Longfield Solar Farm

Representations received regarding Longfield Solar Farm

The list below includes all those who registered to put their case on Longfield Solar Farm and their relevant representations.

SourceRepresentation - click on an item to see more details
Members of the Public/Businesses
Angie Garrard
"Whilst I agree that we need to be more sustainable particularly in light of recent events and do not oppose the project. My only concern is that the area where this site is planned is a haven for wildlife numerous Hares, Badgers, Deers, birds including the Sky Lark also the loss of agricultural land. This is also an area that has bridleways and paths for walking will these remain as part of the project?"
Members of the Public/Businesses
Arthur Hendry
"Main concern over the loss of good arable land in the current climate."
Members of the Public/Businesses
James Michael Charles Raven
"Concerns over the batteries that are used and the components that are used in them with regards to mining of these components."
Members of the Public/Businesses
Mark Richard Button
"the connection to the Grid is in the wrong place in Boreham. It is regrettable that the Longfield newsletter which arrived about April 2022 does not show where the connection will be. The connection should be where the earlier suggestions were; to the north. Just because there is an existing substation in Boreham does not mean that it should be so massively enlarged."
Members of the Public/Businesses
Nina Worley
"We live opposite the proposed site and have discussed with the developers early planting to obscure the solar panels from our house, we were assured that this would be considered for planting Nov 2021. This has not taken place. I would also like to continue to receive email updates regarding this application."
Members of the Public/Businesses
response has attachments
Roberta Mary Rance
"Please see attached."
Members of the Public/Businesses
Church Fields Allotment Association
"My comments are in relation of the works with respect to the access and use of The Church Fields Allotments situated on the Waltham road which are in very close proximity to the Grid Connection Route. In particular I would like to understand how the construction of the cable route will be managed such that there is no impact to the tenants of the Allotments on getting access to and using them as per normal. Note that tenants access the allotments both by car, cycle and on foot along the Waltham road."
Other Statutory Consultees
response has attachments
Natural England
"Please see attached."
Other Statutory Consultees
National Highways
"We are interested to participate during the hearing session and any other transport assessment review, Statements of Common Ground, local impact reports, and written related topics and discussions for the above-mentioned project."
Members of the Public/Businesses
response has attachments
Robin Dixon
"The proposals size, loss of food producing land, battery storage size and technology, joined up thinking between DCO applications on A12 widening and East Anglia GREEN all of which are set to impact on our community."
Members of the Public/Businesses
Peter Lawson
"This is a huge loss of valuable agricultural land when we are at a time of global food shortages. A mantra of Land is Food should be the cry to make the country more self sufficient in feeding itself. We cannot eat electricity though it may make our lives more comfortable. It is food that keeps us alive. Solar farm companies may make the case that we need every available solution to produce green energy for the benefit of household consumers and industry but it is they who ultimately benefit by raking in the profits paid by consumers for their electricity. Instead, the government should insist that all new housing and commercial buildings must have solar pv panels and battery storage installed as part of their design - and not a token number of 2 or 3 but full roof coverage. Roofs should be designed and orientated to take full advantage of the sun's position. This way the consumer is the one who benefits directly with lower energy costs and not paying indirectly to the solar farm companies, in effect cutting out the middle man. It is disingenuous to say the land will revert to its previous state at the end of the solar farm's life when that life is stated as 40 years. For many people affected that does actually constitute the rest of their lives."
Members of the Public/Businesses
Community Planning Alliance
"We believe that the Longfield Solar proposals not be granted a DCO. Our reasons are as follows: AGRICULTURAL LAND LOSS NPPF, rightly, makes the protection of BMV land a priority. The potential development area at Longfield is given as 275.3 ha. It is reasonable to regard the whole of the site as productive agricultural land. It is also obvious the developer has not made a serious attempt to look for or consider alternative sites. In Essex there are over 30,000 ha of poorer grade land providing ample opportunities for alternative sites for solar farm development. As a nation, we should be protecting our best farmland. There are 250,000 acres of south-facing commercial rooftops in England. Those (and east- and west-facing commercial buildings) and domestic rooftops should be used first. BIODIVERSITY AND LONGFIELD SOLAR FARM The unknown impact on the environment poses too great a risk to allow permission to such a substantive scheme. In 2019 a survey by BSG Ecology stated “evidence of solar farms impact on biodiversity remains limited… there is little empirical data on the subject. Natural England recommends the avoidance of solar developments in or near to areas of high ecological value. In the same report it was stated that the lack of evidence available relating to the ecological impact of solar farms is concerning. There are, in addition, concerns about follow-up management of sites once permission is granted . If the proposal is granted permission, an annual management plan must be agreed and the developer must set aside money to fund the management of the land. Money must be set aside to enable council monitoring and enforcement. LANDSCAPE Landscape and visual impact will be very significant. Enormous solar arrays represent an industrialisation of the countryside, which as intrinsic value. Mitigation will have little impact since trees and hedgerows that will be planted to try and limit the adverse impacts will have little effect through the early part of the scheme. CONSTRUCTION TRAFFIC During construction daily maximum moves of 96 HGVs on the strategic road network of which 50 HGVs would be on the local highway network via Wheelers Hill, Waltham Road and Cranham Road. BATTERY SAFETY There are significant risks of fire and explosion from thermal runaway from Lithium-ion batteries. The storage for the Longfield site will be one of the largest in the country and near population centres. It is clear the developer is aware of fire risks but it is difficult to comment on outline plans. It is dangerous for a DCO to be given until such time as fire risks are adequately assessed."
Members of the Public/Businesses
Dennis Watts
"Planning approval should be refused for the following reasons: Size is too big It is far too big and overbearing for the proposed location. If it must be allowed it should be a quarter of the size. Agricultural land loss The whole site is good quality agricultural land regularly used for growing crops. Loss will result in importing more food with the associated financial, transport and environmental costs. Parts of the 30,000 hectares of poorer quality land in Essex - much of it near power transmission lines - should be chosen instead. Landscape and biodiversity damage. Despite some proposed mitigation measures, there will be much damage to the beautiful rural area and loss of habitats for birds, animals and reptile. Local access road is inadequate and unsafe for HGVs During construction the daily maximum moves of 96 HGVs will mostly be on Wheelers Hill and Cranham Road, to the site, from Essex Regiment Way. These, plus minibuses for staff and more private cars will congest local roads totally unsuitable for HGVs and the volume of traffic involved in the project. The road is narrow. Overhanging trees have to be avoided. Vegetation often blocks drivers’ views. Large vehicles using this road extend across the centre of the road in many places, particularly on bends. I have frequently faced HGVs and other large vehicles dangerously approaching my car there and have had to take risky avoiding action. The proposed large increase in HGVs will make it even more dangerous. The published map shows inadequate proposed widening of the road. It still has sharp bends with poor visibility and bottlenecks where it passes through properties beside the road. I suggest inspectors should travel this route or at least view along it on Google Street View. If the plan is approved it will be essential for this road to be enlarged much more and straightened before any work starts on the solar farm. The planning and council involvement for the necessary improvements will need to be done well before any work starts on the solar farm. Conflicting massive construction projects will coincide and conflict nearby Adjoining/very near the proposed site will be the very disruptive combination of the construction of the Chelmsford NE bypass, the ‘North Chelmsford Garden Community’ of several thousand houses, 500 more houses at Blasford Hill, the improvement of the A12 and the construction of National Grid’s new 400kV electricity overhead transmission line with huge pylons. The amount of heavy construction traffic, noise, pollution and increased (already heavy) local traffic congestion will be hugely detrimental for local residents. This should not be made far worse by everything involved with the construction of one of the largest solar farms in the country. Who will be coordinating these simultaneous projects? Based on experience of the poor management and consequent traffic chaos of just the resurfacing of the B1008 recently, I do not have confidence that they will be efficiently managed."
Members of the Public/Businesses
Mrs Sue Webb
"My concerns re The Longfield Solar Farm Plan 1. Construction traffic affecting the local area 2.the visual impact of the proposed site on the local beautiful landscape 3. potential damage to our woodland, flora, and wildlife 4.loss of thousands of acres of food producing land 5.noise and vibration is an adverse effect of the scheme 6. battery safety is a potential fire hazard"
Members of the Public/Businesses
Mrs Sheila Gauden
"Living close to the site of the proposed battery storage units it is concerning to know that there have been fires in these units (causing noxious fumes) around the world. Being told that the health and safety has been assessed meaning that I would possibly have to leave my home, however temporarily that may be, is not exactly comforting. As we look forward, as a country, providing our own food is surely very important to cut down on the transportation of goods around the world which helps to cause global warming. I walk around the footpaths locally , particularly the footpath that runs next to part of the proposed battery units. Over the last few years I have seen many acres of good cereal crops on this proposed site. This is also the case on the proposed site for the main entrance to the solar farm.... acres of good cereal crops..... food that will no longer be available to feed us . We have been told that the solar farm is to built on MAINLY poorer quality farmland ..... I would like to know how much food we have to give up for that and what they call poorer quality. Many people walk the footpath to a bluebell woods , part of which will be adjacent to large battery storage units, and the first section of footpath from the Waltham Road is to be dug up to take the cables to the electricity station. Already the local walkers would lose the great views across open countryside but also use of the footpath while digging takes place....presuming the footpath is allowed to remain afterward. With the building work covering so many many acres of land, animals and birds(of which there are many) will be forced out of their natural habitat. There are many large industrial buildings and sites around this country with vast areas of roof space. Surely as a country we can think outside of the box and not always ruin areas of countryside that enable people to eat, relax and recuperate. The Waltham/Boreham Road is a country road already too busy. With added construction traffic?............."
Members of the Public/Businesses
Paul Possamai
"The proposed Solar Farm development on over 1,000 acres of high quality agricultural land is in direct conflict with both national strategic interest and government policy. This is an opportunistic attempt by the developer to exploit the co- existence of a single large landowner and access to the power grid. I have a number of very major concerns relating to this project and would prioritise them in the following sequence: 1. Loss of Agricultural Land\r\nRecent geopolitical events and climate change concerns have focussed renewed attention on our increasing dependence on importing food at greater cost and uncertain availability. It is evident; and current government policy, that we should preserve our agricultural land for food security and locate infrastructure development to brownfield, industrial and poor quality land wherever possible. The developer appears to have made no serious attempt to consider this, despite the existence of ample such sites and land in Essex. I have lived within the site boundary for many years and have witnessed the bountiful harvesting of cereal, sugar beet, oil seed, potatoes and other crops from the productive farmland that surrounds me. Consigning it to 40+ years of sterility would represent an extraordinary act of misuse of a valuable national resource. 2. Landscape The very extensive site comprises a landscape of moderately undulating farmland with distant views broken by ancient woodlands, copses surrounding ponds, varied natural hedgerows often containing mature oaks, ash and other deciduous trees. It is crossed by narrow (protected) country lanes, public rights of way and many informal bridleways, footpaths and the evident routes of deer herds and other animal species. The developer has accepted that the proposal will have a significant negative impact on the landscape and proposes mitigation essentially in the form of screening. The planting, over time, of additional hedging ( regulated to 3m height ) will possibly hide views of solar arrays, but will certainly destroy the open ,accessible and varied visual impact of a beautiful countryside. Roads and pathways for humans and animals will become sterile claustrophobic corridors.\r\nThis can only be described as Landscape Destruction on an almost unimaginably large scale. 3 Biodiversity Our commitment to improving our environment in the face of the climate crisis embodies a legal requirement to increase biodiversity. The proposed solar site, as indicated above, comprises a natural environment rich in number and variety of species of flora and fauna, able to thrive in a supportive and diversified setting.\r\nThe claim by the developer to deliver a bio net gain of 79% is unjustifiable. Ecologists and academics remain unconvinced of such claims and Natural England recommends the avoidance of solar farms in areas of ecological value 4 Need The key justification for this proposal is based on our drive to secure the net zero target for decarbonising our energy supply. Whilst this is an entirely laudable objective, it is the case that solar farms in the UK are relatively inefficient in comparison with wind, nuclear, hydrogen and other technologies. It is also the case that solar farms have a large carbon footprint. Manufacture, transportation , construction and decommissioning of large scale solar array installations are extremely carbon expensive.It is no wonder that the Government's current Energy Security Strategy concentrates on wind and nuclear as the principal vehicles for delivering future need. 5 Battery Safety The storage battery installation proposed by the developer will be one of the largest in the UK. The Lithium-ion battery technology employed has been plagued by catastrophic failures with fires and explosions experienced internationally, including a site in Liverpool. There is no adequate risk assessment contained in the submission. 6 Construction and Decommissioning There will be a significant impact on local communities and infrastructure during the construction (and decommissioning) phase of the project.The road network is already overloaded and the narrow lanes are inadequate for the proposed 96 daily HGV movements. There is also no indication of how this programme of transport and works will integrate and impact on other local infrastructure projects planned in the same area. NE Bypass, Garden Village. 600 workers , 7days per week, 12hrs per day 2 years of construction will have a dramatic effect on local life and amenity. Summary Our best agricultural land should be used to maintain and increase our food security. Our landscape is a precious national asset that enriches all our lives. We must preserve and treasure it. Our environment is at risk. We must continue to develop and invest in our ecology and biodiversity. Solar panels should be located in areas of low ecological value...rooftops, industrial sites, and land of poor value. ""
Members of the Public/Businesses
response has attachments
DWD LLP on behalf of Countryside Zest Beaulieu Park LLP
"We act on behalf of Countryside Zest (Beaulieu Park) LLP ‘CZ’ who are the landowner and developer of the new Beaulieu development, which outline consent was granted in 2014 for 3,600 homes, new roads, schools, neighbourhood centre and a business park (ref: 09/01314/EIA). CZ are also part of a joint venture with L&Q who will deliver the Chelmsford Garden Community (CGC) which will deliver a further 5,500 new homes. Beaulieu and CGC is located to the southwest of the Longfield Solar Farm application site (see enclosed plan). CZ supports the principle of the Proposed Development which includes a solar farm co-located with battery storage, together with an extension to Bulls Lodge Substation and underground grid connection routes. The Solar Farm application site includes land that is owned by CZ adjacent to Bulls Lodge Substation and required for the underground grid connection. Access is also required across CZ’s land from Generals Lane to the proposed site. As a relevant landowner and developer, DWD wish to register as an Interested Party and be included within any relevant representation on behalf of CZ. This will ensure that CZ can continue to deliver Beaulieu and CGC, whilst also ensuring the delivery of the proposed solar farm can take place with minimal disruption and mutual benefit of both CZ and Longfield Solar Energy Farm Ltd, as well as the wider Community. This letter follows on from previous comments at the Section 48 Consultation stage dated 13th July 2021 and a meeting held with the applicant on 27th September 2021. Follow up comments were sent to the Applicant regarding the revised Scheme Boundary consultation on the 23rd November 2021. As highlighted in our letter dated 13th July 2021, the key areas of interest to CZ which will need coordination with the applicant include the following: Flood Risk, Drainage and Surface Water;Landscape and Visual Amenity;Noise and Vibration; Socio-Economic and Land Use – ProW;Transport; and Cumulative Effects We request therefore to register on behalf of CZ as an Interested Party and be kept informed of progress of the Examination and given the opportunity to attend and speak at the Preliminary Meeting and hearings that take place during the Examination."
Members of the Public/Businesses
David Bull
"The cumulative loss from the Longfield proposal and all the other NSIPs, and smaller schemes going through LPAs, will result in the loss of thousands of acres of food producing land. The result will be more food imports at greater cost and with more uncertainty regarding food availability."
Parish Councils
Little Waltham Parish Council
"Little Waltham Parish Council notes that the main access proposed for the solar farm leads from the A131 Essex Regiment Way along Wheeler's Hill and Cranham Road. The Parish Council considers that this main access point is inappropriate for the site as it will mean that construction traffic will be using small country roads which are narrow in places and not at all suitable for construction traffic. It would resulting in damage to verges and will have a detrimental impact upon that rural area. Complaints have been received from residents in the area as to the impact upon the area and the Parish Council would like to state that it opposes the proposals for access to the site in view of the adverse impact upon the area."
Members of the Public/Businesses
Tritton Farming Partnership LLP
"Tritton Farming Partnership LLP is a rural business with approx. a one mile boundary with the proposed Longfield Solar Farm, thus have excellent local knowledge on the environment and land. The proposed scheme is unsuitable for the area as it is too large and on unsuitable land for a number of reasons. A large area is on Grade 2 land and a scheme of this size will significantly damage the rural landscape of this area. The proposed wildlife corridors are not sufficient for the roaming wildlife, population, particularly deer herds. The buffers of fencing to woodland areas, particularly external woodland should be 100 metres not 25 metres to preserve woodland habitants. High fencing within 25 metres have clear detrimental affects to protected species."
Members of the Public/Businesses
Prof. Mike Alder
"My academic specialisms include land use, ecology and the environment as well as agriculture and soil science. I have a number of concerns about the scheme which I hope the inspectorate will consider. My major concern is the scale of the proposals and the loss of valuable land. The energy security strategy encourages developers of large scale solar schemes to use land of lower value. I do not believe that Longfield have made any serious attempt to look for less valuable land and there are many options near the existing site with grid connections and many more throughout the county of Essex. The land is valuable. The strategic ALC shows the land to be grade 2 and hence BMV and protected by NPPF guidelines. The developer has employed a consultant to do a more detailed ALC this now shows 34% of the land to be BMV and the remaining area to be 3b this is still a substantial area. An analyses of the consultants report indicated that the BMV land could well be 55% of the total. Those of us who know the land well know that it produces a range of high yielding crops and excellent grassland. When I was Principal of Writtle University College we sold our dairy herd to Lord Rayleigh Farms (the Landowner) because of its excellence. Other soil measurements eg soilscapes also show the land to be of high fertility. I accept that Longfield by itself will have little impact on national food security but the cumulative effect of this proposal and all the other NSIPs and smaller schemes going through LPAs will. The inspectorate should therefore reject the scheme as it is on valuable land or at the very least only recommend a DCO for a much reduced proposal. My second concern relates to my knowledge of the area and as an environmentalist with a background in ecological science. The proposed site is near the River Ter, near an SSSI and near many valuable woodland areas. Such sites should be avoided for solar projects. I do not accept there will be a Biodiversity Net Gain. All the literature I have reviewed suggests a biodiversity loss under solar panels. In essence there is so little research on the subject of biodiversity on solar farms that it would be premature to grant approval for a scheme such as Longfield until more is known. The danger of granting approval risks significant environmental damage. My final concern relates to the loss of beautiful landscape in a crowded part of Essex and the loss of a major amenity. The mitigation proposed will not make a significant impact on the loss of visual amenity associated with the project. For the reasons above I suggest the inspectorate should not recommend a DCO be granted."
