Applications for solar farms have recently become more frequent, as a response to the climate crisis and the need for energy security.  Should that mean that sizeable swathes of the countryside should be industrialised, though?

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Solar power already contributes significantly to the national power requirement during the day, but it doesn't work at night, or very well on cloudy days.  You can see the breakdown of contributions to national generation by gas, renewables etc on the National Grid Live Status website. It's worth scrolling down to see the lower charts; for example, these clearly reveal the drop in general electricity demand at night, and at the weekend. A further website that it refers to is Sheffield Solar, which gives specific data for solar.  Set the display to "Last 7 days" to see the huge daily fluctuations in production.

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There is also useful information on the Solar Campaign Alliance website.  Their letter of 18 October 2022 to the Prime Minister is worth reading.

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The first two of a batch of applications near Ludlow came before the Southern Planning Committee on 27 September 2022.  The Committee made it clear that solar farms would not be permitted on good quality agricultural land; one application (at Ledwyche) was rejected outright on those grounds and the other (at Greete) was sent away for a rethink.  The recording of the meeting is available here.  They relied partly on para 174b of NPPF which states that “planning policies and decisions should contribute to and enhance the natural and local environment by .  .  . recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland”.:  The Greete applicant then took out some of the BMV land and the application was passed on 18 October (recording here) despite protests that most of the land is highly productive, and doubts about the figurework. Our submissions are in the documents for 22/02565/FUL (search for CPRE).

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In the Telford & Wrekin Council area there has been strong opposition to two large solar farm proposals at New Works and at Steeraway, which are next to each other and together would form 145 acres of solar panels just south of junction 6 of the M54.  Both were refused by T&WC and both went to appeal.  The New Works application was subsequently approved by the Secretary of State (against the decision of the appeal Inspector) on 27 March 2023.  The Steeraway appeal was heard the week before and its result is still awaited.

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Our reservations about particular applications are essentially three-fold:

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1. Solar panels should be put on roofs in preference to being put onto prime agricultural land. 

2. Claims of carbon savings and electricity generation are frequently misleadingly presented, with a tendency to be uncritically accepted and conflictingly presented by officers. Since the whole rationale of the applications is to save carbon emissions it behoves officers to take great care with the relevant figures.

3. There is no national land-use policy to establish a hierarchy between food production, energy production or landscape value. .

 

The headline output of a solar farm is its maximum possible electricity production.  However, solar farms in 2021 were only at this peak production an average of 10.0% of the time [1].  A solar farm rated at 50Megawatts peak (50MWp) will therefore produce on average during the year 50MW x 8,760 hours in a year = 438,000 Megawatt hours (MWh) x load factor for 2021 of only 10.0% = 43,800MWh.

 

You will sometimes see this expressed in terms of the number of homes that could be supplied. Often this is misleading because it gives the impression that this number of homes could be made independent of the UK network, which of course is not the case.  In practice the electricity produced by a solar farm will go via its substation into the general grid, and households will take their electricity from that general grid, not directly from the solar farm

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Average domestic electricity consumption for 2021 was about 3,866KWh a year and domestic electricity consumption for 2021 was around 35.7% of total electricity consumption[2].

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Taking all that together, a 50MW solar farm might actually be able to supply the needs of 43,800 divided by 3,866 x 1,000 x 35.7% = some 4,045 homes.

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Calculations of carbon savings once a solar farm is up and running are often based on the calculation, within government tables, that each Kwh of current electricity production produces 0.19338 kg of CO2e.  In practice, though, solar farms do not completely replace all carbon-emitting generators.  Nor would this calculation take into account the carbon emissions of on-site construction or off-site manufacture of the solar panels or other equipment.  The same applies to calculations of net biodiversity gain. One developer recently revealed that, although solar farms are a comparatively cheap way of gaining rapid renewable electricity, even they are a net contributor to carbon emissions, to the extent of 6kg/MWh over their lifetime.

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The following text is derived from representations made in September 2022 for the above two applications for solar farms near Ludlow, namely 22/02151/FUL (Ledwyche) and 22/02565/FUL (Greete).  The documents tabs for both include our original letters, the applicants' responses, and our further response to those.

