PLANNING APPLICATION AVA/2020/1224 ALFRETON SOLAR FARM (AVBC)
PLANNING APPLICATION Ref. No: 20/01282/FL Proposed photovoltaic solar park and associated infrastructure (NEDDC)
Alfreton Town Council (ATC) wish to make the following observations and comments to this application, whilst it recognises the importance and requirement for sustainable renewable energy it feels the location of this application is not appropriate within an urban / semi-rural north facing setting.
Economic, environmental and social impacts from such a development are interdependent on each other and this application does not provide adequate mitigations or benefits for each factor.
There is a concern that the applicant has not consulted meaningfully with the local community. In the literature available from the AVBC website, Kronos acknowledge that ‘Early engagement has significant potential to improve the efficiency and effectiveness of the planning application system for all parties. Good quality pre-application discussion enables better coordination between public and private resources and improved outcomes for the community’
The Town Council recognises the constraints of the Covid-19 pandemic. Kronos acknowledge that the leaflet distribution to 1000 properties was not delivered. For a project of this scale and impacting on a neighbouring Town, the selected ‘Zones of Theoretical Visibility’ is not adequate and whilst mitigations have been put in place to offer a second consultation, the scale of the leaflet distribution is inadequate and the wider local community should be included.
It was concerning to hear that the second consultation was not conducted effectively and was indeed branded by Kronos staff as an ‘event’ and not a consultation. There was no opportunity for the public to ask questions openly. Questions were fielded by staff and selected from the chat functionality.
The same community engagement statement has been submitted for 2 separate applications for solar farms adjacent to each other, which are in different Councils. This is misleading, at best, whilst Kronos explain that in effect this is one development, 2 separate applications have been made and the consultation of those have been subsumed into one response. There is an assumption that the responses refer to both applications.
With reference to Kronos’ explanation that this is effectively one application, this raises a concern regarding the limitations of which a Local Planning Authority can approve a solar farm, which is currently up to 50mw of energy. AVBC application is for a farm generating, ‘just less’ than 50mw. North East Derbyshire District Councils (NEDCC) application is for a farm generating ‘just below’ 25mw of energy. Therefore, a total of near 75mw of energy which would require an application of such to be classified as a Nationally Significant Infrastructure Project (NSIP), requiring the planning inspectorate approval.
The Town Council requires that Amber Valley Borough Council (AVBC) and North East Derbyshire District Council (NEDDC) delay any decisions on this application until after the pandemic so that suitable consultation can take place and proper engagement can be undertaken with the affected communities.
The access and egress to the solar farm via Church Street raises several issues relating to highway and pedestrian safety, ease of access and disruption from increased traffic. This is a complicated and busy junction serving as existing access to a Leisure Centre, Adult Education Centre, College, Hall and Conference, Doctors Surgery and Pharmacy, Church, Farm, local businesses and residents. The addition of works vehicles increases the burden on this area of the town. Kronos have mitigated this with an access off the B6013, for both AVBC and NEDDC applications raising the question again if this should be one application. We understand that residents of Ufton Fields Barns may consider legal action to protect their right of access in relation to this application. Whilst that is a matter for them, the Town Council can understand their concern but should the B6013 access be deemed unsuitable for long/heavy goods vehicles then Church Street would appear to be the only other access point for the two application sites. The Town Council insists that AVBC prohibit the use of Church Street for long/heavy goods vehicles especially due to the positioning of the Grade II listed War Memorial on that junction.
There have been significant applications in Alfreton, in the past, where the transport issues were accepted at Planning level, as being of little or no consequence; for example, Outseats Farm. You will recall that that proved to be anything but the case.
Alfreton Hall is a Grade II listed building on the edge of Alfreton Park which should be preserved and protected for future generations along with the historic park and grounds, dating back to 1700’s. St Martins Church is a Grade II* building and the War Memorial is Grade II listed. This area, adjoining the development provides habitat for many species. The woodland groups are an important part of the landscape. (Local Plan Policy LS3& EN14). A conservation area, Ponds Wood, is also located within the development area. The Town Council requires AVBC & NEDDC to recognise the area for its heritage, beauty and links to DH Lawrence providing protection for the open green space.
The site comprises of ‘a mix of predominately native species with a scattering of exotic trees throughout. Several of the trees have been identified as having features associated with veteran trees. These are subject to greater protections following the publication of the National Planning Policy Framework (NPPF).’ (Tree constraints report, evolve. 2020). As none of the trees have been identified as unretainable and all have an expectancy beyond 10 years, has consideration been given to retaining where possible, relocating those that cannot realistically be retained or replanting the equivalent of those lost, elsewhere. AVBC & NEDDC should recognise the loss of the ecology in the area and the importance of the flora, fauna and wildlife.
There is an opinion that the deer fencing would devalue the area of open farmland and public right of way.