Members of the Public/Businesses
Solar Campaign Alliance
"My name is Dr Catherine Judkins and I am sending this representation on behalf of the Solar Campaign Alliance (SCA). The SCA represents a large number of groups who have significant concerns about ground-mounted solar farms on greenfield land in their areas. The group represents both NSIPs and other schemes seeking approval through local planning authorities. The Alliance acknowledges the importance of renewable energy resources. It accepts that solar PV (particularly roof top solar) has a part to play in supplying renewable energy. However, the SCA is against inappropriate development on greenfield land across the UK and is deeply concerned about the number and scale of such developments across the UK. The Alliance notes the recent Energy Security Strategy statement on solar which states that the government would “encourage large scale projects to locate on previously developed or lower value land. The SCA would therefore like to register our objection to the Longfield proposals on the basis that: The scheme does not comply with NPPF which stipulates that valuable farmland should be avoided. The land at the Longfield site sustains a range of high yielding arable crops and grassland. The UK is currently importing 40% of its food and this could soon be 50%. There has been a loss of 3.3% of arable land in the UK as a result of change of land use to growing bioenergy crops and solar farms. This could double, having a very significant impact on home-based food production, during a global food crisis. Valuable farmland, even if not all in the BMV category, must be protected. There is more suitable land in the vicinity of the scheme, which has not been assessed as alternative. The land quality assessment provided by the developer is not consistent with other publicly available assessments. The SCA has significant concerns about biodiversity on the site. The assessments in the application are insufficient. Biodiversity is protected by NPPF guidelines. The Alliance does not accept the metric used to measure biodiversity and believes that the very limited research on biodiversity on solar farms indicates a damage to wildlife and ecosystems. Until such times that adequate research data is available SCA believe it would be potentially damaging to allow such large scale proposals to go ahead with unknown environmental consequences. The Alliance has a number of other concerns relating to the Longfield proposals. It understands there will be significant adverse effects on the landscape in a highly populated part of the country where landscape is of high amenity value. We do not consider 40 years to be a 'temporary' loss of land SCA is very concerned about the dangers of fire and explosion from thermal runaway in BESS systems. Current regulations are inadequate to address this. 6.We also understand there could be noise pollution concerns around the site as well as issues relating to access, particularly during the construction phases of the project."
Members of the Public/Businesses
Louisa-Jane Sime
"This project will span almost the length of Boreham Road, Chelmsford. This particular road has been designated a protected lane by Chelmsford City Council (2009). The 2009 report sets out reasons for designation including historic significance, biodiversity and environmental value. As currently presented, the project does not consider the importance of limiting traffic flow and protecting the biodiversity of the area. There is also significant cumulative impact to the local area given the proposal for widening the A12, Chelmsford Garden Village and National Grid pylon proposal also now in consultation phases. Given the proximity of the proposed Chelmsford Garden Village, I would prefer to see each of the new builds here and nearby Beaulieu developments covered with solar panels to limit the impact to the local area. I would also like to see home solar panels and heat pumps offered to those living in closest proximity to the site to mitigate soaring costs of energy. I am personally in the process of installing panels on my own home but very aware that not all are in a position to do this."
Members of the Public/Businesses
Dr Anne Possamai
"Longfield Solar Farm Planning Application Climate change data demands that green energy sources are developed and utilised urgently across the world. However, it is vital that the value of natural resources is considered when planning for the production of green energy. The proposed Longfield development will use over a vast area of 275 hectares of high quality agricultural land for 40years. A large percentage of this land is of high quality (ie BMV) and all of it is a valuable agricultural resource. Our food supply in the UK is under threat and becoming more expensive in the current geopolitical situation and due to climate change. Currently 40% of our food is imported and this is due to increase to 50% partly due to the loss of productive agricultural land. An increase in food imports will increase food costs and mean more uncertainty about food availability. The appropriate siting of solar panel arrays is fundamental to energy security strategic planning. The use of productive land cannot be justified when there is no evidence that Longfield have considered the use of poor quality land of which there are over 30,000 hectares in Essex. The proposed solar farm will have a major negative impact on the local landscape. This is acknowledged by the developers. This large site comprises farmland with wide ranging views, ancient woodland and many copses surrounding dewponds. It is traversed by narrow country lanes, public rights of way and many informal footpaths and deer trails. The proposed measures to mitigate landscape destruction are welcomed but will take years to even begin to adequately screen the solar panel arrays. The loss of landscape and visual amenity will be disastrous for both people and the many animals who currently enjoy this resource. The impact on the biodiversity of this large area on both flora and fauna is not known and claims of bio net gain are not supported by currently available evidence. Academics and ecologists are sceptical about such claims and Natural England recommends the avoidance of large solar farms in areas of ecological value. The rationale for the Longfield proposal is to help meet the net zero target for decarbonising our energy supply. This is an important and valid reason but solar farms in the UK are relatively inefficient(20%) compared to off shore wind farms(50%). Solar farms also have a large carbon footprint due to manufacture, transportation, construction and decommissioning. The recent government (April 2022) Energy Security Strategy particularly focuses on off shore wind as the favoured source of renewable energy for this reason. The potential construction and later decommissioning of this project will have a severe negative impact on the local narrow road network. this is already busy and completely inadequate to accommodate the 96 daily HGV movements outlined in the proposal. The proposed storage battery installation will use lithium-ion battery technology. these have been involved in severe failures with fires and explosions worldwide. No adequate risk assessment concerning the use of these batteries is included in the submission. All the reasons outlined above mean that I am opposed to the planned solar farm by Longfield. Our food security is of vital importance and our landscape and biodiversity are valuable resources which we need to preserve."
Members of the Public/Businesses
Timothy Young
"I believe this project should be severely curtailed or rejected for the following reasons: - it is in an area of exceptionally beautiful countryside with a variety of habitat and wildlife. Such a use of this land would be a tragedy; - it is in an area (North Essex) that is already suffering from huge development, with housing estates, industrial buildings and new bypasses and roads cropping up everywhere. We cannot afford to allocate such a large amount of open countryside in this area to such a project; - it is using up valuable farmland at a time when geopolitical events indicate we should be looking to protect domestic food production sources; - alternative siting spots for such facilities should be considered - factory/building rooftops, by roadsides, on houses, on other brownfield sites - rather than plastering precious countryside and agricultural land. On this basis, whilst being a supporter of renewable energy, I do not believe the Longfield Solar project should proceed as set out."
Members of the Public/Businesses
Andrew Graeme Raybould
"The loss of productive arable land could be avoided by use of brownfield sites. The current energy crisis is balanced by a need to produce food which can only be achieved on arable land. The site will totally change the rural character of the area\r\nAny cabling should be below the height of the panels themselves. The proposed routing of construction HGVs is along Cranham Road/Wheelers Hill. These routes are not suitable for HGV’s to pass. Regarding decommissioning, the likelihood and timing is vague. What is the ongoing biodiversity plan? Does the site become ‘brownfield’ allowing other development to take place that is currently not permitted? The site impacts at least 3 parishes. None of the centres for these parishes are close by the site. Funds will be channelled to local communities. What is the definition of the local community? The residents on the edge/within the site are a tiny proportion but hugely affected and may see little or no benefit. The scheme will make little contribution to local employment once operational. If a monoculture field is seeded with 5 different grasses and 20 wildflowers then for the field ‘biodiversity’ has increased satisfying a 10% increase for that small area. If the total site is considered, including the woodland a much more robust plan not apparent. The woodlands will not be under the responsibility of the Farm Operators. They will be surrounded by fencing with limited access points for maintenance equipment and fauna. There is no proposed mechanism for accountability on biodiversity and wildlife issues with no independent verification. What if the Operators choose to reduce their commitment to the environment? The Report on the existing flora and fauna has no total species numbers, only the number of records and species densities for individual areas. How will a 10% increase be demonstrated if this is the base-line and by whom? Is this done on a tetrad by tetrad basis? What if some increase and some decrease? Over what time period does the 10% increase have to be shown? There are 50,000 records employed, how will a similar number be generated? Over 3 years it will require 400 records per week, logged and verified by the Essex Recorders Partnership. The effort involved should not be underestimated particularly for groups such as invertebrates. The fencing will mean that the significant deer population will be impacted. Areas outside the fencing will see larger densities of deer on the roads, increasing traffic incidents, and in gardens and paddocks of properties. The panels may not be adequately screened by hedging around the fencing. Unsightly arrays would then be visible from local properties. Most hedging is not thick at 3-4 metres and if enhanced then the character of the area will change. If panels are visible from properties what requirements are there of the Operators to rectify this? Hedging can take many years to grow and thicken and the Operators may not even deem it necessary."
Members of the Public/Businesses
Colin Cutler
"The project uses a considerable about on prime farmland. Taking this farmland out of use for over forty years will detract from the UK's food security. The main aim of the project seems to be to purchase cheap electricity at night from the National Grid and sell it back at a higher rate during peak times. A brownfield site is more suitable for such a project. The danger of Lithium Iron batteries is well known and serious incidents are documented. The Fire Brigade, by their own admission, are unprepared to fight such a fire and the site design does not include facilities to collect fire fighting run off water, which will be highly toxic and dangerous to the environment. I have request several times to see the whole life carbon foot print of the project, including manufacture of the panels and batteries, shipping, installation, decommissioning and, most importantly, disposal of the batteries. Will this calculation be made and compared to the potential cabin saving of the project? Will the calculation be made public? Why are not sites such as motorway and A road margins not being used for such projects? Food Security The war in the Ukraine has highlighted that our food security is at risk and the Longfield Solar Farm proposal will remove approximately 275 hectares (679 acres) of Best and Most Valuable (BMV) agricultural land for at least the next forty years, and probably forever because of contamination during the life of the project. On Tuesday 17 May the national press reported the Governor of the Bank of England warned of “apocalyptic” food price rises. In the face of such predictions, how can any BMV land be sacrificed to this project? Food Carbon Footprint Importing food, if it is available (the Ukraine war has shown food may not always be available for import) to make up the shortfall created by sacrificing BMV land to the Longfield Solar Project will require more imports, which will use more carbon to ship it to the UK, let alone the financial cost to the country. Land Classification The original Land Classification Maps show the whole of the proposed site as Grade 2, and therefore BMV. How is it possible for the Longfield project to have the land reclassified to 34% BMV? May we see the details and especially how the calculations have been made with detailed focus on how the land may or may not be farmed? It seems that where area of high-quality land is surrounded by lower (but still farmable) land, the whole area has been downgraded. This does not reflect a true picture of the land quality. Selection of the sites The National Planning and Policy Framework requires developers to use poorer land. The developers do not seem to have displayed this information. There seems to be ample poor quality land on the margins of motorways and trunk roads, and “brown field sites” which should be used before any good quality agricultural land is even considered Is the Solar Farm a “front” for battery storage? The battery capacity being installed seems to far exceed the solar panel electrical generating capacity. Is the plan of the developers to install excess battery capacity so they may purchase low cost electricity from the National Grid and sell it back at a profit during times of need? Longfield Solar Farm denied this when questioned at a presentation, so why the extra battery capacity? If the plan is to buy and resell excess electrical generation, two questions must be answered: 1.Why not place the batteries on an industrial site and have minimum battery capacity located on BMV land. 2. Why is the Government not implementing such battery or power storage on industrial sites to save power and money? Total Carbon Footprint of the project lifetime\r\nThe purpose of installing solar panels is to achieve carbon zero, however, in spite of requesting the information on a number of occasions, I have yet to see the project life-time carbon footprint compared to other available electricity generating opportunities, including gas and particularly off shore wind and tidal schemes? There will be a carbon footprint for all these stages, and probably more than I know about: Manufacture of: the solar panels. the solar panel support structures. the electricity cables and control cables the storage batteries the containment and environmental controls for the batteries Shipping: all the manufactured items to the UK, probably from China all the equipment to site all the staff to site for the installation and then for ongoing management and maintenance At the end of the project: decommissioning and disposal of the solar panels and supporting structures decommissioning and disposal of the batteries, we have seen no details on how this will be accomplished decommissioning of all the site infrastructure; cables, control equipment, containment, etc restoration of the soil and water courses to agricultural BMV land There will be a carbon impact by all these actions and it would be unwise to proceed without a clear “balance sheet” of impacts and benefits. Recognised dangers of storage batteries There are many recorded cases of Lithium-Ion batteries igniting, usually caused by the batteries overheating. The batteries then burn without the need of oxygen. The recognised way to stop the batteries burning is to cool them with water. To provide an example of the amount of water required: a Tesla car battery caught fire in the USA and 36,000 US gallons (30,000 UK gallons) to cool the battery. The batteries proposed for the Longfield project are many thousand times larger than a single Tesla car battery.\r\n\r\nThe Essex Fire brigade are unprepared to deal with an emergency relating to the batteries and have no plans to make themselves prepared. If the batteries did ignite the resulting toxic gas cloud with cover a significant area (including Terling, Fairstead and proposed Chelmsford Garden Village), cause health hazards to people, disruption to all forms of transport and services, and the probable destruction of wildlife. If the batteries are cooled with water, the run-off water will be toxic and should be collected and treated before it can make contact with soil. This is a huge task requiring bunding of the battery sites and the Longfield project has no plans to deal with such an emergency. I refer the reader to the paper Safety of Grid Scale Lithium-ion Battery Energy Storage Systems by EurIng Dr Edmund Fordham MA PhD CPhys CEng FInstP Fellow of the Institute of Physics; Dr Wade Allison MA DPhil Professor of Physics, Fellow of Keble College, Oxford University; Professor Sir David Melville CBE FInstP Professor of Physics, former Vice-Chancellor, University of Kent, available here. Landscape Landscape and visual impact on this pleasing site in Essex will be significant. Fields of crops will be turned into fields of solar panels and huge battery storage sites. The proposed mitigation will have little or no impact since the promised trees and hedgerows to try and limit the adverse impacts will have little effect in the early years of the project. Noise, Glint and Glare There will be significant noise created by the installation and eventual decommissioning of the site. Additionally, equipment required to maintain the battery operating climate will emit “humm”. We do not yet understand the level of noise, but it is likely to significant for local residents. Glint and Glare from the thousands of solar panels will be significant. Besides impacting the visual amenity of the residents, we have no idea of the impact on birds and wildlife. Traffic There will be a massive increase in road traffic during the construction and decommissioning phase of the project and will disrupt the local roads, local business and the lives of residents. The construction phase will coincide with the various A12 road schemes and compound the disruption and damage to local road and infrastructure. Conclusion The project will drastically reduce the amount of BMV land available to secure the UK food supplies; produce significant amounts of carbon during the manufacture, implementation and decommissioning phases; be a relatively low (compared to wind farms) producer of energy, damage the environment beyond repair and create significant risk from the batteries. We need energy, but there are more effective and efficient solutions, such as off shore windfarms and tidal schemes, none of which require the sacrifice of BMV agricultural land."
Members of the Public/Businesses
Steven Silvester
"I wish to know the route of the cable from sun station to the solar farm."
Members of the Public/Businesses
Sarah Anne Raybould
"I strongly object to the proposed solar development due to the effect it will have on my immediate environment and also the unsuitability of the land. First and foremost this is high grade versatile agricultural land which is needed for food production and should be a last resort for any development. Solar developments should rather be sited on brownfield sites, roof tops and similar . There is no evidence that more suitable sites have been explored in this case, which the government's National Planning Policy Framework says should be encouraged. Secondly, this is an area of open Essex countryside and this industrial development will drastically alter its character of open farmland views. it is an area used for recreation by those living nearby, including myself, for walking and horse riding , and also by large numbers of cyclists. Proposed planting to help in reducing the visual impact will take many years to develop and still will have completely altered our landscape - Essex is known for expansive vistas with large skies .There will be solar panels visible at the edge of our property over and through the hedgerow certainly for many years to come. This is a major impact on us and a change to the natural views we expect living in the countryside. I am very concerned too about the effect on biodiversity and wildlife. Whilst the developers claim they will provide net gain, there is no proper evidence for the effect that a solar farm of this scale will have on the environment. It seems inevitable for instance that replacing agriculture with industry will affect birdlife , particularly ground nesters such as skylarks, and each change to species has a knock-on effect to others. This area also has large herds of deer which will be displaced by this development. Whilst there will be paths through , it seems likely that the deer will stop at the boundaries damaging gardens of those on the periphery and spilling onto local roads, particularly Boreham Road, causing more accidents. This area is too big for an experiment on the effect on our wildlife. and irretrievable damage could be done. Another concern is the traffic on our small local roads during construction. This will undoubtedly disturb residents on Waltham Road and Cranham Road . It will also cause a significant problem on Wheelers Hill where the road is not wide enough for two HGV's to pass and cannot be remedied due to properties on either side. There is the potential for regular accidents and delays to traffic."
Members of the Public/Businesses
Linda Teresa Reed
"The Development Consent Order should be withheld due to: Loss of Agricultural Land: This is a large greenfield site of good agricultural land, including best and most versatile (BMV), currently farmed for food crops. Food production must be prioritized because supply is being disrupted by climate change, reduced availability and high cost of imported food, and land loss to energy/carbon offset schemes. Solar farm proposals involving BMV land should be justified by compelling evidence. However, selection of Longfield over available brownfield and poorer greenfield sites with proximity to the National Grid has not been justified. Loss of Landscape and Amenity: Longfield will fundamentally change key landscape characteristics from farmland to industrial energy production featuring solar panels, substations, battery storage, monitoring towers with associated traffic, noise and light pollution. Mitigation is to screen Longfield with hedgerows and tree planting. This screen will not be effective for several years and will close in footpaths which previously enjoyed wide views resulting in loss of amenity both during and after construction. Larger elements of Longfield will always be visible. Biodiversity Loss: Under the Environmental Act 2021 developers should minimize negative impacts on biodiversity, delivering net biodiversity gains above 10%. Developer's claims to be doing this are not reflected in the DCO application. Construction will severely disrupt existing ecosystems for 2 years. Some populations are unlikely to recover with potential loss of red/amber list birds, great crested newts and bats. Site recovery as habitat for wildlife will take several years. Toppinghoehall Wood is mixed ancient/newer woodland and rich habitat for invertebrates, reptiles (slow worms), bats, owls, hobby, red kites and buzzards living and breeding there. Siting the BESS next to this wood is likely to disrupt bat flight lines and disturb nesting birds due to construction, operating noise and light pollution causing biodiversity loss. Traffic disruption: Developer’s preferred route to the site is from Essex Regiment Way via Wheelers Hill and Cranham Road, a narrow country lane where lorries struggle to pass each other. Extensive widening of Cranham is proposed. This will cause traffic disruption and, if project timelines slip, could clash with other major works including Chelmsford North East Bypass; Chelmsford Garden Village, A12 widening and Boreham Interchange modifications. The second approach via Main Road (B1137) and Waltham Road is unsuitable. Tail backs often occur on Waltham and Main Road through Boreham village after incidents on the A12 and due to other roadworks. Local roads cannot support Longfield construction traffic. Battery safety: Using lithium-ion battery (LIB) storage poses a risk for public health and emergency services. LIBs comprise highly reactive materials in contact with flammable organic electrolytes. At elevated temperatures LIBs can fail, causing exothermic reactions (thermal runaway) and can explode, releasing toxic, flammable gases. If this occurred, as has happened in the past, siting the BESS adjacent to ancient woodland, increases potential for fire to spread. Even with technology improvements and safety measures proposed, the risk is significant."