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CPRE, the countryside charity is committed to supporting solar energy but will always oppose harmful developments.  Solar photovoltaics are an important part of our energy supply in the climate emergency, but the government has given the solar industry carte blanche to develop huge greenfield sites which damage our countryside and ignore the huge potential of roof-mounted solar.  It is hugely disappointing that the transition to net zero carbon for the energy sector is being handled so poorly, and this should not continue.

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The climate and nature emergencies pose an existential threat to the countryside in terms of landscapes, livelihoods and the natural systems which support us all.  CPRE advocates for climate action, and we support renewable energy.  If we are to eliminate our reliance on fossil fuels then no form of zero carbon energy can be off the table.  The Government’s Energy White Paper (2020) committed the UK to generating 40 gigawatts (GW) of offshore wind capacity by 2030; and the Climate Change Committee (2019) recommended that 54GW of solar capacity is needed by 2035.

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The government figures do not indicate how much of the total solar capacity could come from roof-mounted panels. There are around 250,000 hectares of commercial, south-facing roof space in the UK.  This could realistically generate an annual output of 119.05 Terawatt hours.  In 2021 domestic electricity consumption was 109.5 Terawatt hours and total electricity demand was 334.2 Terawatt hours[3].  Therefore, fully utilising the available south facing industrial roof space for solar panels could generate enough electricity to power every home in the UK and then some, or put another way, 36% of the total electricity demand for all of the UK’s needs.  This is why it makes sense to prioritise roof-mounted solar (as well as on brownfield sites, for example by installing above surface car parks) to reduce the need to occupy greenfield sites and agricultural land with solar farms.

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[Developers point out that it would be impossible to install solar on all available roof spaces because many roofs have insufficient strength to take solar panels and also because the complex nature of landlord/tenant relationships tends to militate against solar installations on many buildings. Most brownfield land has hope value for housing or commercial development which prices solar developments out. Owners of car parks do not usually want to lose valuable car parking space to the frames and support structures required for the installation of solar carports. The additional costs of mounting solar on concrete rather than greenfield sites also makes it unviable.].

 

This need for renewable energy, and particularly solar energy, does not justify permission being granted for damaging developments, and strong, effective planning policies are needed which enable schemes that minimise landscape impacts, secure real nature recovery opportunities and enjoy the support of local communities. Schemes that fail to meet these expectations should be refused.

 

Planning policy

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The problem that local people in particular find themselves in is that there are currently no strong, effective planning policies in place to prevent the approval of damaging renewable developments.  National policies, and even more so local policies, are well behind the curve when it comes to providing anything approaching effective land use policies for deciding a hierarchy between food production, energy production or landscape value.  In the meantime, the rush for profits from solar farms is filling this planning vacuum.

 

National policy

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Paragraph 152 of the National Planning Policy Framework (NPPF) states:

The planning system should support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure.

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It is debatable whether solar power contributes adequately towards “minimising vulnerability and improving resilience” because of its inefficient nature.  No sensible energy policy should rely on a source that is ineffective for over half the year on average (i.e. during the hours of night), nor on one whose load efficiency factor is only around 10%.

 

This is starkly evidenced in practice by such developments as that currently being built near the Oswestry sub-station (planning reference 18/04510/FUL).  This is for a 30MW “mini” gas powered standby power station.  Such developments are being built around the country to provide resilience for when peak demand exceeds the ability of the network to supply that demand from intermittent renewable sources.  In other words, they are being built for when intermittent and unpredictable renewable energy sources fail to keep the lights on.

 

Paragraph 154 of NPPF states:
 

To help increase the use and supply of renewable and low carbon energy and heat, plans should:
 

a) provide a positive strategy for energy from these sources, that maximises the potential for suitable development, while ensuring that adverse impacts are addressed satisfactorily (including cumulative landscape and visual impacts);

b) consider identifying suitable areas for renewable and low carbon energy sources, and supporting infrastructure, where this would help secure their development; and

c) identify opportunities for development to draw its energy supply from decentralised, renewable or low carbon energy supply systems and for co-locating potential heat customers and suppliers.

