Objections align with new guidance


Ms Laura Gardener
Case officer NSDC
Proposed solar farm construction off Weston Road, Egmanton
Reference: 13/01422/FULM

Executive summary
The residents of Egmanton reject by an overwhelming majority vote taken at a properly convened series of meetings the proposed solar farm within the parish boundary. We were not properly consulted in advance. We were given no opportunity to suggest alternative sites and we have been unduly time-pressured in our enforced responses. We feel like David against Goliath: unpaid volunteers having to fight paid commercial forces. It is all wrong. No-one in this village is against renewable energy per se. But, of the right sort and in the right place. A number of properties in the village have installed solar panels.

David beat Goliath. This is a battle we must win to preserve our heritage and countryside for succeeding generations.

In our paper dated 20th January 2014 the planning officials, via yourself, were informed of a vote of 34 to 3 against the proposed solar farm within the village of Egmanton. This vote was taken at a formal Parish Meeting held on 16th December 2013. The main reasons for the rejection by residents were shown to be:-

• The scale of the proposed development
• Unacceptable visual impact
• Adverse affect on heritage assets within a conservation village
• Lack of prior consultation
• Delayed and onerous traffic management
• Taking good quality agricultural land out of crop production
• Foreseen perils of water run-off
• Proximity to private property and the A1 trunk road
• Attempts to satisfy short-term financial interests against the feelings of local residents and
• The superior case for macro rather than such micro renewable schemes.

Our second paper dated 11th February responded to the counter-points raised by the consultants Carter Jonas. A further meeting of the Parish held on 6th February 2014 refuted each response by the consultants.

Our third letter dated 19th February gave our considered response to the photomontages submitted at our request by the consultants. The views expressed on the images derived from a further full meeting of the Parish of Egmanton held on17th February 2014 and attended by 40 residents. Villagers considered that the pictures did not give a fair and balanced view of how the proposed solar farm will appear as a permanent landscape. We suggested sites from which images should have been taken. In the third letter, three further points were made:-

• The Trent Valley Internal Drainage Board had commissioned their own consultants to undertake modelling studies to inform the design process for the proposed Egmanton Risk Alleviation Scheme
• Website “Eusoils.jrc.ec.europa.eu” stated that it is impossible to avoid topsoil compaction if sheep are permanently grazed whereas tillage and natural processes re-loosen the topsoil
• Deputy High Court Judge Robin Purchas, sitting in London, upheld a refusal by North Norfolk Council quoting section 66(1) of the Planning (Listed Building and Conservation Areas) Act 1990. The law does not allow developments that “Flies in the face of the will of the local community”.

What are the particular planning considerations that relate to large scale ground-mounted solar photovoltaic Farms?
The purpose of this fourth letter sent on behalf of the residents of Egmanton is to demonstrate to the planning committee how the content and spirit of the above revision to planning guidance, as issued by central government on 6th March 2014, reflects precisely the situation in Egmanton Parish and the feelings of the residents.

As the planning committee will be aware, the first two bullet points of the new guidance say that the particular factors a local planning authority will need to consider include:-
• Encouraging the effective use of land by focussing large scale solar farms on previously developed and non-agricultural land, provided it is not of high environmental value
• Where a proposal involves Greenfield land, whether (1) the proposed use of any agricultural land has been shown to be necessary and poorer quality land has been used in preference to higher quality land; and (2) the proposal allows for continued agricultural use where applicable and/or encourages biodiversity improvements around arrays.

In addition and relevant to Egmanton is bullet point No 7:-
• Great care should be taken to ensure heritage assets are conserved in a manner appropriate to their significance, including the impact of proposals on views important to their setting. As the significance of a heritage asset derives not only from physical presence, but also from its setting, careful consideration should be given to the impact of large scale solar farms on such assets. Depending on their scale, design and prominence, a large scale solar farm within the setting of a heritage asset may cause substantial harm to the significance of the asset.

This additional planning guidance asks the local planning authority to refer specifically to a speech by the Minister of Energy and Climate Change, the Rt Hon Gregory Barker MP, to the solar PV industry on 25th April 2013.

The very first point made by the minister in that speech was:-
“Solar is rightly popular. But if we aren’t careful, or if the sector expands inappropriately, that invaluable popular public support will slip through our fingers. We don’t want solar to become a bone of public contention like onshore wind. And that is my key message today. Solar is a genuinely exciting energy of the future. It is coming of age and we want to see a lot, lot more. But not at any cost….. not in any place…. not if it rides roughshod over the views of local communities. As we take solar to the next level, we must be thoughtful, sensitive to public opinion, and mindful of the wider environment and visual impacts”.

It is pertinent that the minister when quoting successful solar installations refers, inter alia, to a large rooftop array at the Bentley Motors Factory in Crewe, the “solar bridge” at Blackfriars in London, and the Wymeswold Solar Farm in Leicestershire as
built on a disused World War 2 airfield. These sites are notable as not being on greenfield land. The minister went on to say “In other parts of the country, solar has been installed on disused airfields, degraded soil and former industrial sites. This is the model for future solar projects”.