Members of the Public/Businesses
British Transport Police
"At present I have no objections to the planned application."
Members of the Public/Businesses
response has attachments
Mr John McKenna on behalf of Mr Frederick George Bentley
"Please see attached."
Members of the Public/Businesses
Essex Area Ramblers
"The development should conform to NPPF paragraph 98 at all stages. The development should conform to the Draft Overarching National Policy Statement for Energy (EN-1). Existing PRoWs, or acceptable alternatives, should remain open at all times. The ambiance of these PRoWs will be negatively affected by the construction and operation of this site, and measures should be taken to keep this to a minimum. It is essential that sufficient width and mitigation measures are implemented along the ProWs to ensure that users do not feel hemmed in by the fences and CCTV systems. \r\n\r\nSignificant viewing points should be maintained. Measures to increase the safety of walkers, cyclists and horse riders using the access roads will be needed."
Local Authorities
Essex County Council
"Essex County Council Relevant Representation for Longfield Solar Farm Thank you for confirming that Essex County Council is a host authority (C Authority) for the Longfield Solar Farm application under section 102(1)(c) of the Planning Act 2008, and a such is automatically an Interested Party for the duration of the examination. Following the Planning Inspectorate’s acceptance on 28th March 2022 of an application for a Development Consent Order (DCO) for Longfield Solar Farm, and to assist the Examining Authority when it carries out its initial assessment of principal issues, in advance of the preparation of the draft examination timetable, Essex County Council wishes to make a relevant representation, in respect of our main areas of interest. In summary, Essex County Council’s main areas of interest and of relevance to this DCO Application cover the following topics: Highways and Transportation Public Rights of Way (PRoW) Flood Risk, Drainage and Surface Water Minerals and Waste Archaeology Climate Change including renewable energy Socio-economics - jobs and skills Essex County Council will set out its position and provide full detail for the areas listed above in the Local Impact Report, currently in preparation, as well as provide its view on the broader planning issues relating to this DCO Application. This will be submitted to the Examining Authority by the due date. Engagement between the applicant and Essex County Council, following Statutory Consultation and prior to the submission of the DCO Application, together with two additional pre application Statutory Consultations undertaken in October 2021 and in January 2022, have raised matters which include, but are not limited to: The requirement for Road Safety Audits for all proposed highway works, including access, road crossings and road widening. The impact of works on the status of the Protected Lanes. The potential implications of glint and glare on the road network and road safety and on users of the PRoW network. Mineral sterilisation on an area of land permitted for mineral extraction. Under the Agent of Change principle that any maintenance of solar panels required due to the deposition of dust from mineral extraction is the responsibility of the operator. Disapplication of Section 23 consent to undertake works/alter an ordinary watercourse. The archaeology trial trench evaluation report and the presentation of data require amendments. Detail required on the mitigation proposals in terms of locations, methods and potential to mitigate by design, in the area identified as possible WWI practice trenches, which are considered of archaeological interest and importance. Detail required on how the mitigation proposals can provide enhancement and betterment to the cultural heritage/historic environment. Jobs and skills in the renewable technology sector to support the county’s green economy. Essex County Council will continue to engage with the applicant on this DCO Application on the above-mentioned matters and will continue to work in close collaboration with Braintree District Council and Chelmsford City Council."
Members of the Public/Businesses
J Halfhide
"The Government’s recent Energy Security Strategy sets out that large scale schemes, such as Longfield, should be located on land of lower agricultural value. If approved, this application is likely to pave the way for further schemes, and as such great consideration needs to be given to the loss of BVM land and the wider impact this would have on the UK’s food security going forward. BMV land within the site boundary amounts to 34% with Subgrade 3b (still with high yield) being 55%. The applicant has not sufficiently demonstrated that they have sought alternative sites of lower agricultural land value. Additionally, the applicant’s reasoning for why areas of BMV have been kept in the Order Limit include the reduced amount of energy to be generated if the scheme were reduced in size, and the overall effect of removal on the single continuous site. Neither of these explanations are acceptable reasons for including BMV land in the proposals, especially since the National Planning Policy Framework makes the protection of BMV land a priority. It seems apparent there would be unacceptable loss of BVM if the DCO were to be granted. Of particular concern are the Lithium-ion batteries. Battery fires and the thermal runaway phenomenon will continue to occur and, alarmingly, we currently have no engineering standards to prevent them. Measures to mitigate and the reality of the potential hazard to people, livestock and the environment have not been clearly set out for the public consultation. It would be premature for a DCO to be granted until the risks and mitigation have been fully presented."
Members of the Public/Businesses
Vincent Fruchard
"The project is going to destroy high quality farmland at a time when food supply is becoming a strategic issue (Ukraine war, high inflation). It will destroy the landscape. The site will never go back to farmland and will be eventually developed for poor quality badly insulated residential properties. There are plenty of better sites for solar panels: along main roads like the A120 for example and on top of commercial buildings. There is in addition a serious risk of fire with battery storage substations.. Solar panels are inefficient. Nuclear power stations are a much better stable long term solution."
Members of the Public/Businesses
Rita Watts
"The overall area occupied is much too big This change to semi industrial landscape is far too big, overwhelming and overbearing for the proposed location. If it must be allowed it should be a quarter of the size. Farming land loss Over many years I have seen the site used for growing food crops, so its loss will result in importing more food with all the financial, transport and environmental costs. Some of the 30,000 hectares of poorer quality land in Essex, where near power transmission lines, should be chosen instead. Landscape and wildlife damage There will be much damage to the beautiful rural area and loss of habitats for birds, animals and reptiles despite the attempts to reduce this. The chosen access road is unsafe for HGVs I have seen many near misses with oncoming HGVs taking up the most of the road on bends. A great many HGVs will be on Wheelers Hill and Cranham Road, to the site, from Essex Regiment Way. Minibuses for staff and more private cars will congest local roads totally unsuitable for HGVs and all the traffic involved in the project. The road is too narrow. Overhanging trees and vegetation often blocks drivers’ views. The proposed large increase in HGVs will make it even more dangerous. The published map shows inadequate proposed widening of the road. It still has sharp bends with poor visibility and bottlenecks where it passes through properties beside the road. I hope inspectors will travel this route to see its inadequacy. This road would need to be enlarged much more and straightened before any work starts on the solar farm, involving local councils for the necessary improvements. Very large construction projects will take place nearby causing a chaotic situation These include the construction of the Chelmsford NE bypass, the ‘North Chelmsford Garden Community’ of several thousand houses, 500 more houses at Blasford Hill by Bloor, the improvement of the A12 and the construction of National Grid’s new 400kV electricity overhead transmission line with huge pylons and possibly this, one of the largest solar farms in the country. How will these simultaneous projects be efficiently coordinated? Based on experience of other recent minor works with their poor management and consequent traffic chaos I doubt that they will be efficiently managed."
Members of the Public/Businesses
David Arthur Kelly
"I strongly object to this industrial scheme on the grounds of visual impact on a huge area which provides rural amenity routes totalling more than 9 miles including country lanes, footpaths and bridleways, extensively used by walkers, runners, cyclists, horse riders and motorists to exercise in a beautiful, green, peaceful environment. Many miles of these tranquil routes traverse fields with open views across landscape which will be blighted either by being restricted to a view of security fencing and panels or if “mitigated” by planting will become enclosed public rights of way (PROWs) with restricted views of landscape and sky. Construction of this industrial solar power plant will thus result in gross urbanisation of a valuable rural asset. Users of these PROWs include local residents of the picturesque villages and hamlets of Terling, Fairstead, Gambles Green, Flacks Green, Fuller Street, Boreham, Little Waltham and Ranks Green but also are drawn from Chelmsford and the towns of Braintree, Witham and Maldon. These have been recently expanded in number of dwellings and residents resulting in loss of green space and with that loss, decreased access to quality, rural, amenity space, making the remaining land more precious. This scheme will remove more than 1400 acres of such land and the views from it’s urbanised PROWs will be severely impaired. For many reasons including rising fuel costs, pandemic, demographic change, war and global political unrest, the population needs more recreational facilities close to home, this scheme will deprive a population in excess of 350,000 of an amenity which is vital to their mental health and wellbeing. From a personal perspective I object to losing the benefit which I have derived from running and walking through this rural landscape for the last 32 years. I also object to the adverse visual impact this will have on my home, (REDACTED). In discussions with the developer during the consultation phase I have been reassured that they will make adjustments to mitigate this adverse impact. From the confusing documents supplied, however, it is clear that from the first floor windows on the north side of the property and particularly from the barn, views to the south of the property will be exclusively a view of panels. If the scheme goes ahead then I ask that no panels are placed in the field to the north of WHF and that considerable effort should be made to lessen the impact from panels to the south east. I am also concerned about the effects of noise pollution during the construction and operating phases of the development. The latter being the threat of low frequency noise from inverters placed near to (REDACTED) which may have severe adverse effects on my mental and physical health. In this respect I must point out that I am a veteran of both the conflicts in Iraq and Afghanistan and deployed on 12 occasions from 2002 to 2012.(REDACTED)"
Members of the Public/Businesses
Scarlet Stapleton
"Proposed solar farm will severely impact the farm land I think importantly, that now there is a growing crisis in the supply of grain from Ukraine and Russia. There should be no further loss of such productive land due to the growing importance of UK food security. There is also a large number of house being built in the same area, introducing a solar farm too will mean significant agricultural land being lost."
Members of the Public/Businesses
Ruth Kelly
"1) Inadequate consultation. No information received by post repeatably therefore missed opportunities to attend meetings. Who else has not been told? 2) Visual impact. Views from our home impacted both to the north and towards Scarletts Wood. Supposed mitigation to the north is in an area not in view from our home. No mitigation towards Scarlett’s Wood. Glint and glare will substantial. Screening will not be sufficient to prevent this and will in any case take 10-20 years to mature. 3) Low level hum can adversely effect on mental health 4) Corridor for wildlife will be through our garden as their normal routes will be fenced off. Deer will be very destructive. No mitigation offered 5) For 32 years daily walks along tracks will no longer have beautiful views of the Ter valley, Great Leighs church and across open fields. Instead footpaths will be surrounded by fencing and, maybe, security lights. Openness will be replaced by a sense of enclosure. This will have a detrimental effect on well-being that the countryside is recognised to provide 6) Water/sewerage to and from our property comes from the south across fields and leaves to the north. Once covered with panels there will be no access. What provision has been made for continued provision of this service? 7) Traffic on a restricted lane (Boreham Road) will increase and be too large for a country lane.This will alter the nature of the area . 8) Lane will be taken out of food production giving concerns for the food security of the nation if schemes like this go ahead and are replicated. 9) Is this a carbon neutral scheme? What plans for panel recycling, removal, obsolescence of technology? 10) What proof of increased biodiversity that could not be achieved by altered farming methods? 11) This is a large area using good agricultural land. Large areas of Essex are brownfield sites or industrial units and factories, the roofs of which could be used for solar panels. Housing development in Chelmsford is continuing at a pace with no requirement for renewable energy. Why is this not considered essential by the planners as opposed to using land which could provide food? What alternative sites were considered and why were they rejected? 13) destruction of flora eg orchids 14) This is an opportunity to reinstate fruit varieties which originated from farms in Boreham and will soon lost. 16) Who will manage the wildflower meadows or will the land be left to naturalise? What are the long term plans for management? What plans for electricity to be supplied free of charge for those whose homes are changed irrevocably by this scheme?"
Members of the Public/Businesses
Anthony David Chambers
"All of my comments relate to the construction site access along Cranham Road and Waltham road. 1. Craham Road is know as a very narrow carriage way with no foot paths and encroachment of hedges. I query if it is possible to widen the carriage way with out taking land in private ownership. 2. Waltham Road and Cranham road are effectively the Chelmsford bypass with severe traffic congestion during the peak hours. Traffic in the morning peak travelling west along Cranham road to the A130 often backs up half a mile due to static traffic travelling south on the A130. If there are deliveries to site at this time HGVs will back up on to the A130 as they will not be able to pass the stationary vehicles on Wheelers Hill. 3. A full TIA is essential for normal working days not only during covid. 4. Car traffic on Cranham road will stop or reverse in several location to allow an HGV to pass. 4. No footpath links to the garden village are shown although they were indicated on the early proposals. 5. The proposed construction access point will be extremely unsafe. A examination of ECC accident reports will clearly identify that this is an accident black spot and the number of incidents at the proposed access point. Several vehicles, cars and HGVs a year slide in to the ditch at this point when travelling north. Vehicles also leave the carriage way opposite the proposed access when travelling south. 6. As the site access is on the inside of the bend on the Waltham Road, HGVs leaving the site vehicles will obscure any vehicles travelling south along the Waltham Road. This can on exasperate the likelihood of northbound vehicles leaving the carriage way. 7. Reducing the speed limit at this point to 30 mph would make a great deal of sense. 8. A construction management/Traffic management plan must be submitted with restrictions on deliveries all construction traffic and site workers out side peak hours."
Members of the Public/Businesses
Campaign to Protect Rural England - Essex
"1. Landscape If approved, the site will be one the largest solar farm developments in the UK, involving over 450ha of open countryside. Fields containing continuous rows of metal and glass will bring a dramatic industrial scar to the rural environment which is further damaged by perimeter security fencing, floodlighting, CCTV towers and a range of buildings housing all of the associated apparatus including the battery storage units. Longfield Solar Farm will therefore have a significant impact on the landscape and a visual impact on an attractive part of the Essex countryside. The scheme would result in the loss of some key characteristics, namely the agricultural character of the area and reduction in the sense of openness. The visual impact on the landscape will be very significant and is a major concern. Mitigation will have limited impact since trees and hedgerows that will be planted to reduce the adverse impacts will have little effect through the early years of the scheme. 2. Loss of Agricultural Land All the land affected is good quality agricultural land, the majority being Grade 2. National planning guidance indicates a strong presumption against solar farm development on the ‘best and most versatile farmland’ (classified as Grades 1,2 and 3A). Similarly, the BRE ‘Planning Guidance for the Development of Large Scale Ground Mounted Solar PV Systems’ also underlines the fact that national planning policy would not support development on higher grade agricultural land and specifically states that ‘the best quality land should be used for agricultural purposes’. The potential loss of so much BMV agricultural land is extremely concerning as food production loss would be significant. Current UK food production is around 50% of total need - to improve food security, the target is 70%. Current events in Ukraine have underlined the urgent need to become more self-sufficient with less reliance on imports of basic foodstuffs. The National Planning Policy Framework generally aims to protect agricultural land of this calibre. \r\n\r\nFundamentally, a single scheme of this size in this location should not be promoted when a number of dispersed smaller sites utilising ‘brownfield’ or low grade agricultural land would be much more appropriate and acceptable. There has been no evidence given that other sites have been considered, with this site being favoured by the convenience of having a single landowner - despite the scale of the project being totally inappropriate to the area. 3. Permanence CPRE is concerned that this and other solar farms are using the argument that after several decades (in this case a lifetime of forty years) the facility will be de-commissioned and the land returned to agriculture. However, it is highly likely that the PV panels will, one way or another, become redundant before the expiry of the 40 year lease term and quite possible that more efficient sources of electricity production will have been found, thereby rendering the panels obsolete. The operating company has stated in public it may seek to sell its leasehold interest at some time. Assurance that the costs and obligations of future reinstatement are guaranteed or bonded is therefore crucial. However, experience elsewhere shows that many such agreements have proved worthless. There is, therefore, huge uncertainty as to whether the site will ever be returned to agriculture or to a natural state. If PV panels have become obsolete it is quite likely that the operating company will have ceased to exist, so in that case and/or where any bond is worthless or inadequate, there will be uncertainty whether the landowner will undertake any reinstatement. In addition, the cost of de-commissioning and re-cycling is likely to considerably outweigh the value of what is created, leaving an abandoned and derelict site. There is then a possibility that the site could be classified as ‘brownfield’ - which could lead to pressure to redevelop for another unsuitable use. 4. Impact on the Local Community Rather than contributing positively to the local community, the proposals are more likely to have a negative effect on most local residents. The prolonged construction phase will generate a significant amount of construction traffic using the local (inadequate) road network. Within the whole site, temporary infrastructure - such as internal roads, construction and welfare compounds - together with noise from percussive groundworks will seriously affect the amenity and tranquility of the area and its biodiversity. The proposals will fundamentally change the nature of the landscape for both residents and visitors who enjoy access to the open countryside for recreational purposes with its extensive network of public rights of way both within and adjacent to the site as well as the area’s quiet lanes. It is increasingly acknowledged that exposure to natural environment is of great benefit in terms of wellbeing and good mental health. The benefits of exercise for both physical and mental health are even more widely recognised. 5. Biodiversity The site is of significant biodiversity value with its range of habitats and important species identified in the surveys. Despite the proposed mitigation and enhancement measures, a solar farm on this scale will certainly damage traditional habitats through the concentrated development of industrial plant and infrastructure. Security fencing surrounding large areas of land will remove traditional pathways for transitory animals and bird deaths are likely to be a common occurrence as large areas of glazing are mistaken for water. Essentially, the land will be changed from rural to industrial with a consequential impact on local wildlife. Also, new woodland creation will take a considerable time to mature, so any of the stated visual/habitat benefits would take years to become established. A further concern is the potential impact on the quality of the soil. Large arrays of solar panels will change the way rainwater falls on the ground, air currents will change and large areas will be permanently shaded from sunlight. It is unknown what impact these environmental changes will have on the ability of the soil to store carbon and could potentially be counter-productive in the stated objective to reverse climate change. 6. Statement of Need CPRE takes very seriously the need to develop alternative sources of energy. However, the siting of such facilities needs to be handled with sensitivity. Despite its ‘green’ intentions, the proposed development is essentially a huge industrial site resulting in large scale blighting of the natural landscape. Government guidance has for many years has has indicated greater support for offshore wind farms and repeatedly aimed to discourage solar farms on productive agricultural land. The Government’s Energy Security Strategy (April 2022) concentrates on offshore wind and nuclear, with no targets set for solar power. The strategy states it will ensure environmental protection for ground mounted solar and large-scale solar projects will be encouraged to locate on previously developed or lower value land."