 

Shropshire Council policy
 

There are no specific policies for solar farms within Shropshire Council’s existing Local Plan, which is made up of Core Strategy (adopted February 2011) and SAMDev (adopted December 2015).  The only relevant policies are relatively vague ones for renewable energy generally.  It was not, after all, until May 2019 that the Council declared a Climate Emergency.

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Policy CS6 of Core Strategy of February 2011, paragraph 4.78, states that:

To mitigate climate change through sustainable construction, all proposals, including changes to the existing building stock, will be required to complete a sustainability checklist to accompany planning applications.

 

As long ago as July 2011, Shropshire Council adopted a Sustainable Design Supplementary Planning Document (Part 1), which included the Sustainability Checklist referred to, as above, in Core Strategy.  It seems that, despite subsequently espousing climate action, Shropshire Council has been lax in pursuing this sustainability agenda, which has been on its “statute book” for over a decade.

 

It is therefore the case that no such sustainability checklist has been submitted with this current application, despite Core Strategy seeming to require it.

 

There will be a more specific policy once the emerging Draft Local Plan is adopted.  At the moment (late September 2022) the Examination in Public Stage 1 hearing sessions have been completed but this did not include any examination of the relevant policy DP26, Strategic, Renewable and Low Carbon Infrastructure (which will happen at the Stage 2 hearings, later this year or early next year).  Nor have the Inspectors yet revealed whether they consider the Draft Plan to be sound as to its approach to climate change issues. The Council has first to satisfy the Inspectors about its approach to the Duty to Cooperate and to minerals policy before the Inspectors release their initial findings.

 

Draft Policy DP26, once adopted, would support solar farms (and other non-wind renewable development) where their impact is, or can be made, acceptable.  For determining that, assessments of the proposal’s effect should cover Visual amenity, Landscape character, Natural assets, Historic assets, Air quality, noise and public amenity, Water quality and water resources, Traffic generation and the nature of vehicle movements, and the Shropshire Hills AONB.  Large scale ground mounted solar photovoltaic solar farm proposals should show how they have made effective use of previously developed and non-agricultural land.  Where a proposal requires the use of agricultural land, poorer quality land should be used in preference to land of a higher quality.  Proposals should allow for continued agricultural use wherever possible and/or encourage biodiversity improvements around arrays.  The assessment should pay particular attention to the impact of glint and glare on neighbouring land uses and residential amenity as well as aircraft safety, (including defence operations).

 

Planning Practice Guidance states that “the NPPF explains that all communities have a responsibility to help increase the use and supply of green energy, but this does not mean that the need for renewable energy automatically overrides environmental protections and the planning concerns of local communities”[4].  Shropshire Council will need to take this guidance into account in the face of the considerable number of public objections to the current proposals, most of them grounded in concerns for the environment.

 

Shropshire Council has also not acted on NPPF paragraph 154b in that it has NOT “considered identifying suitable areas for renewable and low carbon energy sources, and supporting infrastructure, where this would help secure their development”.  Many Local Authorities, including the smaller and neighbouring Powys County Council, have undertaken such an exercise.

 

Planning Practice Guidance does state that “identifying areas suitable for renewable energy in plans gives greater certainty as to where such development will be permitted.  For example, where councils have identified suitable areas for large scale solar farms, they should not have to give permission outside those areas for speculative applications involving the same type of development when they judge the impact to be unacceptable”[4].

 

The only comparable exercise we are aware of that has been undertaken is the LUC “Shropshire Renewable Energy Opportunity Map Method Report” of October 2011, commissioned by Shropshire Climate Action Partnership, and generously funded by Shropshire Council itself[5].  The “Energy opportunities and constraints mapping” results of this report are hosted by Shropshire Council on its maps website .  This showed that both the proposed sites near Ludlow were "constrained" and therefore not thought suitable for a solar farm site.

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[1] Digest of UK Energy Statistics 2022 (DUKES 2022) Table 6.3 (percentage of how much was generated compared to maximum possible generation - based on the average of capacity at the start of the year and capacity at the end of the year)[1]

[2] From DUKES 2022 Table 5.1

[3] DUKES 2022

[4] https://www.gov.uk/guidance/renewable-and-low-carbon-energy

[5] https://zerocarbonshropshire.org/renewable_energy_mapping_project/