On the 14th December 2018 the Planning Inspectorate accepted the application for Cleve Hill Solar Park. Kent Wildlife Trust registered as an Interested Party and is taking part in the examination. We attended the Preliminary Hearing in Faversham on the 30th May 2019, and have submitted a Written Representation, which can be downloaded below. This sets out our technical response to the proposals submitted. A less technical summary of our position is set out on this webpage.
The Planning Inspectorate's page for the project can be viewed HERE.
Kent Wildlife Trust still has concerns regarding the adequacy of the area of mitigation for Brent geese, and believe less of the area will be functional than is being argued. There also remain significant uncertainties regarding mitigation for lapwing, golden plover and marsh harrier. The area also has immense potential for habitat creation to restore lost habitats of the Swale, and we believe the proposals for Managed Realignment here should be taken forward sooner rather than later. We therefore remain opposed to this development.
What is it?
Cleve Hill Solar Park is a proposed development of solar photovoltaic (solar panels) covering an area of approximately 360 hectares (890 acres).
Where is it?
The proposed site is located on the north Kent coast, roughly 1 mile northeast of Faversham, 3 miles west of Whitstable and situated closest to the village of Graveney.
It is surrounded by habitats designated for their wildlife value at a National and International level (shown in green on the map below). ‘The Swale’ has three levels of designation: Site of Special Scientific Interest, a national designation; Special Protection Area, a European designation; and Ramsar (a wetland of international importance designated under the Ramsar Convention). The Swale Estuary is also a Marine Conservation Zone (a national designation), though at present it seems unlikely the solar farm will impact on this.
How is it different from other solar parks?
Cleve Hill Solar Park is huge. It is about five times bigger than anything else currently built or planned in the UK. Most notably it is also of a very different design to other solar developments – rather than south-facing panels, they will face east and west, meaning they can be installed much closer together. This new design is likely to increase the impacts and significantly reduce the opportunities for wildlife compared to ‘traditional’ designs.
What are Kent Wildlife Trust’s concerns?
With the information we have at present, our concerns fall into three main categories: loss of ‘functionally linked’ habitat, direct impacts on the habitats within the development site, and the loss of opportunity that this area provides to the environment.
Loss of ‘functionally linked’ habitat
While the development site itself has no wildlife designations, at certain times it does support species that the surrounding habitats are designated as important for. As such, it is ‘functionally linked’ to these designated areas, and its loss may have an impact on the species in question. The developers will have to undertake a ‘Habitats Regulations Assessment’ to determine the impacts on these species, what mitigation may be necessary, and ultimately demonstrate that any impacts will not be significant. An area of mitigation for the loss of the land has bee proposed in the east of the site, though its success will depend upon achieving a high carrying capacity for the SPA species, which have differing habitat requirements. Whether or not this capacity can be achieved is uncertain.
Direct impacts on habitats within the development site
It is fairly clear that there will be a significant loss of habitat for those species that rely on the open farmland in this area, for example skylarks and yellow wagtails. There is still a lot of detail to be finalised regarding habitat creation and management in the areas not covered by solar panels.
The true value of the land
When Graveney Marshes were drained to create the arable land we see there now, a gap in the ecological network was created, and this farmland is one of the only undesignated coastal areas between Whitstable and the Medway Towns. There is huge potential for this area to be returned to nature to undo some of the damage done over the past several decades, and this is reflected in the Environment Agency's proposals to realign the cost here, producing a matrix of mudflat, saltmarsh and grazing marsh. Such a significant area surrounded by designated habitat provides one of the best opportunities we know to restore lost coastal habitats in North Kent.
Isn’t solar power good?
Kent Wildlife Trust is not opposed to solar farms, and we have extensive experience in advising on wildlife enhancements for such sites. We are also supportive of initiatives to reduce human reliance on fossil fuel energy generation. This must not be at the expense of other aspects of the natural environment, however. As with many development issues, it can be as much about ‘where’ as it is ‘what’. There are potentially significant issues with these particular proposals in this particular location, as detailed above.
Putting aside the potential impacts mentioned above for a moment, we also recognise that there may be opportunities to enhance certain areas of the site that will not end up under solar panels – the ditch network for example, and any ‘buffer’ areas.
What will Kent Wildlife Trust be doing?
As well as making sure our ability to manage South Swale Nature Reserve isn’t compromised (and ideally is improved), we will be scrutinising the survey work to ensure it is adequate and appropriate to assess the impacts of these proposals on the wildlife and habitats within and around it. We will be seeking to influence any decisions made to get the best possible outcome for wildlife. This is a very important area for wildlife, we need to ensure that it stays that way and becomes richer and better for nature in the future. We site on a 'Habitat Management Steering Group' convened by the applicant, alongside Natural England and the RSPB.
A 'Phase 2 Public Consultation' ran from the 31st May to the 13th July 2018. Kent Wildlife Trust's response to this consultation can be downloaded at the bottom of this page.
What can other people do?
These proposals have been classed as a Nationally Significant Infrastructure Project and as such will be determined in a different way to a ‘normal’ planning application. The developer has undertaken a couple of rounds of consultation with relevant stakeholders, including local people, including a A 'Phase 2 Public Consultation' that ran from the 31st May until the 13th July 2018. The application was submitted in November 2018 and accepted in December 2018.
Independent Planning Inspectors are examining the application, a process that includes further meetings and written representations, before making a recommendation to the Secretary of State. The Secretary of State will then make the final decision.