Members of the Public/Businesses
response has attachments
Environment Agency
"Our relevant representation outlines where we consider further work, clarification or mitigation is required to ensure that the proposal has no detrimental impact on the environment. The submitted Flood Risk Assessment (FRA) is not adequate. Our main concern relates to flood risk modelling. We are not satisfied how the Flood Zones have been defined for the purpose of siting the Solar PV panels, Solar Stations and Balance of Solar Systems (BoSS) in Flood Zone as the applicant has not undertaken site specific hydraulic modelling of the River Ter and Boreham Brook (tributary) but have instead used the Braintree SFRA outlines to define the fluvial Flood Zones. The applicant will either need to remodel or assess that there is no 'critical infrastructure' within Flood Zones 2 or 3 or ideally that critical infrastructure is outside the 0.1% (1 in 1000) annual probability event with allowance for future climate change (maximum credible scenario). Further information can be found within our full letter referenced AE/2022/127023/01-L01 and dated 25 May 2022 which we have emailed to [email protected] We request that this letter is uploaded as part of our formal submission."
Other Statutory Consultees
UK Health Security Agency
"Thank you for your consultation regarding the above development. The UK Health Security Agency (UKHSA) welcomes the opportunity to comment on your proposals at this stage of the project. Please note that we request views from the Office for Health Improvement and Disparities (OHID) and the response provided is sent on behalf of both UKHSA and OHID. We can confirm that: Human Health and Wellbeing This section of OHIDs response, identifies the wider determinants of health and wellbeing we expect the Environmental Statement (ES) to address, to demonstrate whether they are likely to give rise to significant effects. OHID has focused its approach on scoping determinants of health and wellbeing under four themes, which have been derived from an analysis of the wider determinants of health mentioned in the National Policy Statements. The four themes are: Access Traffic and Transport Socioeconomic Land Use Having considered the submitted ES OHID wish to make the following specific comments and recommendations: Methodology - Determination of significant effects It is noted that Chapter 15 is drafted with reference to the Healthy Urban Development Unit and as such no assessment of significance is provided for human health. This does not conform to the requirements of the EIA Regulations and as such an assessment of significance will be required to form part of the ES. Recommendation The ES must provide an assessment of significance for those health determinants scoped into the population and human health chapter. The population and human health assessment should draw upon the findings from other relevant chapters, including air quality and noise. As there is not a defined approach to the assessment of significance for population and human health, it is strongly advised that any proposed approach is agreed with OHID/UKHSA and the local public health team. The guidance issued by the International Association of Impact Assessment (IAIA) could be used as a basis for the assessment of significance. We can confirm that we have registered an interest on the Planning Inspectorate website. Please do not hesitate to contact us if you have any questions or concerns."
Members of the Public/Businesses
Ann Jones
"Object on grounds of battery storage, recycling of batteries and equipment."
Members of the Public/Businesses
Catherine Gaywood
"Boreham should be connected to the permissive path network that is being proposed within and around the solar farm. This is possible 90% within the project boundary. Route through boreham industrial estate, cut through hedge (neg impact), then into the project boundary. The path can be joined to existing PROW. Traffic management along Main Road Boreham needs to be provided. Collective major infrustructure projects will have a detrimental impact on traffic flow through the village, yet no mitigation, such as provision of cycle lanes, increased width pavements and the reduction to 30mph. Three projects are Solar Farm improving the attractivness of a 'rat run' - Cranham Road. The A12 Hatfield Peverel junction colosure and the North Chelmsford developments and new station. Each project should be required to contribute to the traffic calming measures within Boreham. Future adaptations within the solar farm - EDF must set out how they will communicate with the local community - suggest a minimum of XX months notice in writing to the parish council setting out what, when, why and give account of hte expected impact to the site (habitat, visual, noise, times, traffic etc). This is not to stop the adaptation ensure decisions are made that are transparant. The ‘moving’ technical standards should not be an excuse to just buy the cheapest or to avoid giving specifications to what will be installed. Eg – the converter things that will be dotted around the fields are unknow at this point. They could be housed in shipping containers they could be left open. What is actually provided is what gives the best value for money at tender stage. This does not mean that standards should not be set for both options. EG – a containers should be painted in neutral colours and not bright primary colours. OR – The preference is for the use of containers so that the infrastructure can be shielded to minimise the visual impact. Confirmation re the screening of the on site substation. (13mheight) Existing woods and additional ‘corridor’ to screen great – however – how long will this natural screen take to establish and be fit for purpose. Can EDF – purchase mid hight trees now, hold them in storage where they can continue to grow, and then transport them to site as more mature trees than would otherwise have been. Infilling with whip and 3-5 year old trees. Giving instant impact and long term density. As part of the development of the Scheme, and in order to allow vegetation to establish and provide screening of the Scheme earlier, three categories of planting have been proposed: a. Advanced Mitigation Planting (planted 2022); b. Construction Day 1 Planting (planted at the beginning of construction); and c. Residual Mitigation Planting (planted at the end of construction). The specification of Ancillary development is very broad but is the issues that will have the most impact / value to the local community. 'Standards of service' need to be set that hold EDF to account on how things will be maintained going forward. As an example - road side verge cutting. Currently this is managed by local farm tennents. EDF by replacing htem should consider this as part of their 'whole site management plan'. If approval granted the EDF team should share with the local community a clear project management time line of activity and include geographical reference. This should be updated monthly and shared (paper and electronic) with the parish coucil ahead of each public meeting. What ever standards of best practice for construction and delivery are set now should be adhered to (as a minimum) for the second phase which is proposed 5 years after operation begins. With only 8 FT staff proposed once operational will the site hold sufficent equipment to complete and deliver thier maintenance responsiblities. How will this be managed to ensure the biodiversity and habitat enhancemets proposed are delivered. Decomissioning - It is expected extensive and accurate asset management records are kept. The location of burried cables needs to be maintained throughout the life of the project including the record of those that remain int he grown (over 1mdeep) on site cleareance. This should be shared both electronicaly and in paper version iwth the land owner. More ownership and responsibility is needed for the recycling of the decommissioned solar farm equipment. It is not acceptable to sit back and hope someone else comes up with a solution other than landfill. Is Polaris or EDF investing in a solutions programme for which this project should contribute a proportion of profits towards the research. Community ownership of the scheme, whilst this does encourage local interest and communication with those in the vicinity. It is an elitist scheme. To be part of the scheme requires households / individuals to financially purchase ‘shares’. Those on low incomes, with least disposable income have limited ability to join this scheme. Their voting power, and financial return will be the least. Unless a community ownership scheme has the ability to offer a fair access to the scheme for everyone, it should not be considered. Options could include - at no cost XX ‘share’ be given to every household within XX meter distance of the scheme boundary. The volume of shares given then decreases with distance. If a property crosses a meter boundary their allocation is based on where the residential property is situated plus a % increase by the volume of land within the greater meter buffer. For tenants and those with an interest in the village such as families with children at the school at the time of planning approval should also be awarded XX shares. After this the scheme can be opened up and anyone within this identified groups can then purchase additional shares. It can also be considered that anyone with the criteria on benefits can also be given an additional share. Basically the scheme needs be fair to all impacted and facilitate a way to allow all to participate. Section 111 - ECC request to focus funding to support displaced employees because of the scheme is valid. However the local primary school is the resource where investment will offer long term return to future communities of the area. For a 40 year project, after this initial interest within the planning process, there is no direct commitment to those who will be continually impacted by the presence of the scheme. The school is best place to support future generations and offer an enhanced learning facility and sensory support. Solutions could include the creation of a creative/ sensory area, disabled toilet/ changing area, as well as provide space for smaller group focused learning away from busy class rooms. These facilities offer space to support students with their sensory needs and offer enhanced facilities for the long term future. In practical terms this would be a new build provision located at the back of the school on the left hand side as you face the school from the road. Currently this area is occupied by a large storage unit. It is not accessed by the children so would not be a loss of play/ education space. The loss of open countryside and access to it should also be mitigated for with the provision of outdoor learning features within the school grounds. This should be developed in discussion with the school. Construction traffic – Large numbers of staff will be accessing the site. Whilst it is hard to enforce how individuals trave to work and the routes they take, every effort should be made to encourage active travel and car sharing. EDF should offer insetives to staff, contractors and supplier to facilitate this. Eg Structure the car park to have priority spaces etc. Proved an electric car charging point. Any company / pool cars should be electric. There should be a minimum of one electric/ hybrid of each type of construction vehicle on site all the way from wheelbarrow to JCB digger. All HGV’s accessing the site should be euro5 and above. No contractors, suppliers or deliveries to site can utilise the village of terling to reach the site. There should be restricted areas that are not necessary to use. When spotted traveling through the village and reported to the construction compound site manager (email and telephone number made available to all with links to terling) the offending company has a 5 strike policy and if reached will be fined first and if happens again will loose their contract. This applies to all size vehicles (car, van and truck). Measures to minimise the visual impact are welcome (reducing the height to 3 m and planting against the deer fencing to offer shielding). The issue is maintenance of this planting both that inside and outside of site fencing. Is there sufficient staff numbers planned to take on the ecological management and maintenance of the whole site. Permissive paths should be of a standard that families feel confident to cycle on them. By offering a new cycle network, there should also be cycle infrustructrue provided within the village. Cycle racks as an example. Located in an area where visitors are likely to congregate such as proximity to the pub/coffee shop. Signage too. When operational, within the solar farm Land management and grass clearance/ cutting should be dealt with through the use livestock."
Parish Councils
response has attachments
Terling and Fairstead Parish Council
"Terling and Fairstead Parish Council Longfield Solar Energy Farm (application no EN010118) Interested Party reference 20031557 The Parish Council (PC) has attended presentations/webinars during the pre-application and application stages. It has considered newsletters, both soft and hardcopy documents deposited. Its Councillors have walked the perimeter of the proposals and its footpaths, with many residents. It has encouraged the community to make their separate representations as an Interested Party to HMPI. The PC will seek to make further and specific commentary during the examination by HMPI. Text of submission to HMPI: The PC refers to its submission of 23/11/21 at the statutory pre-application consultation (26-10/21-27/11/21), included in the DCO submission. A copy of this document is at the end of this submission. The Secretary of State originally called for sites in single ownership to support solar farms of over 50 MW. It is clear now there will be additional land acquired to deliver this scheme “at scale”. The DCO extends to Cranham Road connecting to the Chelmsford NE bypass. The last Longfield newsletter plan did not show this, their preferred access route. It is unclear if the acquisition of necessary land will be in advance of any physical works on the Longfield scheme. Longfield is very large, the associated BESS of a scale proportionally larger; its impact/massing in this rural/agricultural location, even with the mitigations suggested, do little to ameliorate long-term land industrialisation for future generations. The PC is not convinced by Longfield’s proposals; a single scheme at scale is both relevant and contributes to the national energy requirement, and questions the suggested efficiency of solar farms and the proportionate loss of high yield food producing land. The EIA is evasive concerning the removal of topsoil (at construction phase) suggesting any re-instatement for agricultural use requires robust conditions in any DCO consent. The economic model charging the BESS from solar (daytime) then night-time alternatives has been glossed over. This is the main economic driver for the quantum and scale of the BESS - Longfield should evidence this. The PC intends to challenge the battery technology and Essex Fire and Rescue responses as to future community risk, which it believes to be significant. Alternative sites which may have been considered are dismissed as those that “may come forward in addition to Longfield in due course”, one is already in the control of EDF (Bradwell). The PC will challenge this view at examination. The proposal includes several Chelmsford City Council/Braintree District Council designated and adopted ‘protected lanes’. The PC is extremely concerned about the negative effect on landscape/visual amenity in this attractive part of Essex for its community, and Chelmsford’s expanding population. The construction/de-construction impacts the community’s amenity significantly. Longfield advise 600 personnel at times with associated vehicle movements. Will there be a construction camp and hours of work conditioned as Monday to Friday 0730-1700, Saturday 0730-1300 with no work on Sundays? The PC is still to be convinced of the carbon factors stated in the manufacture, construction, operation and decommissioning of the scheme as well as the negative carbon footprint of any associated activity. The PC notes that no permanent legacy community assets are included within the proposals. The PC has concerns on the applicant’s financial status. The PC requests the re-instatement of land to agricultural use be conditioned by a performance bond. The PC has two other DCOs (pre-statutory consultation stage); A12 widening and National Grid East Anglia Green and the proposed Chelmsford Garden Village is close to the site. The PC seeks evidence of collaborative approaches to programming these significant impacts within the Parish. The cumulative effect of the Longfield proposals and all other solar schemes will affect the UK's food security. The local landscape will suffer and the PC recommends this DCO should not be granted. In summary, the PC’s combined community view is the scheme is too large and in the wrong place. END OF SUBMISSION TEXT – TO FOLLOW – LETTER TO PLANNING INSPECTORATE 23RD NOVEMBER 2021 Longfield Solar Farm; Development Consent Order - Additional Statutory pre-application consultation 26 October 2021 to 23 November 2021 under section 42 of Planning Act 2008 Please find set out below Terling and Fairstead Parish Council’s response to Longfield Solar Farm’s letter of 25 October 2021 addressed to the Clerk. Terling and Fairstead Parish Council (The Council) is a statutory consultee. General update The Council’s Planning Committee held a public meeting on 10 November 2021 and invited all parishioners via its website and village hub to respond to both the above letter and Newsletter via the Clerk of the Council. The Council’s formal response now includes those expressed opinions of the wider community. The Council is aware of two major infrastructure schemes that will affect and impact the subject application proposals namely:- A12 widening proposals being advanced by a DCO application by National Highways and presently before the Planning Inspectorate, which may now be registered. Chelmsford NE bypass being advanced by Essex Highways (ref cc/Chl/85/21) to Essex County Council. The Council is concerned by the apparent lack of reported public engagement to demonstrate joined-up thinking between these separate applications and the Longfield team, with its consequent effects on the loss of amenity and enjoyment to the lives of our parishioners. The Council is aware that National Highways is commencing a further series of public consultations on its proposals to widen the A12. The Council will be making representations to National Highways regarding the need for a joined-up approach for these proposals, to allay its concerns and encourage a comprehensive and inclusive approach to these major infrastructure schemes. The stated construction programmes for the separate schemes appear to have become combined and will seriously impact on many residents and parishioners, especially to the west of the community. Communication The Council is concerned to note that Longfield’s Newsletter of 25 October 2021 had not been received by many members of the Terling community. Indeed, if it had not been for the Council’s monitoring of the Longfield website, the wider community would have remained in ignorance of the additional consultation. The Council will be bringing this lack and lapse of the statutory consultation process to the attention of the Planning Inspectorate. Please note the reference on the Longfield website to locate the October Newsletter was confusing. Longfield has demonstrated no effort to garner wider publicity with posters or leaflet drops to publicise and inform parishioners of the proposed changes prior to the time of writing, which is disappointing. Should further consultation and Newsletters be produced by the Longfield team, we would request and encourage a more inclusive consultation process. Infrastructure proposals, access and traffic management The Council notes that there are significant changes to access now proposed. They are convenient to Longfield’s commercial aspirations and not the wider community. The Council will, in due course, comment on the suitability of the enlarged scheme in this location, and the defective rationale for this site’s selection. We will also be analysing suggested alternative site appraisals for comparison, with less impact to the continued quiet enjoyment of the wider Terling community and combined detrimental effect on our environment and continued wellbeing. We shall continue to question the loss of c 1172 acres of land capable of food production. The proposed revision to the DCO application boundary now includes Wheelers Hill and Cranham Road but only to the extreme width of the carriageway and footpath as may be extended. There is no supporting data supplied, and certainly the Longfield communication of 25 October 2021 does not include reference to any residential properties that continued amenity is set to be impacted by this proposed revision. Is it the intention that these changes to the roads will be permanent or will Longfield reinstate to present configurations on operation of the Longfield facility? The revision to this application is silent in relation to Drakes Lane, which the Council suggests is set to become an alternative route of access to the western approaches to the Terling settlement, via Birds Farm Lane and Noakes Farm Lane (which combine to Waltham Road). The Chelmsford NE bypass planning application [direct to Essex County Council (ECC)], does not appear to take into consideration in section 1B of that application, the revisions now proposed by Longfield for Cranham Road and Drakes Lane. The Council has made representations to ECC drawing attention to this apparent disconnect in comprehensive data provision. Battery Storage The Council is now aware the proposed enlarged battery storage facility at Bulls Lodge substation is now being advanced as the preferred location. We continue to seek further information as to the safety of the proposed technology for battery storage, conversion (DC to AC and AC to DC). It appears the storage facility is now even closer to the A12 (which will be 6 lanes when widened). The battery storage is also closer to Boreham village. The Council is increasingly concerned as to the size and installation of more battery technology and the explosion risk from such a concentration of battery enclosures. The Council is very uncomfortable about the robustness of the responses to its enquiries to the Fire Authorities and the Longfield team. Additional Solar Farms within 8 kms of the Longfield site The Council has been monitoring the proposed solar farm and battery storage scheme at Links Farm to the south of Braintree (BDC ref 21/01878, 9 June 2021). This is c163acres and stated to be capable of producing 35Mw and is pending consideration by Braintree District Council at the time of writing. Observation has been made that if c163 acres of land at Links farm is stated as producing 35Mw of generated power, why is the Longfield site (as now enlarged and re-stated as being c1172 acres) only capable of producing 50Mw? Concluding comments To say changes in the revised proposal and this additional statutory consultation are consequent as mere “refinements” to the new Longfield proposal, is disingenuous. Stating that the further consultation is … “purely changes to the scheme boundary in order to allow for our preferred grid connection route.” and ”these changes will not affect the outcomes of the PEIA set out in the PEIR…”, the Council contends is Longfield seeking to mitigate previous scheme errors in its initial round of public consultation resulting in the earlier DCO submission. The Council now questions the deliverability of the wider and much enlarged Longfield scheme. Parishioners have commented that when the Secretary of State first approached the wider UK market seeking site proposals for a 50Mw solar farms and battery storage installations, it was clearly stated the sites proposed should already be in a single ownership or controlled by the respondents, evidently from the information supplied in the Longfield October letter this is not now the case. There is no confirmation the additional land has been acquired or rights acquired to deliver the Longfield proposal as has now become enlarged. There is commentary that the necessary land has to be so controlled (perhaps by compulsory purchase) but it appears there is no certainty given as to programme or agreement. Additionally, the existing HV pylons and distribution infrastructure is already in excess of 60 years old, and the expected life cycle of the existing pylons suggests replacement during the expected period of operation of the Longfield installation; should, even now, an underground network of cables to future proof the facility, be advanced for public consultation? The proposed revisions to the western access routes, the siting of the enlarged battery store closer to the A12 and the village of Boreham, require further justification and evidence to both the PEIA and PEIR (as these may require), to be updated and available for wider community comment. Only when such reassessments and revised risks analysis, as appraised by the Longfield team, may be considered by this Council, can the next stage of the DCO application process be permitted to advance. TERLING AND FAIRSTEAD PARISH COUNCIL"
Members of the Public/Businesses
Terling CE Primary School
"Terling Church of England Primary School has served the community of Terling and the surrounding area since 1853. It currently has a roll of 104 pupils who will all be impacted by the Longfield Solar Farm project in many ways, including: Significant changes to the local environment and biodiversity Significant changes to the landscape and amenity around them Reduced access to outside space Construction traffic to and from the site Reduced future employment for their families and themselves Potential impact of the fear from local discussions regarding the safety of the site including battery storage facilities Potential noise impact during the construction process and also when the facility is running Previous plans for the site included an education space to provide a facility for children to learn about the project. This has been removed from the plans but is an important part of our children’s education if they are to learn from such a development. The school could provide this space but is not currently in a position to do so. We therefore request a capital investment for the school to provide this facility. The school providing this area would be better placed and we have external buildings which could be developed to provide this space. It would also be a benefit to the school to be able to use this educational space for other activities to include break out, storage and an outside educational provision. Learning about the outside space is fundamentally important, particularly following the recent pandemic. Children struggle to be outside and play accordingly as they missed to much interaction with their peers and the outside world. Having an outside learning provision to learn about the Longfield development, the biodiversity and the environment but also that break out space, separate to the main school buildings, will be of huge worth to the children’s mental health and education. \r\nWe would welcome the facility to be open to other educational establishments and the public for educational need."
