy output that bypassed the local community and went straight to ‘the City’!
A few million!
Maybe it was the lure of ‘relatively’ low grid connection costs (in the low millions!) that blinded BSR to the many other serious problems that developing the site would pose. But, as well as attractive connection costs, the two-hour presentation in 2020 contained other very strong hints that might explain how BSR were drawn into making such a bad choice of site. It seems their landscape and flood experts led them to believe, and their ‘Head of Energy’ to actually say:
“On this particular site we are not impacting on any protected landscape, heritage or ecological designations” and are “not too impacted by flooding or visual impact.”
This mistaken belief may explain why the developer failed, during the pre-application stage, to seek the recommended expert planning guidance and advice from the Area of Outstanding Natural Beauty Management Planning Team. This omission may also have been partly to blame for what subsequently happened!
Even before the Application was submitted,
The Council Planning Officers made it clear in writing to the developer, that the proposed site is in a ‘highly valued landscape’, in the setting of the AONB (the highest level of legal protection in England), 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. They also highlighted that the Site impacts the settings of two protected Conservation Areas, many listed buildings and heritage assets. It is also in an area that the Council had identified as very highly sensitive to large scale development, and which is being considered as a National Park.
Much has changed
After claiming: “On this particular site we are not impacting on any protected landscape, heritage or ecological designations” and “not too impacted by flooding or visual impact.” late last year, after a very detailed examination of the Applicant’s proposals by Council’s specialist Planning Officers, qualified and independent Landscape and Visual Impact, Heritage and Hydrology experts, it became very clear that the NDF Site did indeed have flood and serious drainage issues, and was in an area and landscape specifically identified by the Council as unsuitable for Major Development.
What a Surprise!
So, the Applicant engaged a new landscape expert to assess the issues and areas the Planning Officers identified had been missed by the Applicant’s first consultant. A second consultant was asked to re-assess the impacts the generating plant would have on the countryside around it, in particular the highly protected areas within the Dorset AONB that had not been fully considered in the first assessment. Sure enough (surprise, surprise!) the second expert found that all the impacts examined caused effects that are “adverse “.
The SHV expert Landscape Assessment
The SHV independent Landscape Assessment had also identified that: “The Applicant’s (first) Environmental Statement generally underestimated the Site’s visibility in the wider landscape, and failed to record a fair and representative assessment of views in accordance with the professional Guidelines for Landscape and Visual Impact Assessment (GLVIA), including important views to and from the Dorset AONB.” BSR made it clear, during their 2020 ‘virtual’ local consultation, that the site would be very visible from important public footpaths and viewpoints on the high ground around Hazelbury Bryan – and from the well-used public footpaths that surround and transverse the site.
Advice from Flood Experts retained by BSR
If the unsuitability of the landscape for solar was underestimated, then it was the advice from Flood Experts retained by BSR that almost certainly contributed to the other seriously mistaken “belief”, that the proposed site was: “not too impacted by flooding”. BSR’s initial Flood Risk Assessment also proved to be inadequate, and it is now established that the local area, and parts of the Site, are significantly affected by very high rainfall and unpredictable flash floods which, in places, pose a threat to life.
The’ lake’, shown in the image above, is the site selected by the developer to be their ‘Temporary Maintenance Compound’ during the months of construction. Unpredictable flash flooding is already identified as a “threat to life”
“Not too impacted by flooding,” said the Applicant!
By the end of last year, it became clear that the Applicant’s original Flood Risk Assessment overlooked some very serious matters. So, the SHV Group commissioned a qualified hydrologist to review the Food Risk Assessment. That report established that the 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. 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.”
Drainage that cannot drain!
The ‘misunderstandings’ about the nature and extent of flooding may also have led the developer to wrongly suggest that sustainable drainage for the site would not be needed to prevent surface runoff causing additional downstream flooding. But, by September 2021 that position became completely untenable, and the developer belatedly proposed an infiltration-based drainage system, including grassed swales. However, BSR appears to have again overlooked the serious, and explicit warning, contained in their own Flood Risk Assessment (FRA) that: “The reported hydrological characteristics of the Site suggest that infiltration may not be feasible”. The expected low infiltration rate indicated that the proposed swale drainage would not work, and therefore, surface runoff and downstream flooding could increase.