How does the new planning guidance and the content of the minister’s speech square with the objection of Egmanton residents to the proposed solar farm development?
The planning committee will note from the two maps placed with NSDC by the developers ROC Energy that the sixty acre field selected for the proposed solar farm is Grade 3 which is officially classified as “good agricultural land”. Only a small area is Grade 4. Over 90% of the surrounding land in this the Trent Valley falls into this category. This excellent land grows wheat, oats, barley, rye, oil-seed rape, sugar beet and a variety of other root crops as well as variants of willow for fuel in power stations. The land is also suitable for growing soft fruits such as apple, pear and plum and varieties of currants. Thus, the field in question falls into the category of that which should not be considered for a solar farm. Conversely, there are sites in the immediate vicinity which align closely with those quoted by the minister such as:-

• The disused Bevercotes Colliery site
• The Boughton old army camp
• High Marnham old power plant
• The disused airfield at Ossington
• Roof tops at Tuxford & Newark industrial estates.

It is not NIMBY ism to suggest the developer and their appointed consultants direct their attention to these locations in conformity to the new planning guidelines, the minister’s speech and, indeed, their own trade association www.solar-trade.org.uk four of whose ten “Commitments” are:-

• We will focus on non-agricultural land or land which is of lower agricultural quality
• We will be sensitive to nationally and locally protected landscapes and nature conservation areas, and we welcome opportunities to enhance the ecological value of the land
• We will engage with the community in advance of submitting a planning application (the italics are ours)
• We will seek the support of the local community and listen to their views and suggestions.

ROC Energy is not a member of this trade association (source – telephone call 1st April 2014).

In relation to the preservation of heritage assets, the planning committee may care to refer to Appendix 1. This paper refers specifically to the heritage assets in and around Egmanton.
In further support of the value of heritage assets, the committee is further asked to review the comments made by English Heritage on both this solar proposal (paper dated 13th December 2013) and the turbine proposal (paper dated 24th March 2014). Residents of Egmanton contend that all the comments and views expressed in the observation paper relating to the proposed wind turbine apply equally to the solar farm installation blot on the landscape.

We respectfully refer the planning committee once again to our paper No 1 under the heading “Foreseen peril of water run-off” and under the same heading in our paper No 2. This point is made specifically due to a map placed on the NSDC planning website by ROC Energy. This image is presumably placed in an effort to placate anxiety of further flooding. This map image is misleading and possibly mischievous. The planning committee is directed to the Environment Agency Flood Map using the post code NG22 0HF. This is the relevant document. It shows that the proposed solar field is located precisely in the triangle bounded by the A1 to the East, Goosemoor Dyke to the North and the un-named Beck that flows through Egmanton Village to the South. This area is coloured deep blue indicating flood zone 3; a high risk area. Our contention is that this solar farm will, due to additional water run-off, exacerbate the flood risk to the village.

Letter dated 25th March 2014 to Miss Gardener from Carter Jonas
The letter quoted above and posted on the planning website refers to a meeting between a Kevin Ayrton – Senior Planner – Carter Jonas and Matt Lamb

In our opinion, two statements in the letter from Carter Jonas and therefore in the public domain express hubris in the extreme. “The new Guidance that has been introduced is just that, guidance”. The inference, one assumes, is that it can therefore be placed to one side? If so, what is the purpose of a planning process? Why do we need Ministers of State to give guidance? Best left to developers and their advisers to decide what is best for us? The speech by the minister included “brownfield land should always be preferred”. The consultants say “Critically, however, this is only a preference”. A preference is a preference. Egmanton is surrounded by suitable brownfield sites as has been demonstrated in this response. Carter Jonas conclude by telling us that they are involved with an appeal for a solar farm elsewhere. This means that the original application was refused as this one should be to preserve our beautiful village and surrounding countryside.

Appendix 1.
Heritage assets in and around Egmanton.
Egmanton, Laxton, Wellow and Bothamsall all have motte and bailey sites and these are thought by the Land Trust to have been in a line on the edge of Sherwood Forest, not only for defence but also to control the forest and the deer etc. This would seem to be supported by the fact that the first patron of Egmanton Church in 1244 was Robert D’Ayville, Lord of the Manor of Egmanton and Keeper of the Forests to the North of Egmanton (i.e. Sherwood Forest). Some features of the church are even earlier and there is a good example of a Norman tub font.

The church is Grade 1 listed and contains the restored Shrine to Our Lady, rood screen and decoration round the south door with organ doors above, the work having been commissioned by the Duke of Newcastle and undertook by (Sir) Ninian Comper in the late 1890s. We therefore have connections with the Duke’s Mausoleum at Milton, the other side of Tuxford and Clumber Chapel in Clumber Park, the site of his previous seat. The shrine and the rood screen have been restored during the past few years, and we are delighted that the Nottinghamshire Historic Churches Trust has earmarked us this year for their special award so that we can complete the third phase of this restoration with work projected to be completed between May and July 2014.

Since the 1930s there has been a Society of Our Lady of Egmanton and they hold 4-5 main Pilgrimages each year and in the summer process through the village. They also visit Lady Wood between Egmanton and Moorhouse where Our Lady was said to have appeared to a village girl probably in medieval times. Membership is nationwide and our individual visitors also include those from abroad. We also receive group visits from major cities including London as well as those with local interests.

The church may also be appropriate for educational purposes, not only from an art appreciation point of view, but also because of the wide range of history it represents with stories reflecting the lives and times of the people who are represented here. Through the ages, it represents the medieval, the first Elizabethan era when Nicholas Powtrell was sergeant at law and justice of the assizes. He was a Member of Parliament, built an Elizabethan house near the village, emparked it and the earthworks of the fishponds still remain as well as his alabaster tomb in the church.

Then the final glory of the Comper work reflecting the achievements of the Victorians.

J G Smith FCCA – EPM honorary treasurer.