Members of the Public/Businesses
Pauline Leigh-Collyer
"It is shameful that prime agricultural land is going to be used for solar panels where there appears to be no real efforts on the part of the developers to source a comparable sized area of poor agricultural land. Tenuous and misleading data in the planning application regarding quality of land and very biased impact assessments which do not reflect the views of the local community. Solar panels are far from the most efficient modality for green energy and indeed leave their own very prominent carbon footprint and green house emissions. Solar panels are already proving to be the very poor relation amongst the innovative and successful methods for sustainability for the future. This direction is a worrying trend and should at least be slowed rather than progressing with what will be the largest site in the UK. Huge concern about related batteries and risk of fire and even explosions as happened in Liverpool. Huge impact on the wildlife and bird population and negative impact on local ecosystems. Eye sore to an idyllic landscape that will never be reversed. This open green space is part of the treasured Essex Way and is used and appreciated by so many. Huge impact on local residents and visitors negatively effecting on their wellbeing. Noise factors and construction issues in a very rural setting along a very winding country road which is valued hugely by locals for access."
Members of the Public/Businesses
William George Kyle
"The proposal uses too much good quality agricultural land; the proposed site is too large and would overwhelm the surrounding area; the site traffic is both too numerous and large for the Main Road in Boreham and also for Waltham Road; the battery installation is too near to Toppinhoehall Wood; and the sub-station should be on the site"
Members of the Public/Businesses
Edward Hugo Baldock
"Issue: A Date: 26.05.22 Author: EHB Relevant Representation Concerning Longfield Solar Farm Development Consent Order Application EN010118 System Need It is a physical fact of nature that solar radiation is at its maximum in summer while our national need for electricity is at its maximum in winter. This disparity is very strong; the output of PV systems varies by a factor of about 7 as between its peak in summer and its trough in winter; the nation’s present electricity usage (on a quarterly basis) is about 20% lower in Q2, Q3 than it is in Q1,Q4 and this variation must be significantly greater on a monthly/weekly basis. The plans for a space-heating transition from natural gas to electric-powered heat pumps will further (and drastically) accentuate the demand disparity. Wind (and thus wind-derived electricity) on the other hand, peaks in the winter when our needs are, and will be, greatest. Thus, in the absence of a choice to use electrolysers to produce and store the PV-derived energy as hydrogen in summer for use in the winter it is, on a national consideration basis, simply foolish to divert limited investment capital away from wind turbines towards large-scale PV systems. On this basis of grossly inefficient comparative use of national resources (further aggravated by the loss of BMV farmland), this Application should be rejected. Energy Storage System The BESS is, potentially, very, very dangerous; it could choose to self-destruct, as a significant number already have so done. It would also represent a useful target for a terrorist or an enemy. The proposed BESS is very large, perhaps the largest yet constructed. For reference, this 1600MWhr battery is equivalent to ~ 5,760,000 sticks of dynamite or ~1.38 kilotons of TNT. Thus, it contains the energy-equivalent of a smallish tactical nuclear weapon when fully charged. The energy at issue is somewhat larger than (about twice) that released in the 2020 Beirut explosion. Please consider these facts should the Examination choose to determine this aspect of the Application. The BESS aspect of the project is outside the definition of a Nationally Significant Infrastructure Project and is thus arguably outwith the allocated competence of this Examining Authority to determine; please decline to determine whether the BESS should proceed or not, and hand it off to the appropriate competent authority for separate determination. Site Selection - Alternatives The Applicant is required to provide evidence for the reasons why he has selected the Application Site in preference to other potential sites; he claims that he has done this, but is maintaining the process and results as a private secret. Please require the Applicant to reveal to the Examination all the alternative sites that he considered and the exact evaluations he applied whereby they were discounted. In particular, please require him to reveal the sites that he rejected that were not on Best and Most Valuable land. Site Selection – Best and Most Valuable Land The Government has stated a very strong preference that BMV land should not be used for large-scale Solar projects. The great majority of the Application Site was, prior to its choice for this Application, Grade 2 or better (i.e. it was BMV land). Because of this site deficiency the Applicant has employed an agent to justify the reduction of a significant part of its area to Grade to 3b (i.e. just outside the BMV category). It is inconceivable that, were the Site Owner to have been selling the land to another for farming purposes, he would have found such evidence to justify this downgrading; please treat this downgrading with great caution and Examine it very, very, very thoroughly. Please disallow all land that is BMV, or has been invalidly downgraded to be not BMV, from use in this, or any, Solar project. Noise The Applicant has stated in his Application an ability/intention to ameliorate the operational noise emanating from individual pieces of equipment by a stated number of decibels [dBs]. This is a completely wrong and invalid approach to the issue. Please require the Applicant to commit to achieving an absolute noise level compared to the established ambient noise measured prior to the implementation of the project; this will require that each piece of equipment be subject to a variable number of dBs of amelioration dependent upon its individual noise source level. The noise level permitted at individual receptors (dwellings) is set out as a British Standard; please require that, as a minimum, this standard be applied. Compensation There are a number of domestic properties that, in the event that the Project is permitted to proceed, and due their location very close to the boundaries of the Application Site, will unquestionably directly suffer the misfortune of a significant downgrading in their ambient environment both during the construction phase and during the operational phase. The electrical power produced from the Application Site will be at a fixed and low cost; the part of the National Grid utilised in its distribution to these properties will be very small. Thus, it would be possible and reasonable to supply those properties that particularly deserve some compensation with their electrical power at cost-price per kWhr for the Application Site and at a reduced Standing Charge from that derived by consideration of more remote production facilities that require more use of the National Grid’s distribution function. Please place a Condition upon the Applicant that it shall provide electrical power to the affected properties at the Site’s cost-of-production and cost-of-distribution rates for the whole period of the Site’s operation. N.B. that the power that my property provides to the National Grid from my domestic PV system is currently deemed to be worth 4.25p/kWhr whereas power delivered to my property from the National Grid is deemed to be worth 30.799p/kWhr. It must surely be the case that power from a commercial-scale PV system will be produced at a cost less than from my domestic system."
Members of the Public/Businesses
Heather Diane Cutler
"Very worried about the permanent loss of good agricultural land at a time when the loss of Ukraine wheat has demonstrated once again the need to produce as much as possible at home. Very worried about the fire risks and total lack of fire and water emergency response plans regarding the large number of batteries for stored power."
Members of the Public/Businesses
Mrs Marianne Golledge
"TOO BIG. WRONG LOCATION. VANDALISM OF COUNTRYSIDE. The short sightedness of Longfield Solar Farm and other similar schemes is breath taking. The main reason they chose this site/location was through laziness and to save money because it had one owner to deal with and location. This is not enough of a reason to scar the landscape, blight homes, upset local wildlife flora fauna systems and finally and possibly most importantly use Grade 1 farm land so urgently needed in the next 20 years. (Am I right in thinking they have managed to downgrade some of the land to Grade 2/3 but I bet if they were selling it would suddenly be Grade 1 again) This smacks of BIG industry taking the shortest, cheapest and least work route. Solar should be on all NEW BUILD housing (Chelmsford Garden Village), INDUSTRIAL rooves, BROWN field sites. Anywhere but this type of location It should be made easier by these companies pushing these solar farms to encourage their current customers to have solar on their rooves and any land they may have. EDF are not interested whatsoever about the area they build these so called green solar farms in, nor it appears is the landowner. The future is NOT solar this is Big Business making a quick buck with the usual knee-jerk reaction and latest fad. The future is hydrogen or local fusion systems This site is no different to other sites that have been refused planning. It is a massive mistake to cover this valuable arable land in so called green solar panels. Once built it will be highly unlikely to be arable land again. With the Chelmsford Garden Village being considered just across the fields from this Longfield site there will be over 3,500 acres of Essex countryside taken up with eyesore pointless structures that could be put elsewhere with some thought and consideration for the those who live in the area. The high fences surrounding the solar panels will divert wildlife totally disrupting there routes and feeding grounds. Many other local wildlife may get caught in the fences. This may sound petty to such big businesses but it affects the local area and those that live next to these 'dirty green' farms This 'dirty green' solar farm may not be in the field next to me but it is to my fellow villagers and I would be heartbroken to see my local fields covered by these ugly 'dirty green' temporary monstrosities that could be placed nearer the demand and out of sight on rooves. How the landowner can see his valuable agricultural land used in this way shows they don't care for the community they live in any way and it is a short-sighted money making scheme that will benefit only their pockets and be detrimental to the village. Making financial contributions to the village will only help a few not the whole area and hardly improves the area in any way that the solar farm ruins and vandalises the area. Why is the Badger survey not public. The badgers around here are getting less and less over the years and they have not been encouraged by local landowners as far as can be seen. Sadly unless it makes money they don't care, same as the absentee energy companies.\r\nThe wildlife displaced by all these schemes along with the widening of the A12 and the potential high pylons coming across the same local area will be catastrophic. A very short sighted view on getting power to this land at the enormous loss of high yielding agricultural land. Once its gone its gone. One question that concerns me greatly is where these panels will be coming from and are the sources for the materials, are they green and compliant with UK standards or are materials coming from countries with very poor human rights and little concern for the local environments. Are you promoting UK manufacturing or importing? These panels should be green from start to finish and fully recyclable. At least if you do get permission and after you have decimated the local area there may be some green environmental saving to be made. The whole scheme smacks of 'Green Washing' in other words the solar farm is claiming its green but the building and construction is so ungreen it cancels out the benefits of the solar energy. Hence dirty green power as the panels are inefficient in the UK climate, great in a desert but not Essex or Uk in general at the expense of prime agricultural land. I bet any desert location would give their right arm to have the fertile soil we have in Essex. What happens to old panels and batteries? Where do the materials come from and the mining for some of the precious materials used, is it clean and green????? China and its human rights issues are they being thought of as should any of the components come from here they should be excluded. Change the system so individual home owners can sell power to the grid and therefore Power companies no longer need to build eyesore farms on valuable farming land. Huge question over the safety of the storage units and their proximity to the local community and the potential eyesore and blot on the landscape that might be built nearby Chelmsford Garden Village. At the moment Longfield are only considering the present locals not 5000 new neighbours!!!!!! The government first published it’s Solar PV roadmap and strategy in 2013, setting out the guiding principles for deployment of solar within the UK. Within it, they stated developers should ensure proposals are appropriately sited and give proper weight to environmental considerations such as landscape and visual impact, heritage and local amenity. We believe the site is inappropriately sited when considering this criteria. Where else have you considered for this scheme? Can Essex afford to loose even more valuable land to an unwanted solar farm that will mount up the amount of acres being taken up with new builds such a Chelmsford Garden Community Between Little Waltham, Chelmsford, Boreham and Hatfield Peverel there is 3500 acres of prime Essex countryside being lost to new build and a solar farm, along with the widening of the A12 and the potential high pylons coming across the same local area, the harm to wildlife displaced by all these schemes will be catastrophic. Its prime agricultural land needed to grow crops Solar can go else where New Builds (Roof tops of the Garden village is the most obvious) can also be more innovatively created and do we really need quite so many houses or is it just hype just as this solar farm can be put else where its just cheaper and easier for the companies to bung it in the countryside where the cities and towns don't have to think about it???? WRONG LOCATION. WRONG SIZE. WRONG TIME."