A third attempt!
The Applicant’s soil survey had established that ground on the site is saturated for over 199 days a year, something that would significantly increase the speed of the surface rain runoff. So, we now wait again! Having gone from “no drainage needed” to infiltration-based swales that won’t work. We wait! This time for new drainage proposals, possibly involving a storage and controlled surface water discharge system, in a ‘last-ditch’ attempt to reduce the risk of increased peak surface runoff and downstream flooding.
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.
The ‘coverup’
In the light of the long list of harms the second expert identified, a host of additional “mitigation” planting proposals have been put forward in an attempt to cover up, or hide, 190 acres of incongruous industrial power plant; something even the Applicants acknowledge will be impossible – as large sections of the industrial site can be ‘looked into’ from the high ground that surrounds it to the south-east, south and south-west, which include public viewpoints within the highly protected AONB and the Hazelbury Bryan Conservation Areas. The Applicant concludes in the latest Environmental Assessment (revised Chapter 6.) that, as the planting matures (15 years onwards) there: “would not be any significant adverse or visual effects in the longer term” caused by the proposed development.
Unjustified conclusions
It is our considered opinion, informed by the expert assessments presented in the revised Applicants EA/LIVA, the SHV Landscape Statement, and the Wyvern Heritage and Landscape Submission, that we have to echo the words of the AONB Landscape specialist in regard to the original incomplete assessment:
“The (Applicants) conclusions are not based on evidence sufficient to clearly justify these conclusions.” and are therefore unjustified.”
“Frustrated of Dorset”
Way back in 2020 the ‘Head of Energy’ also let the attendees at the online consultation event know that the founding director of BSR had set up the company because he was: “frustrated by the planning process”. What has happened since 2020 with this proposed development must have only added to the director’s frustration. The developer seems to have been drawn into attempting to develop a Site because it offered a ‘relatively’ easy connection to the existing grid. But their Landscape and Flood Risk desktop assessments have let them down, by failing to point out the serious faults in the proposal. Now, after a second Landscape and Visual Impact Assessment – and with possibly a second Flood Risk Assessment on the way, the ‘planning system’ may be getting just as ‘frustrated’ as the ‘founding director!’
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.
We believe it is unreasonable to suggest that the “energy infrastructure” shown in Viewpoint 1, (Image above) from Footpath N49/11 (below) contributes to a significant utilitarian element in the wider landscape. However, and ironically, the development application proposes all of these features in vastly increased quantities over 77 Ha of the receiving landscape.
The last (ironic) words from the BSR 2020 online community presentation go to the leader of the BSR support team, who said about the Site selection and planning law: “Policy is supportive in principle – but requires that it is equally clear that such sites need to be located in areas that are suitable – and fits well in the local community and environment.”
The ‘expert’ view
The expert view is that the North Dairy Farm Site is unsuitable for a major 190-acre infrastructure development, and it certainly does not “fit well in the local community”, which the Applicant knows is overwhelmingly (97%) opposed to industrial development, and which, Dorset Council considers, is an area highly sensitive to a major solar plant, and where frequent flash flooding is already a “risk to life”- and increased downstream flooding is a realistic probability.
The revised and augmented report has now been submitted to the Council, and is available to download from the SHV Webpage, or from the Council Planning Portal, Remember to click the small ‘Accept’ conditions button at the bottom of the Council’s page, and then select ‘Documents’.
Uniquely Rapid discharge and unpredictable flash flooding
Environment Agency Upper Lydden River catchment area (a sub area of the Stour Catchment) and the Wonston Brook Catchment Area is approximately 40 km2. All the exceptionally high annual rainfall runoff ‘meets’ around the proposed solar site.
Both catchment areas focus their flows around the site
The heavy blue dashed line to the south represents the high rainfall areas of the Downs and High Escarpments (1000 – 1400 mm a year – with 50% runoff) The light dashed arrows indicate that both the Upper Lydden (yellow) and the Wonston Brook (to the right) focus their catchment flows, and runoff, around the proposed North Dairy Farm site.
All the Save Hardy’s Vale letters to Dorset Council are available here.
Save Hardy's Vale 