National Planning Policy Framework: Open space and recreation states:
- Access to a network of high-quality open spaces and opportunities for sport and physical activity is important for the health and well-being of communities.
- Planning policies and decisions should protect and enhance public rights of way and access, including taking opportunities to provide better facilities for users, for example by adding links to existing rights of way networks including National Trails.
There is a concept that solar farms generate additional noise in the local vicinity, not just during construction but daily generating of power. Whilst the application states this will not be a concern, we seek reassurance that a Noise and Vibration consultation has been undertaken on this plan to consider impacts during construction on nearby noise sensitive properties and ongoing management of a solar farm and the impact of noise and disturbance. This could affect the prospect of businesses locating to Alfreton and house purchases in the Town and local area.
The Glint and Glare Study ‘predicts’ a low impact to traffic on the B6013 and A615 and mitigations to lessen the impact on several properties. Can assurances be given that those mitigations will be put into place and maintained for life of the solar farm. It is noted that ‘Zones of Theoretical Visibility’ spans far beyond 5km, yet somewhat surprisingly only 3 properties identified as affected.
Concerns have been raised regarding fire risk, the Building Research Establishment Ltd states ‘All electrical installations, by their nature, will carry some degree of fire risk. Although fires caused by PV panels are rare, any fire involving a building with a PV array can present an increased risk to occupants and fire-fighters’. The Town Council seeks assurances that a risk assessment is completed by Kronos and adequate safety measures are in place to lessen or remove those risks.
There are no meaningful proposals to mitigate the effects a development of this type would have on the community and local landscape, with Kronos defending the use of the land and devaluing its importance rather than putting in place alternative or additional benefits for the best use of the land underneath the panels and no economic benefits to the community through job creation or investment. Kronos’ response is to denigrate the area and disregard the value of the important scenic view over the Amber Valley, to Crich, on the edge of the Peak District; more importantly the last open space in the Town of Alfreton.
A company presenting the values of sustainable green energy and environment, wishing to introduce a solar farm in a community should establish those values to support local initiatives and provide improvements to have a positive impact on the area. There are concerns that provisions are not being provided to lessen the effects of such a development, no additional open space opportunities, protection of the public right of way or indeed to better facilities. If S106 funding is available for an application of this type this must be considered.
Alfreton and surrounding parishes would and could benefit from development that improves the facilities on offer to its residents. This application offers no compensation for any detriment to the area. The Town Council have projects planned for improving facilities within the Town and Kronos could support those plans by way of compensating for the loss of amenities through, for example, sponsorship of an amphitheatre on Alfreton Park, of community hub within the town, regeneration of the Town Centre, compensatory dedicated open space within the area of the development.
A less intrusive, alternative solution would be to utilise the roof space or footprint of existing industrial buildings and estates, brown field and open spaces on wasteland and industrial estates (Local Plan, point 1.11), have these options been explored? The Town Council requires AVBC & NEDDC to support them in their aim to protect this area.
The Town Council would like to see the public rights of way, open spaces, farmland and green belts surrounding Alfreton protected from development. This area is the only countryside available to the town of Alfreton and it would be a great loss to the residents if the area was used for such a development. The recent pandemic has highlighted the valuable and regular use of these footpaths, promoting and fostering good mental health.
Whilst the Town Council support AVBC in their aim to become carbon neutral we would like to work together to review alternative measures which could be utilised in the area to strike a balance. Alfreton has seen many developments in the vicinity in the recent past removing much of the green spaces which surround it: Outseats Farm, Damstead Park, Lily Street Farm and now the application for Kronos Solar Farm and the anticipated Solar Farm on the opposing side of the A615.
Before the approval in 2020 of the Clevehill Solar Farm in Kent, Shotwick Solar Farm in Flintshire was the largest with a capacity of 72MW. The approval of the two applications would see Alfreton Solar Farm as the second largest solar farm in the UK, pending approval of two further applications through NSIP.
In conclusion we would draw the attention of the planning authority to the fact that this would be the second largest in the country, due to that impact, the planning authority should be particularly diligent and vigilant in requiring mitigation in the loss of community with no apparent benefits.
The Town Council would like AVBC & NEDDC to carefully consider the contents of this letter and the impact that such an application would have on the area.
The Town Council wants to reserve its right to attend and speak at both Council Planning Boards when this application is considered.
Best Wishes
Joint Town Clerk, Alfreton Town Council
Cc:
Amber Valley MP Nigel Mills
Leader of the Council AVBC Councillor Chris Emmas-Williams
Deputy Leader AVBC Councillor Ben Bellamy
Chesterfield MP Toby Perkins
Chair of Planning Board AVBC Councillor Mick Wilson
Leader of the Council NEDDC Councillor Alex Dale
Deputy Leader of the Council NEDDC Councillor Charlotte Cupit
NEDDC MP Lee Rowley