Members of the Public/Businesses
William Harvey
"OBJECTION TO LONGFIELD SOLAR FARM DEVELOPMENT 1. AGRICULTURAL LAND LOSS National Planning Policy Framework makes the protection of BMV land a priority, this is even more important as we move closer to food poverty with in the UK.Developers should be using areas of poorer agricultural land and not BMV as all the land proposed in this development was first recorded as being. Developers need to show they have searched for sites that are of low agricultural value and explain why these are not suitable. 1.2 The context of land loss is its effect on food security.The cumulative loss from the Longfield proposal and all the other NSIPs, and smaller schemes going through LPAs, will result in the loss of thousands of acres of food producing land. The result will be more food imports at greater cost and with more uncertainty regarding food availability. 1.3 It is suggested the Longfield development will see the first 12 inches of top soil removed across the total area proposed, if this is true then this land will never return to agricultural land again. 1.4 On the original ALC maps the whole site was Grade 2 and therefore BMV, my understanding is that is has now changed as lower grade soil has been, however within the area marked as lower grade there is still a large area of BMV land that can be used, this is very misleading. 1.5 Alternative sites, Longfield state that using land classification maps shows no prevalence of higher-grade land in the vicinity of the scheme. The maps used in the documentation also show that the scheme is all on Grade 2 land and most of the land to the south and south-west is Grade 3 (the bulk of which is Grade 3b). On page 79, the map provided indicates there is ample low-grade land within the vicinity of 400Kw NETS power line 1.6 Removal of BMV land from proposals (para 6.7.30, pages 84 & 85) explains why 6 BMV land areas remain within the proposal in detail, this is not a good enough reason for including BMV land in the scheme 1.7 Conclusions, based on all the facts in paras 1.1 and 1.6 above, it is reasonable to regard the whole of the site as productive agricultural land and on this basis all planning approval should be refused, even more so when the UK is heading in to food poverty. It is quite clear that the Longfield developers have made no serious attempt to look for or consider alternative sites as with in the county of Essex there is over 30,000 ha of poorer grade land providing more than enough space to develop this solar farm development. If this low grade land is to be ignored by Longfield then the very least BMV land should be removed from this proposals. 2. BIODIVERSITY AND LONGFIELD SOLAR FARM 2.1 Introduction to BNG Maintaining and increasing biodiversity is regarded as a critical factor in managing the stability of the planet. To this end, the 2021 Environment Bill mandates most new development will deliver an overall gain in biodiversity. This is called ‘biodiversity net gain ‘(BNG) or sometimes ‘net biodiversity gain’ (NPG). This is therefore an important aspect for all local planning authorities to consider in approving or rejecting planning proposals and, in particular, solar farms. The law does not apply to NSIPs (Nationally Significant Infrastructure Projects). Nevertheless, developers may wish to show their NSIP proposals do deliver BNG. 2.2 Measurement of BNG Biodiversity was originally measured by using Biodiversity Metric 2.0 (JPO 29) Natural England 007.2019; this has now been superseded by Biometric 3 (JPO 39) Natural England 07.2021. JPO 39 was used in the Longfield BNG report. 2.3 Commentary on BNG Ecologists in the UK generally regard the metric as not fit for purpose. Prof. K. Willis a leading ecologist from Oxford University said in 2021 that the BNG total “will promote further loss and fragmentation of some of the UK’s natural environment and even more important the ecosystem services that flow. She concludes that “net biodiversity gain will end up being net biodiversity loss”. 2.4 Biodiversity impact on solar farms, In 2019 a survey by BSG Ecology stated “evidence of solar farms impact on biodiversity remains limited… there is little empirical data on the subject”. Natural England recommends the avoidance of solar developments in or near to areas of high ecological value. In the same report it was stated that “the lack of evidence available relating to the ecological impact of solar farms is concerning”. Longfield documents (para 4.6.1) claim a BNG of 79%. This is not a figure that can be justified. 2.5 BNG Trading Rules “The proposed development results in a loss of 6.35 units of high distinctiveness – lowland mixed woodland, and the provision of lower distinctiveness woodland to compensate for the loss of habitat is contrary to published net gain trading rules”. In addition, the report states that “Trading rules are not met for mixed scrub and pond habitats.” Overall, the conclusion must be there is a possible damage to biodiversity and the BNG is not valid and does not follow the trading rules as set out in JPO 39. 2.6 Ecological Survey details 2.6.1 Badger Survey – this report is confidential and so comments cannot be provided. 2.6.2 Reptiles – “The ecological data is only valid for short periods due to the transient nature of the subject. A survey in 2022 is recommended.” This is not currently available. 2.6.3 Birds (para 6.1.1). “The scheme has the potential to result in the direct loss of habitat needs by protected and notable bird species.” There is a recommendation that a significant number of extra surveys are required. Wintering bird surveys are needed in 2022/23. 2.6.4 Breeding Bird Surveys – “The construction of the scheme in the absence of avoidance or mitigation has the potential to affect the breeding bird assemblage within the site boundary. These potential effects include;\r\n- habitat loss and fragmentation - displacement and/or loss of breeding populations - increase in noise causing disturbance and visual distortions”.\r\nNoted that loss of arable farmland will have an impact on the birds it supports such as Golden Plover, Skylark, Lapwing, Yellowhammer and Linnet. The loss of game cover will impact flocks of seed-eating passerines, Linnet and Yellowhammer. 2.6.5 Great Crested Newt (para 7.1.4). Noted that the Great Crested Newt terrestrial habitat may be directly affected on a temporary and permanent basis by the scheme. 2.6.6 Flora. Flora surveys are critical in any ecological survey as they represent baseline trophic levels. Surveys were carried out in 2020 and the document notes not all habitats were surveyed (para 3.4.4). Also noted that surveys are normally only valid for 18 months to 2 years. Noted there will be major construction impacts on the flora from noise, dust and lights. There will be habitat loss and change. “Overall, there will be loss of some improved grassland and important arable plant assemblages”. 2.6.7 Additional comments, the consultation brochure identifies 1 SSSI near the site and 31 non statutory sites within 2km. There is reference to an OLEMP (on-line Landscape & Ecology Management Plan). This could be an important document but is not available for comment. 2.6.8 Biodiversity Conclusions It is clear there will be mitigation and enhancement proposals in the Longfield Solar Farm; these are to be welcomed. If the mitigation and enhancement were to be applied in an agricultural context, as they could be in the government’s Environmental Land Management (ELM) scheme, then the biodiversity gains could be greater. It is clear from all the reports that more work is needed on ecology and biodiversity. The existing site is of significant value with its woodland areas, ponds, proximity of valuable sites and the range of species identified in the surveys. There is a probable negative impact on biodiversity and more ecological study is needed. It would be premature to give approval for large scale solar schemes such as Longfield Solar Farm proposals as after a few years considerable ecological damage could be achieved that would be difficult to correct. Current advice from organisations such as Natural England is to site solar farms away from areas of value. The Longfield Solar Farm site would be classed as an area of value. The BNG assessment of 79% cannot be justified, (para 7.3 Statement of Reasons quotes 79% BNG as a public benefit). 3. LANDSCAPE\r\nLongfield Solar Farm will have a major impact on the landscape and a visual impact on what is a beautiful part of the Essex countryside. This is identified in the consultation booklet p.21 “We have identified potential impacts on views into the site from a number of points during the construction, operational and decommissioning phases.” Specified points to note regarding landscape are: 3.1 Para 6.5.4 acknowledges the fact that the scale and speed required to meet the current and future need identified is likely to have some negative effects on the landscape and visual amenity which may not be able to be mitigated. 3.2 Landscape Visual Amenity – para 10.8.18 notes medium sensitivity and medium magnitude effect (in construction) with moderate adverse to significant effect. Para 10.8.39 – the scheme would result in the loss of some key characteristics, namely the agricultural character and reduction in the sense of openness given the change of land use. Para 10.8.59 notes – People walking the Essex Way would experience moderate adverse effects. These effects are considered to be significant. Para 10.9.2 - It would not be possible to mitigate every adverse effect due to requirements of the solar generation. Table 10.7 indicates the residual effects after mitigation – a number of which are described as major adverse and significant (namely White Oaks which will surrounded at every outlook). 3.3 Mitigation effects Para 10.8.62 states that by year 15 the proposed planting would have established and would be in leaf and reduce the perception of the new infrastructure. Para 10.8.5 refers to advance mitigation planting, stating this would have significant effects by year 4 3.4 Overall Landscape Conclusions Landscape and visual impact will be very significant. Mitigation will have little impact since trees and hedgerows that will be planted to try and limit the adverse impacts will have little effect through the early part of the scheme (namely 15 years). 4. NOISE\r\nChapter 11 of the Environmental Statement – Noise & Vibration 4.1 Chapter 11 is prepared by AECOM. 4.2 There are a number of NPPF, NPS, EN3 and EN1 guidelines NPPF state “proposals should demonstrate they mitigate impacts such as noise”, “prevent new developments from contributing to or adversely affected by unacceptable levels of noise pollution”, “identify and protect landscape areas which have remained undisturbed by noise”. 4.3 Noise levels are considered to have a medium impact at 70-75 dM and a high impact at 75dM. 4.4 The ES splits the site into R numbers. The properties most affected by the noise are near Boreham on the Waltham Road. Six sites are identified as having moderate to adverse noise early morning and night. R27 is White House and is given a medium rating of 40dM (LAr) night time and early morning. 4.5 The ES appears to undervalue the noise factors. In the construction phase mitigation appears to be primarily by informing those most affected by the noise when this will happen. Noise and vibration will come from inverters, transformers and switch gear. This is an adverse effect of the scheme. 4.6 Taking all the above in to account how detrimental will this noise pollution be to the “Mental Health” of the residents of Terling and the surrounding area having this work taking place six days a week, Monday to Friday 12 hours a day 00.70am to 19.00pm. 5. OTHER SIGNIFICANT CONCERNS 5.1 Construction Traffic Para 11.5.27 Chapter 11 ES During construction daily there will be a large number of HGVs on the strategic road network of which 50 HGVs would be on the local highway network via Wheelers Hill, Waltham Road and Cranham Road. 5.2 Planning Statement 7.2 Noted that National Highways has yet to submit for a DCO, when can this document be viewed and commented on as it not yet available. 5.3 Planning Statement 3.3 In the construction period there will be over 600 workers and the construction will be from 7 a.m. to 7 p.m. on Monday-Sunday, how will impact on the metal health of the people of Terling and the surrounding areas? 5.4 Statement of Reasons 4.1 Compulsory Acquisition Powers. These are requested as it has not been possible to obtain all interests by agreement. Para 1.7.1 accepts this might infringe human rights. It is quite clear the construction phase will be very disruptive to local residents. 6. BATTERY SAFETY 6.1 Outline Battery Supply Management Plan. This is an outline plan and the detail is to follow. However, there are significant risks of fire and explosion from thermal runaway from Lithium-ion batteries. The storage for the Longfield site will be one of the largest in the country. It is clear the developer is aware of fire risks but it is difficult to comment on outline plans. It seems dangerous for a DCO to be given until such time as fire risks are adequately assessed and fully published. 6.1.1 In Summary – Liverpool report The explosion at the BESS facility at Carnegie Road, Liverpool was a result of a failure within one of the battery racks in one container which led to a thermal runaway which in turn produced gases within the container culminating in a large explosion with parts of the container being blown across the compound to a distance of 23m.The main fire took 6 hours to bring under control but the continual recycling of heat from the Li-ion batteries remained an issue and defensive fire-fighting continued on-site for a total of 59 hours. The fire and explosion were deemed to have been caused by the failure of one or more battery units, but the root cause of the battery failure remains unknown. The Liverpool site had only 3 BESS containers (Longfield is multiple enclosures). A fire suppression system had been fitted. The report stated there was a significant risk to emergency responders. Battery safety is a serious planning consideration for the Longfield submission, this is why a full “fire risk assessment” is required and should be published prior to any planning permission being granted. STATEMENT OF NEED 7.1 This statement, along with many other paragraphs in the documentation, justifies the Longfield proposals as a contribution to decarbonising the energy sector to meet net zero targets. The scheme is described as the deployment of zero-carbon electricity at scale. 7.2 It needs to be understood that solar farms are relatively inefficient. In terms of the amount of power exported to the grid Solar's rating is about 15% efficiency whereas for off-shore wind the figure is 50%+ efficiency. 7.3 Solar farms are not carbon-neutral. Research by scientists at Cranfield University has shown that Green House Gas emissions are relatively high (GHG). This is particularly during the construction phase. The probable output is 6.87 gas CO2 per KWhr. Most schemes ignore upstream processes, PV panel manufacture, BESS cables and cabling. The Energy Security Strategy (April 2022) concentrates on offshore wind and nuclear. No targets are set for solar. The strategy states it will ensure environmental protection for ground mounted solar and large-scale solar projects will be encouraged to locate on previously developed or lower value land. The strategy encourages roof-top solar and will simplify planning for this. All the above implies the Longfield proposals should not be granted a DCO on the basis they are not Carbon neutral, are relatively inefficient and do not accord with the government strategy as set out in the recent energy security strategy namely that large schemes should be sited on lower value land"
Members of the Public/Businesses
Brian William Newland
"The location of the proposed Longfield Solar Farm in Chelmsford is mostly on very valuable Grade 2 Agricultural Land. It is therefore a poorer use of this land and should be refused permission."
Members of the Public/Businesses
Charles Henry Martin
"Dear Sirs, I would like to register as a person of interest in the planning process. My comments on the Longfield Solar farm proposal have previously been submitted to the developer during their consultation process but I reiterate them below:- 1.The land area of the site is vast and it only generates 500 MW. This compared to older thermal power stations of 4x500MW. Using very little land. Considering the land take, can the output be increased by better panel technology. Can the solar panels be designed and fabricated in the UK rather than importing the units from Europe as is proposed. We are very good at design in this country especially in Chelmsford where we have a history of high-tech industry. Surely better units can be designed and fabricated in the UK thus either increasing the output from the farm or reducing the land take. 2. The battery storage units should not be located anywhere near Boreham Village as in the original proposal. I note that they have been relocated on plan to adjacent to Toppinghoe Wood, this is an historic woodland and not a suitable location due to intrusiveness, possible explosions/fire and risk to wildlife. 3. All cable routes should be underground and any grid connections must be away from Boreham Village. This should not present a problem as the National Grid power lines pass through the site and connections can be made anywhere along their length within the site. The latest proposal I note is to make the connection at the Bulls Lodge substation which means laying cables some distance from the farm to the substation unnecessarily affecting land along this route. 4. As the land is under one family ownership this is very convenient for the developer. Presumably all the preliminary lease negotiations have been concluded prior to this proposal being tabled to the public. I find this “tail wagging the dog”. There is much lower quality land in Essex and those landowners would be interested in being part of a solar project. For instance there are many relatively small field plots alongside the A130 between the A12 and A127 which are not so commercially viable for agricultural farming as they were severed by the construction of the A130 scheme a few years ago. With the correct willingness to proceed, these plots could be assembled into a viable solar farm project with less environmental impact on the surrounding countryside which is already impacted by the A130 Strategic Route. 5. I would strongly resist any such farm in the local parishes. However if one were to proceed, then greater public access to this land area could be included within the scheme. By this I mean more/improved Public Rights of Way and better access to them from Boreham Village. The A12 when it was constructed in the 1960s was an environmental disaster with very little thought given to accessing the north side of the A12. If the old bridge that now only crosses the railway line opposite Damases lane could be continued for pedestrians to link up with the B1137 Main Road from the north side of the A12 this would help. Perhaps some public car parking to enable more convenient access to the local footpaths. 6. I suspect the local employment would be minimal in the finished project as there is little to do to maintain electricity generation by this form. However there is potential to recruit locally for various skill sets as Chelmsford is renowned for its high-tech industries and also the development of the necessary specialist skills from the local labour market would be welcome. 7. As this project has a 40 year lifetime, it will long outlive me but as a back note to the local area, Boreham has been promised local facility improvements in the past resulting from the restoration of the gravel workings to the west of the proposed site. Namely water parks and general public open space. This has amounted to nothing in the 25 years the gravel has been extracted. I sincerely hope that the Longfield site will deliver a more usable area for the public both during the farm’s lifetime and also the restoration of the site. You should also be aware that Boreham is renowned for prolonged power cuts and these should be resolved before commencing work, possibly by contributing some funding to this end. National Grid/Power Networks do not seem to have the funding or any interest in resolving these long-standing problems. 8. I am a net supporter of renewable energy but I feel that this site is not suitable. The land is good quality agricultural land and Boreham has had its fair share of large-scale developments on its doorstep and this is one project too far."
Local Authorities
response has attachments
Chelmsford City Council
"Please see attached."
Members of the Public/Businesses
Edward Bennett
"Longfield is proposed as one of the UK’s largest solar developments, covering 450ha of countryside. The detrimental effect of this to those of us whose homes will be enveloped by continuous rows of metal and glass, security fencing, floodlighting and CCTV towers cannot be overstated and has been accepted as immitigable by the developer itself. For those living close to the battery storage site, the proposed scheme poses significant danger. Thermal runaway incidents and the release of toxic gasses are known hazards, but the Outline Battery Fire Safety Management Plan includes no engineering standards to address this, nor has any realistic safety plan been proffered, a fact substantiated by Essex Fire and Rescue Service. Set-backs or complete removal of panels from proximity to residential areas must be built into any accepted version of the scheme. So-called mitigation planting will have limited effect as new trees and hedgerows will have little effect in autumn and winter and none during at least the first 10 years of the scheme whilst the planting becomes established. There is a serious need to develop alternative sources of energy. However, this solar plant will take up roughly 600 times more space than a conventional power station producing the same capacity of electric power. The same capacity could be delivered by just three offshore wind turbines. The Government Energy Security Strategy (April 2022) recommends offshore wind and nuclear energy, with no recommendation for solar power. The strategy further states that large-scale solar projects should be located on previously-developed or lower-quality land. Longfield has made no genuine attempt to find more appropriate sites on low-grade land. Essex contains some 30,000ha of lower-grade, more appropriate land, not to mention available brownfield sites, all of which would be more suitable. The siting of this proposed scheme is evidently based on nothing more than the lazy convenience of dealing with a single land owner in this early stage. All land affected by this proposed scheme is good quality agricultural land, the majority being Grade 2. National planning guidance recommends strongly against solar development on “best and most versatile farmland (BMV), classified as Grades 1,2 and 3A. Likewise, BRE’s ‘Planning Guidance for the Development of Large Scale Ground Mounted Solar PV Systems’ stipulates that national planning policy doesn’t support development on high-grade agricultural land, stating specifically to the contrary that “best quality land should be used for agricultural purposes”. The proposed loss of so much BMV land will be disastrous for food production, particularly within the wider trend of land being lost to solar projects. UK food production is presently around 50% of total need, and diminishing rapidly. To improve food security, the government’s target is 70%. The National Planning Policy Framework is intended to protect high-value farm land. The area to be covered by the proposed scheme has significant biodiversity value, containing a number of habitats and rare species, as Longfield’s own research corroborates. Despite the proposed mitigation and enhancement measures, an industrial solar plant of this size will eradicate traditional habitats through both the panels and associated infrastructure and through the perimeter fencing and lighting, which will exclude access to most larger mammals. Furthermore, bird deaths are a common occurrence in large solar developments, as birds mistake panels for areas of water. For these reasons, I recommend that the Longfield application for a DCO should be rejected."
Members of the Public/Businesses
Essex County Fire and Rescue Service
"Firefighting Water Requirements, Access for Firefighting and safety features approved to recommend standards for BESS e.g. fine water spray and not a gaseous flooding system for a BESS."
Members of the Public/Businesses
James Curtis
"I believe this proposal will have a negative impact on agricultural land, biodiversity, the landscape, as well as increasing noise pollution and traffic. There are concerns over the battery safety and there is a lack of consideration about the impact these proposals will have on adjacent properties. Although a need for more sustainable energy generation is required, this does not provide the sustainable alternative needed and there are genuine concerns about the carbon emissions this proposal will generate. Below are further details on each point: 1. AGRICULTURAL LAND LOSS According to the Defra Agricultural Land Classification map for east region (2001) ALL of the land taken up by the proposal is classified as >60% BMV or 20-60% BMV. Only a small area west of the Waltham Road is classified as 20-60% where there are a series of ponds and small lakes and a strip of land that follows the course of the River Ter. This development would lead to a loss of nearly 700 acres of excellent food producing land. To the south and east of the proposed site there are large areas of land classified as <= 20% BMV where the impact on food production would be significantly less. Food security is arguably more important than power security. It is contrary to A Green Future: Our 25 Year Plan to Improve the Environment which sets out the government’s 25-year plan to improve the health of the environment. It plans to: protect the best agricultural land, put a value on soils as part of our natural capital, manage soils in a sustainable way by 2030. 2. BIODIVERSITY There is a large diverse wild animal population that would be severely impacted by the proposed fencing around the site, notably deer, hares and other small mammals as well as the commercial rearing of pheasants and partridge. There would be destruction of ground nesting birds (Skylarks) as well as a significant impact on hunting birds eg Red Kite. Important natural land corridors would be disrupted. There are a large number of bat colonies in the area. 3. LANDSCAPE There will be a significant visual impact on the landscape of what is a beautiful part of the Essex countryside. The area is notable for its unspoilt views and quiet surroundings. It is a popular area for walkers and cyclists and contains part of the Essex Way. This development would destroy the rural setting that is so important to many people’s recreation and well-being. Neighbouring properties are not sufficiently protected from the visual eye-sore these panels will create. A hedgerow buffer is not adequate. 4. NOISE Noise levels both during the construction phase and when operational will have a significant impact on the tranquility afforded by the current rural setting. 5. CONSTRUCTION TRAFFIC The forecast traffic volume of 50 HGVs via Wheelers Hill, Waltham Road and Cranham Road is untenable. These are narrow country roads unsuitable for such a volume of HGVs and constitute a danger to local road users who use this route as a ‘cut through’ from the A12 to the A131. This route will also be severely affected by the construction of the the new by-pass road. 6. BATTERY SAFETY There are significant risks of fire/explosion from thermal runaway from Lithium-ion batteries. The recent BESS explosion in Liverpool is an indication of the serious risks that large battery installations pose. The Liverpool fire also illustrated the need for adequate water supplies to control such fires. There are no such adequate supplies in the area. Access for emergency vehicles would be severely hampered by the road system. 7. STATEMENT OF NEED The scheme is justified as a contribution to decarbonising the energy sector to meet net zero targets. However, solar farms are relatively inefficient. Solar's rating is about 15% efficiency whereas for off-shore wind the figure is 50%+ efficiency. Solar farms are not carbon-neutral. Most schemes ignore upstream processes, PV panel manufacture, BESS cables and cabling. The Energy Security Strategy (April 2022) concentrates on offshore wind and nuclear. No targets are set for solar. The strategy states it will ensure environmental protection for ground mounted solar and large-scale solar projects will be encouraged to locate on previously developed or lower value land. The strategy encourages roof-top solar and will simplify planning for this. The Longfield proposals should not be granted a DCO on the basis they are not Carbon neutral, are relatively inefficient and do not accord with the government strategy as set out in the recent energy security strategy namely that large schemes should be sited on lower value land. More consideration needs to be given to the location and scale of this proposal. Rather than using agricultural land for increased solar, focus should be driven to installing these on new builds, factories, along major roads and motorways. This proposal is a destruction of the natural landscape and biodiversity of the area which we should be protecting now more than ever."
Members of the Public/Businesses
Karen Mallottides
"Battery safety Noise Agricultural land loss"
Members of the Public/Businesses
Keith Richardson
"AGRICULTURAL LAND LOSS According to the Defra Agricultural Land Classification map for east region (2001) ALL of the land taken up by the proposal is classified as >60% BMV or 20-60% BMV. A small area west of Waltham Road is classified as 20-60% where there are a series of ponds and small lakes and land near the course of the River Ter. This development would lose nearly 700 acres of excellent food producing land. South-east of the proposed site there are large areas of land classified as <= 20% BMV where the impact on food production would be significantly less. Food security is arguably more important than power security. It is contrary to A Green Future: Our 25 Year Plan to Improve the Environment - the government’s 25-year plan to improve the health of the environment by - protecting the best agricultural land - putting a value on soils as part of our natural capital - managing soils in a sustainable way by 2030 BIODIVERSITY There is a large diverse wild animal population that would be severely impacted by the proposed fencing around the site, notably deer, hares and smaller mammals as well as pheasants and partridge. There would be destruction of ground nesting birds (Skylarks) as well as a significant impact on hunting birds eg Red Kite. Important natural land corridors would be disrupted.\r\n\r\nThere are a large number of bat colonies in the area. LANDSCAPE There will be a significant visual impact on the landscape of a beautiful unspoilt part of the Essex countryside. It is a popular area for walkers/cyclists containing part of the Essex Way. This development would destroy the rural setting that is so important to many people’s recreation and well-being. NOISE Noise levels both during the construction phase and when operational will have a significant impact on the tranquility afforded by the current rural setting. CONSTRUCTION TRAFFIC The forecast traffic volume of 50 HGVs via Wheelers Hill, Waltham Road and Cranham Road is untenable. These are narrow country roads unsuitable for such a volume of HGVs and constitute a danger to local road users who use this route as a ‘cut through’ from the A12 to the A131. This route will also be severely affected by the construction of the the new by-pass road. BATTERY SAFETY There are significant risks of fire/explosion from thermal runaway from Lithium-ion batteries. The recent BESS explosion in Liverpool is an indication of the serious risks that large battery installations pose. The Liverpool fire also illustrated the need for adequate water supplies to control such fires. There are no such adequate supplies in the area. Access for emergency vehicles would be severely hampered by the road system. STATEMENT OF NEED The Longfield proposals should not be granted a DCO on the basis they are not Carbon neutral, are relatively inefficient and do not accord with the government strategy as set out in the recent Energy Security Strategy namely that large schemes should be sited on lower value land."
Members of the Public/Businesses
Lisa Curtis
"I believe this proposal will have a negative impact on agricultural land, biodiversity, the landscape, as well as increasing noise pollution and traffic. There are concerns over the battery safety and there is a lack of consideration about the impact these proposals will have on adjacent properties. Although a need for more sustainable energy generation is required, this does not provide the sustainable alternative needed and there are genuine concerns about the carbon emissions this proposal will generate. Below are further details on each point: 1. AGRICULTURAL LAND LOSS According to the Defra Agricultural Land Classification map for east region (2001) ALL of the land taken up by the proposal is classified as >60% BMV or 20-60% BMV. Only a small area west of the Waltham Road is classified as 20-60% where there are a series of ponds and small lakes and a strip of land that follows the course of the River Ter. This development would lead to a loss of nearly 700 acres of excellent food producing land. To the south and east of the proposed site there are large areas of land classified as <= 20% BMV where the impact on food production would be significantly less. Food security is arguably more important than power security. It is contrary to A Green Future: Our 25 Year Plan to Improve the Environment which sets out the government’s 25-year plan to improve the health of the environment. It plans to: protect the best agricultural land, put a value on soils as part of our natural capital, manage soils in a sustainable way by 2030. 2. BIODIVERSITY There is a large diverse wild animal population that would be severely impacted by the proposed fencing around the site, notably deer, hares and other small mammals as well as the commercial rearing of pheasants and partridge. There would be destruction of ground nesting birds (Skylarks) as well as a significant impact on hunting birds eg Red Kite. Important natural land corridors would be disrupted. There are a large number of bat colonies in the area. 3. LANDSCAPE There will be a significant visual impact on the landscape of what is a beautiful part of the Essex countryside. The area is notable for its unspoilt views and quiet surroundings. It is a popular area for walkers and cyclists and contains part of the Essex Way. This development would destroy the rural setting that is so important to many people’s recreation and well-being. Neighbouring properties are not sufficiently protected from the visual eye-sore these panels will create. A hedgerow buffer is not adequate. 4. NOISE Noise levels both during the construction phase and when operational will have a significant impact on the tranquility afforded by the current rural setting. 5. CONSTRUCTION TRAFFIC The forecast traffic volume of 50 HGVs via Wheelers Hill, Waltham Road and Cranham Road is untenable. These are narrow country roads unsuitable for such a volume of HGVs and constitute a danger to local road users who use this route as a ‘cut through’ from the A12 to the A131. This route will also be severely affected by the construction of the the new by-pass road. 6. BATTERY SAFETY There are significant risks of fire/explosion from thermal runaway from Lithium-ion batteries. The recent BESS explosion in Liverpool is an indication of the serious risks that large battery installations pose. The Liverpool fire also illustrated the need for adequate water supplies to control such fires. There are no such adequate supplies in the area. Access for emergency vehicles would be severely hampered by the road system. 7. STATEMENT OF NEED The scheme is justified as a contribution to decarbonising the energy sector to meet net zero targets. However, solar farms are relatively inefficient. Solar's rating is about 15% efficiency whereas for off-shore wind the figure is 50%+ efficiency. Solar farms are not carbon-neutral. Most schemes ignore upstream processes, PV panel manufacture, BESS cables and cabling. The Energy Security Strategy (April 2022) concentrates on offshore wind and nuclear. No targets are set for solar. The strategy states it will ensure environmental protection for ground mounted solar and large-scale solar projects will be encouraged to locate on previously developed or lower value land. The strategy encourages roof-top solar and will simplify planning for this. The Longfield proposals should not be granted a DCO on the basis they are not Carbon neutral, are relatively inefficient and do not accord with the government strategy as set out in the recent energy security strategy namely that large schemes should be sited on lower value land. More consideration needs to be given to the location and scale of this proposal. Rather than using agricultural land for increased solar, focus should be driven to installing these on new builds, factories, along major roads and motorways. This proposal is a destruction of the natural landscape and biodiversity of the area which we should be protecting now more than ever."
Members of the Public/Businesses
National Grid
"Representation by National Grid Electricity Transmission in respect of the Longfield Solar Farm DCO (the “Project”) Introduction This relevant representation is submitted on behalf of National Grid Electricity Transmission Plc (“NGET”) in respect of the Project. NGET is interested in particular in the extension to Bulls Lodge Substation (“NGET Works”), which are intended to be carried out by NGET, and in the impact of the Project on NGET’s infrastructure and land within or in close proximity to the proposed Order limits. NGET can confirm that it has worked with the Promoter during the preparation of the application documents in order to ensure that they accommodate NGET’s requirements. National Grid will, however, require appropriate protection for retained apparatus including compliance with relevant standards for works proposed within close proximity of its apparatus. National Grid’s rights of access to inspect, maintain, renew and repair such apparatus must also be maintained at all times and access to inspect and maintain such apparatus must not be restricted. Further, where the Promoter intends to acquire land or rights, or interfere with any of National Grid’s interests in land or National Grid’s apparatus, National Grid will require appropriate protection and further discussion is required on the impact to its apparatus and rights. Further detail is set out below. NGET Land and Infrastructure Impacted NGET has a substation and high voltage electricity overhead transmission line within or in close proximity to the proposed Order limits including a proposed connection Bulls Lodge 400kV substation. The substation and overhead line form an essential part of the electricity transmission network in England and Wales. The details of the electricity assets are as follows: Substation Bulls Lodge 400kV Associated fibre cables Overhead Lines 4VB 400kV overhead line Braintree-Pelham-Rayleigh Main Circuit 14VB 400kV overhead line Braintree-Pelham-Rayleigh Main Circuit 1 Protective Provisions NGET requires protective provisions to be included within the DCO to ensure that its interests are adequately protected and to ensure compliance with relevant safety standards. NGET is working with the Promoter in relation to the protective provisions for inclusion within the DCO, along with any supplementary agreements which may be required. NGET and the Promoter will keep the Examining Authority updated in relation to these discussions. NGET Works The Project includes the NGET Works (Work Nos. 5, 7B and (in part) 9 in the draft DCO) and NGET will require sufficient powers and rights of access under the DCO in order to be able to carry these out. As mentioned above, NGET and the Promoter have co-operated to ensure that the DCO accommodates NGET’s requirements and will continue to do so throughout the examination process. Summary As a responsible statutory undertaker, NGET’s primary concern is to meet its statutory obligations and ensure that any development does not impact in any adverse way upon those statutory obligations. NGET and the Promoter have worked together closely in order to agree the requirements for the NGET Works and to ensure that the Project includes both the powers required by NGET and satisfactory protection for NGET’s infrastructure. NGET reserves the right to make further representations as part of the examination process but in the meantime will continue to work with the Promoter with a view to reaching a satisfactory agreement on all matters."
Members of the Public/Businesses
The Riley Family on behalf of Riley
"Our comments regarding the Longfield Solar farm development: The unprecedented size and industrial nature of the development is far too large and inappropriate for the location proposed. The motivation for this solar farm to be of this immense size and in this location is purely due to there being one willing land owner who owns all the land, not because it is the best location for a solar farm. The developer has confirmed that NO other sites were considered and that NO comparison with any other sites was made. A large proportion of the land earmarked for development is classified as Best and Most Versatile agricultural land. The UK should be looking to becoming more self-sufficient in the production of food and not use good quality agricultural land for industrial use. There are more suitable positions on lower grade agricultural land that have not even been considered. The developer confirmed that is much simpler and easier to deal with only one land owner. The developer's claims that only a third of the land is BMV is in contradiction to the original Agricultural Land Classification maps which state that the whole site consists of BMV land. All BMV land should be removed from the proposal and not retained just for the solar farm's operational convenience. This is not a viable reason to retain land of this quality in the development. Other renewable energies such as nuclear are looking to develop modular units and place them in brownfield locations and industrial areas. Regeneration of existing brownfield and industrial sites should have had far more focus and discussion but this has been dismissed by the developer. The developer confirmed that it is much easier and cheaper to build on untouched fields than regenerate a more appropriate site. The solar farm will have a wholly detrimental impact on the landscape, environment and substantial wildlife that relies on the land. The solar farm will completely destroy the visual aspect of the landscape and there are no possible mitigation proposals the developer has or could put forward that will improve this. A vast rural landscape will be replaced by industrial units and fencing on a huge scale, the character of the area will be lost forever. Where once residents lived within a rural setting they will be living in the middle of a huge industrial zone. Planting a new young hedgerow will not alter this. There are IMMENSE safety concerns regarding the enormous lithium battery storage unit and the potential for fire, explosion and emission of toxic gases. These concerns have not been addressed by the developer. There is a general lack of information available relating to the effect on biodiversity and ecology of a solar farm of this massive scale over the period proposed. The developer has suggestion biodiversity net gains and positive ecological improvements that are unsubstantiated. This area should not be used as a learning tool for future solar farm developments. Once the solar farm has been built it will be too late, the damage will be irreversible. The solar farm will have a detrimental effect on the noise levels in the region. This is a rural area and it is well known that the components of a solar farm such as transformers, inverters etc. emit a level of noise and vibration that is significant. There is no possible mitigation to improve this. With reference to the construction of the solar farm, the roads surrounding the solar farm are rural roads and even with the vague, limited improvements proposed are totally unsuitable and dangerous for large construction vehicles and lorries, especially in the numbers that will be needed to build this solar farm. The enormous number of construction workers, 600 at the peak, highlights that this is a massive construction project totally inappropriate for the area and infrastructure. Initially the developer proposed working hours of 7am to 7pm, 6 days a week. They have now increased this to 7am to 7pm, 7 days a week. We feel this is to give them room to negotiate and achieve their aim of working 6 days a week. These working hours, 6 days a week are TOTALLY UNACCEPTABLE. Residents will be living right in the middle of a major construction site with substantial light, noise and dirt pollution. In reality we would be affected from 6am to 8pm and residents' mental health would be severely affected. This programme of working hours is to entice travelling labour, not local workers. The workers will have to have experience of similar projects and be sourced nationwide. The developer's claim that it will create jobs for local people is a sop to try and push through planning approval. Off shore wind farms are 3 times more efficient than solar farms and the construction/decommissioning (of which there is limited and vague information) of this huge solar farm will create large green-house emissions. This solar farm proposal is therefore just a money making vehicle for the land owner and the developer. If the developer was serious about helping to meet the Government's target for zero carbon electricity it would be investing in off shore wind farms and nuclear projects such as the modular nuclear units. The Energy Security Strategy concentrates on these areas of renewable energy, not solar and states that solar developments should be on previously developed or lower value land (not prime agricultural land) and encourages the use of roof-top solar panels. In conclusion, this solar farm proposal is not aligned with the Government's strategy for energy, is far too large, industrial, damaging and unsuitable for the location and disregards the area's heritage and productive use of the site.""
Members of the Public/Businesses
Susan Lesley Richardson
"AGRICULTURAL LAND LOSS According to the Defra Agricultural Land Classification map for east region (2001) ALL of the land taken up by the proposal is classified as >60% BMV or 20-60% BMV. Only a small area west of the Waltham Road is classified as 20-60% where there are a series of ponds and small lakes and a strip of land that follows the course of the River Ter. This development would lead to a loss of nearly 700 acres of excellent food producing land. To the south and east of the proposed site there are large areas of land classified as <= 20% BMV where the impact on food production would be significantly less. Food security is arguably more important than power security. It is contrary to A Green Future: Our 25 Year Plan to Improve the Environment which sets out the government’s 25-year plan to improve the health of the environment. Its plans include: - protect the best agricultural land - put a value on soils as part of our natural capital BIODIVERSITY There is a large diverse wild animal population that would be severely impacted by the proposed fencing around the site, notably deer, hares and other small mammals including bats. There would be destruction of ground nesting birds (Skylarks). Important natural land corridors would be disrupted. LANDSCAPE There will be a significant visual impact on the landscape of what is a beautiful part of the Essex countryside. The area is notable for its unspoilt views and quiet surroundings. It is a popular area for walkers and cyclists and contains part of the Essex Way. This development would destroy the rural setting that is so important to many people’s recreation and well-being. NOISE Noise levels both during the construction phase and when operational will have a significant impact on the tranquility afforded by the current rural setting. CONSTRUCTION TRAFFIC The forecast traffic volume of 50 HGVs via Wheelers Hill, Waltham Road and Cranham Road is untenable on these are narrow country roads. This route will also be severely affected by the construction of the the new by-pass road. BATTERY SAFETY There are significant risks of fire/explosion from thermal runaway from Lithium-ion batteries. Access for emergency vehicles would be severely hampered by the road system. STATEMENT OF NEED The scheme is justified as a contribution to decarbonising the energy sector to meet net zero targets. Solar farms are relatively inefficient. Solar's rating is about 15% efficiency whereas for off-shore wind the figure is 50%+ efficiency. Solar farms are not carbon-neutral. Most schemes ignore upstream processes, PV panel manufacture, BESS cables and cabling. The Energy Security Strategy (April 2022) concentrates on offshore wind and nuclear. No targets are set for solar. The strategy states it will ensure environmental protection for ground mounted solar and large-scale solar projects will be encouraged to locate on previously developed or lower value land. The strategy encourages roof-top solar and will simplify planning for this. The Longfield proposals should not be granted a DCO on the basis they are not Carbon neutral, are relatively inefficient and do not accord with the government strategy as set out in the recent energy security strategy namely that large schemes should be sited on lower value land."
Members of the Public/Businesses
Tracie Harvey
"OBJECTION TO LONGFIELD SOLAR FARM DEVELOPMENT 1. AGRICULTURAL LAND LOSS 1.1 National Planning Policy Framework makes the protection of BMV land a priority, this is even more important as we move closer to food poverty with in the UK.Developers should be using areas of poorer agricultural land and not BMV as all the land proposed in this development was first recorded as being. Developers need to show they have searched for sites that are of low agricultural value and explain why these are not suitable. 1.2 The context of land loss is its effect on food security.The cumulative loss from the Longfield proposal and all the other NSIPs, and smaller schemes going through LPAs, will result in the loss of thousands of acres of food producing land. The result will be more food imports at greater cost and with more uncertainty regarding food availability. 1.3 It is suggested the Longfield development will see the first 12 inches of top soil removed across the total area proposed, if this is true then this land will never return to agricultural land again. 1.4 On the original ALC maps the whole site was Grade 2 and therefore BMV, my understanding is that is has now changed as lower grade soil has been, however within the area marked as lower grade there is still a large area of BMV land that can be used, this is very misleading. 1.5 Alternative sites, Longfield state that using land classification maps shows no prevalence of higher-grade land in the vicinity of the scheme. The maps used in the documentation also show that the scheme is all on Grade 2 land and most of the land to the south and south-west is Grade 3 (the bulk of which is Grade 3b). On page 79, the map provided indicates there is ample low-grade land within the vicinity of 400Kw NETS power line 1.6 Removal of BMV land from proposals (para 6.7.30, pages 84 & 85) explains why 6 BMV land areas remain within the proposal in detail, this is not a good enough reason for including BMV land in the scheme 1.7 Conclusions, based on all the facts in paras 1.1 and 1.6 above, it is reasonable to regard the whole of the site as productive agricultural land and on this basis all planning approval should be refused, even more so when the UK is heading in to food poverty. It is quite clear that the Longfield developers have made no serious attempt to look for or consider alternative sites as with in the county of Essex there is over 30,000 ha of poorer grade land providing more than enough space to develop this solar farm development. If this low grade land is to be ignored by Longfield then the very least BMV land should be removed from this proposals. 2. BIODIVERSITY AND LONGFIELD SOLAR FARM 2.1 Introduction to BNG Maintaining and increasing biodiversity is regarded as a critical factor in managing the stability of the planet. To this end, the 2021 Environment Bill mandates most new development will deliver an overall gain in biodiversity. This is called ‘biodiversity net gain ‘(BNG) or sometimes ‘net biodiversity gain’ (NPG). This is therefore an important aspect for all local planning authorities to consider in approving or rejecting planning proposals and, in particular, solar farms. The law does not apply to NSIPs (Nationally Significant Infrastructure Projects). Nevertheless, developers may wish to show their NSIP proposals do deliver BNG. 2.2 Measurement of BNG Biodiversity was originally measured by using Biodiversity Metric 2.0 (JPO 29) Natural England 007.2019; this has now been superseded by Biometric 3 (JPO 39) Natural England 07.2021. JPO 39 was used in the Longfield BNG report. 2.3 Commentary on BNG Ecologists in the UK generally regard the metric as not fit for purpose. Prof. K. Willis a leading ecologist from Oxford University said in 2021 that the BNG total “will promote further loss and fragmentation of some of the UK’s natural environment and even more important the ecosystem services that flow. She concludes that “net biodiversity gain will end up being net biodiversity loss”. 2.4 Biodiversity impact on solar farms, In 2019 a survey by BSG Ecology stated “evidence of solar farms impact on biodiversity remains limited… there is little empirical data on the subject”. Natural England recommends the avoidance of solar developments in or near to areas of high ecological value. In the same report it was stated that “the lack of evidence available relating to the ecological impact of solar farms is concerning”. Longfield documents (para 4.6.1) claim a BNG of 79%. This is not a figure that can be justified. 2.5 BNG Trading Rules “The proposed development results in a loss of 6.35 units of high distinctiveness – lowland mixed woodland, and the provision of lower distinctiveness woodland to compensate for the loss of habitat is contrary to published net gain trading rules”. In addition, the report states that “Trading rules are not met for mixed scrub and pond habitats.” Overall, the conclusion must be there is a possible damage to biodiversity and the BNG is not valid and does not follow the trading rules as set out in JPO 39. 2.6 Ecological Survey details 2.6.1 Badger Survey – this report is confidential and so comments cannot be provided. 2.6.2 Reptiles – “The ecological data is only valid for short periods due to the transient nature of the subject. A survey in 2022 is recommended.” This is not currently available. 2.6.3 Birds (para 6.1.1). “The scheme has the potential to result in the direct loss of habitat needs by protected and notable bird species.” There is a recommendation that a significant number of extra surveys are required. Wintering bird surveys are needed in 2022/23. 2.6.4 Breeding Bird Surveys – “The construction of the scheme in the absence of avoidance or mitigation has the potential to affect the breeding bird assemblage within the site boundary. These potential effects include; - habitat loss and fragmentation - displacement and/or loss of breeding populations\r\n- increase in noise causing disturbance and visual distortions”. Noted that loss of arable farmland will have an impact on the birds it supports such as Golden Plover, Skylark, Lapwing, Yellowhammer and Linnet. The loss of game cover will impact flocks of seed-eating passerines, Linnet and Yellowhammer. 2.6.5 Great Crested Newt (para 7.1.4). Noted that the Great Crested Newt terrestrial habitat may be directly affected on a temporary and permanent basis by the scheme. 2.6.6 Flora. Flora surveys are critical in any ecological survey as they represent baseline trophic levels. Surveys were carried out in 2020 and the document notes not all habitats were surveyed (para 3.4.4). Also noted that surveys are normally only valid for 18 months to 2 years. Noted there will be major construction impacts on the flora from noise, dust and lights. There will be habitat loss and change. “Overall, there will be loss of some improved grassland and important arable plant assemblages”. 2.6.7 Additional comments, the consultation brochure identifies 1 SSSI near the site and 31 non statutory sites within 2km. There is reference to an OLEMP (on-line Landscape & Ecology Management Plan). This could be an important document but is not available for comment. 2.6.8 Biodiversity Conclusions It is clear there will be mitigation and enhancement proposals in the Longfield Solar Farm; these are to be welcomed. If the mitigation and enhancement were to be applied in an agricultural context, as they could be in the government’s Environmental Land Management (ELM) scheme, then the biodiversity gains could be greater. It is clear from all the reports that more work is needed on ecology and biodiversity. The existing site is of significant value with its woodland areas, ponds, proximity of valuable sites and the range of species identified in the surveys. There is a probable negative impact on biodiversity and more ecological study is needed. It would be premature to give approval for large scale solar schemes such as Longfield Solar Farm proposals as after a few years considerable ecological damage could be achieved that would be difficult to correct. Current advice from organisations such as Natural England is to site solar farms away from areas of value. The Longfield Solar Farm site would be classed as an area of value. The BNG assessment of 79% cannot be justified, (para 7.3 Statement of Reasons quotes 79% BNG as a public benefit). 3. LANDSCAPE Longfield Solar Farm will have a major impact on the landscape and a visual impact on what is a beautiful part of the Essex countryside. This is identified in the consultation booklet p.21 “We have identified potential impacts on views into the site from a number of points during the construction, operational and decommissioning phases.”\r\nSpecified points to note regarding landscape are: 3.1 Para 6.5.4 acknowledges the fact that the scale and speed required to meet the current and future need identified is likely to have some negative effects on the landscape and visual amenity which may not be able to be mitigated. 3.2 Landscape Visual Amenity – para 10.8.18 notes medium sensitivity and medium magnitude effect (in construction) with moderate adverse to significant effect. Para 10.8.39 – the scheme would result in the loss of some key characteristics, namely the agricultural character and reduction in the sense of openness given the change of land use. Para 10.8.59 notes – People walking the Essex Way would experience moderate adverse effects. These effects are considered to be significant. Para 10.9.2 - It would not be possible to mitigate every adverse effect due to requirements of the solar generation. Table 10.7 indicates the residual effects after mitigation – a number of which are described as major adverse and significant (namely White Oaks which will surrounded at every outlook). 3.3 Mitigation effects Para 10.8.62 states that by year 15 the proposed planting would have established and would be in leaf and reduce the perception of the new infrastructure. Para 10.8.5 refers to advance mitigation planting, stating this would have significant effects by year 4 3.4 Overall Landscape Conclusions Landscape and visual impact will be very significant. Mitigation will have little impact since trees and hedgerows that will be planted to try and limit the adverse impacts will have little effect through the early part of the scheme (namely 15 years). 4. NOISE Chapter 11 of the Environmental Statement – Noise & Vibration 4.1 Chapter 11 is prepared by AECOM. 4.2 There are a number of NPPF, NPS, EN3 and EN1 guidelines NPPF state “proposals should demonstrate they mitigate impacts such as noise”, “prevent new developments from contributing to or adversely affected by unacceptable levels of noise pollution”, “identify and protect landscape areas which have remained undisturbed by noise”. 4.3 Noise levels are considered to have a medium impact at 70-75 dM and a high impact at 75dM. 4.4 The ES splits the site into R numbers. The properties most affected by the noise are near Boreham on the Waltham Road. Six sites are identified as having moderate to adverse noise early morning and night. R27 is White House and is given a medium rating of 40dM (LAr) night time and early morning. 4.5 The ES appears to undervalue the noise factors. In the construction phase mitigation appears to be primarily by informing those most affected by the noise when this will happen. Noise and vibration will come from inverters, transformers and switch gear. This is an adverse effect of the scheme. 4.6 Taking all the above in to account how detrimental will this noise pollution be to the “Mental Health” of the residents of Terling and the surrounding area having this work taking place six days a week, Monday to Friday 12 hours a day 00.70am to 19.00pm. 5. OTHER SIGNIFICANT CONCERNS 5.1 Construction Traffic Para 11.5.27 Chapter 11 ES During construction daily there will be a large number of HGVs on the strategic road network of which 50 HGVs would be on the local highway network via Wheelers Hill, Waltham Road and Cranham Road. 5.2 Planning Statement 7.2 Noted that National Highways has yet to submit for a DCO, when can this document be viewed and commented on as it not yet available. 5.3 Planning Statement 3.3 In the construction period there will be over 600 workers and the construction will be from 7 a.m. to 7 p.m. on Monday-Sunday, how will impact on the metal health of the people of Terling and the surrounding areas? 5.4 Statement of Reasons 4.1 Compulsory Acquisition Powers. These are requested as it has not been possible to obtain all interests by agreement. Para 1.7.1 accepts this might infringe human rights. It is quite clear the construction phase will be very disruptive to local residents. 6. BATTERY SAFETY 6.1 Outline Battery Supply Management Plan. This is an outline plan and the detail is to follow. However, there are significant risks of fire and explosion from thermal runaway from Lithium-ion batteries. The storage for the Longfield site will be one of the largest in the country. It is clear the developer is aware of fire risks but it is difficult to comment on outline plans. It seems dangerous for a DCO to be given until such time as fire risks are adequately assessed and fully published. 6.1.1 In Summary – Liverpool report The explosion at the BESS facility at Carnegie Road, Liverpool was a result of a failure within one of the battery racks in one container which led to a thermal runaway which in turn produced gases within the container culminating in a large explosion with parts of the container being blown across the compound to a distance of 23m.The main fire took 6 hours to bring under control but the continual recycling of heat from the Li-ion batteries remained an issue and defensive fire-fighting continued on-site for a total of 59 hours. The fire and explosion were deemed to have been caused by the failure of one or more battery units, but the root cause of the battery failure remains unknown. The Liverpool site had only 3 BESS containers (Longfield is multiple enclosures). A fire suppression system had been fitted. The report stated there was a significant risk to emergency responders. Battery safety is a serious planning consideration for the Longfield submission, this is why a full “fire risk assessment” is required and should be published prior to any planning permission being granted. STATEMENT OF NEED 7.1 This statement, along with many other paragraphs in the documentation, justifies the Longfield proposals as a contribution to decarbonising the energy sector to meet net zero targets. The scheme is described as the deployment of zero-carbon electricity at scale. 7.2 It needs to be understood that solar farms are relatively inefficient. In terms of the amount of power exported to the grid Solar's rating is about 15% efficiency whereas for off-shore wind the figure is 50%+ efficiency. 7.3 Solar farms are not carbon-neutral. Research by scientists at Cranfield University has shown that Green House Gas emissions are relatively high (GHG). This is particularly during the construction phase. The probable output is 6.87 gas CO2 per KWhr. Most schemes ignore upstream processes, PV panel manufacture, BESS cables and cabling. The Energy Security Strategy (April 2022) concentrates on offshore wind and nuclear. No targets are set for solar. The strategy states it will ensure environmental protection for ground mounted solar and large-scale solar projects will be encouraged to locate on previously developed or lower value land. The strategy encourages roof-top solar and will simplify planning for this. All the above implies the Longfield proposals should not be granted a DCO on the basis they are not Carbon neutral, are relatively inefficient and do not accord with the government strategy as set out in the recent energy security strategy namely that large schemes should be sited on lower value land."
Members of the Public/Businesses
Angharad Wynne-Golledge
"This project is using land that has been treasured by many for years. The countryside already has so many other factors that are decreasing the amount of land that is left un touched. We must take responsibility at protect this land from being lost. It is well known in the construction industry that solar farms will never make enough energy to contract the environmental impact they have to make and maintain them. To allow this project to go ahead will be hugely irresponsible and damaging to this area. There are so many other option that can be done before destroying green spaces. The fact that this company have proposed to install this in the countryside where they propose is a clear indication of how irresponsible and backwards their thinking is. This land would never be the same and it would be devastated by this project."
Parish Councils
Boreham Parish Council
"I have already commented to Longfields and my comments are still valid. Storage of batteries are right next to protected ancient woodland, namely Toppinghohall wood and others. Also this site represents high quality agricultural land which must be used for food and animal food particularly with the problems in Ukraine. Large car firms like Toyota are already developing hydrogen cells for batteries which are much better in every respect for the future and this should be examined before we agree to this massive development. Also I would suggest wind turbans are also cheaper, take up less space and are far more efficient. Finally this application will be a massive blot on the landscape which can be put to much better space without having to destroy the natural environment which will happen. Thank you for reading these comments."
Local Authorities
response has attachments
Braintree District Council
"Please see attached."
Members of the Public/Businesses
Chris Williams
"There are a number of issues with this scheme. 1. Not carbon neutral Large solar farms are not carbon neutral, unlike other viable alternatives like offshore wind. This has been proven clearly by research by Cranfield University. Solar in this country is a good solution for smaller scale, localised on homes and commercial roofs but is too inefficient to be considered for replacing usable farmland. Solar in the UK is around 15% efficient as opposed to offshore wind at around 50%. We currently have no suitable method of recycling solar panels.The majority of PV panels are currently imported from China, currently the worst performing country environmentally in the world, as confirmed by COP26. Removing farmland also has a further negative impact due to more need for importing food, which in itself has a considerably poor carbon footprint impact. For a scheme to be truly carbon neutral, the whole story needs to be examined carefully. In doing so it is clear the total carbon footprint for Solar Farms is very poor. 2. Viable alternatives There are better viable alternatives. A single 8MW offshore wind turbine produces the same energy as that of around 35 acres of a Solar Farm. Wind Farms are placed in shallow waters, not affecting shipping. They do not cause issues with fishing or birds, have a very low carbon footprint and so are very green. UK policy is behind on allowing local authorities the power to push for the use of solar on commercial rooftops. This is an obvious option that is poorly supported and must be explored first. We should not be considering sacrificing farmland for solar before these better alternatives, and policies supporting those alternatives are developed. 3. Size and landscape The scheme is simply too large for the area and will cause considerable visual harm to the local landscape. The scheme will have a devastating impact on wildlife and public amenity. Visually the developer’s response is simply to mask the fields of panels, replacing many lush country vistas with high bush lines, deer fencing, or bush lined claustrophobic corridors. The planting of these bush lines will not mature for at least 10 years, so the panels would be clearly visible for this time. Large areas will be fenced off preventing animals from travelling routes established for centuries. There are minimal visual breaks in the scheme - the scheme is continuous for nearly 3 miles, so the scheme will be unavoidable on a daily basis for many residents. 4. Land loss & food security At least 34% of the land is BMV, a figure based on an assumption that the lowest grade found in that field has been used to represent the whole field. Given precision farming techniques, this is no longer the case and has been ignored in the ALC analysis. Land can be farmed with ease using variable GPS based technology, so this figure is likely to be much higher. There is also a growing importance of the value of non-BMV land, land that is still high yield. We must not remove any usable farmland. Food security cannot be ignored in the UK. With a move to import less and to become less reliant on imports, growing less food in the UK is a poor move. Prices are rising due to higher associated costs attributed to an aligning of import, fuel and Ukrainian and associated trades - a major contributor to the growing issue of food poverty in the UK. We cannot ignore the cumulative negative impact of UK solar farms on UK food production, especially at this time. 5. Biodiversity claims All biodiversity claims in the report appear to be based on theoretical studies, because there have simply not been schemes of this size built in the UK (for good reason). It would be impossible to claim with confidence that the scheme would provide the required Biodiversity Net Gain of 10% or more. Solar Farms are suitable for large, un-farmed, ideally desert terrains. The UK is far from this and has delicate, balanced ecosystems instead. There is no evidence at all that wildlife will be able adapt to single-site schemes of this size especially with most of the scheme fenced off. 6. Battery safety Large scale battery storage safety currently has a very poor safety record. With a growing number of BESS fires in the UK and globally, this is not a safe technology. We have been told by Essex Fire & Rescue that this is somehow not their concern. The HSE do not see this as falling into COMAH either. As a minimum we see this as a lack of thought as to how to deal with this, for example with no consideration for the volume of water required to handle a BESS fire of this potential scale. SUMMARY This scheme must not go ahead. There are viable, better, far greener alternatives that set a stronger foundation for a truly green future without making poor short-term commercially-led decisions."
Members of the Public/Businesses
Helen Drury
"1) The environment: Large solar farms are not carbon neutral, unlike other viable alternatives like offshore wind. This has been proven by research by Cranfield University. Solar in this country is a good solution for smaller scale, localised on homes and commercial roofs but is not efficient enough to be considered for replacing usable farmland. Solar in the UK is only 15% efficient as opposed to offshore wind at around 50%. We have currently no suitable method of recycling solar panel chemicals. The majority of PV panels are currently imported from China, currently the worst performing country environmentally in the world, as confirmed by COP26. The unseen further carbon contribution created by this scheme forcing more food importing also has a substantial negative impact on a scheme like this. 2) Size and landscape: The original call from the Secretary of State was for parcels of land with a single land owner. This no longer applies to Longfield Solar Farm as it’s so big there’s now more than one landowner involved. The scheme is too large for the area and will cause considerable visual harm to the local landscape. The scheme will have a devastating impact on wildlife and public amenity. The developer’s response is simply to mask the fields of panels, replacing many lush country vistas with high bush lines, deer fencing, or bush lined claustrophobic corridors. The planting of these bush lines will not mature for at least 10 years, so the panels would be clearly visible for this time. There are minimal breaks in the scheme, so the scheme will be unavoidable on a daily basis for many residents. 3) Land loss and food security: 34% of the land has been classed as BMV, a figure based on a sweeping assumption that the lowest grade per field has been assumed to represent the whole field. Given precision farming techniques, this is no longer the case. A farmer can farm land with ease using variable GPS based technology, so this figure is likely to be much higher. There is also a growing importance of the value of non-BMV land, land that still produces suitable harvest levels. Food security cannot be ignored in the UK. With a move to import less, to become less reliant on imports, growing less food in the UK is a poor move. Prices are rising due to higher import costs, a contributor to the growing issue of food poverty in the UK. The UK has some of the best farmland in the world and we’re losing it very swiftly, we cannot ignore the cumulative impact of UK solar farms. 4) Biodiversity: There have not been schemes of this size built in the UK, which means all claims to increase biodiversity are based on theoretical studies, not unbiased evidence. Solar is suitable for large, un-farmed terrains. The UK is far from this and has delicate, balanced ecosystems. Wildlife will simply not adapt to a scheme of this size for some time, if at all. 5) Battery safety: Large scale battery storage safety has a very poor safety record. With a growing number of BESS fires globally, this needs more careful thought. We have been told by Essex Fire & Rescue that this is not their concern, but it should be. We see as a minimum a lack of thought as to how to deal with this, for example with no consideration for the volume of water required to handle a BESS fire. The current opinion is to risk assess the site AFTER it’s built, which isn’t adequate. 6) Government policy contradictions: The British Energy Security Strategy states the government will continue “supporting the effective use of land by encouraging large scale projects to locate on previously developed, or lower value land and ensure projects are designed to avoid, mitigate, and where necessary, compensate for the impacts of using greenfield sites”. This does not apply in regards to Longfield Solar Farm. The National Planning Policy Framework states: “Planning policies and decisions should contribute to and enhance the natural environment by a) protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils”. “b) 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” “c) remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate”. This also does not apply in regards to Longfield Solar Farm. The 2021 Environment Act demands a BNG of 10% from every planning permission granted. The developers have theoretical plans, but have not provided unbiased evidence that this can be delivered. As the government stated that there would be a 2 year implementation period for mandatory BNG following the assent of the Environment Bill 2021, it means this will come into force in November 2023 which is before construction on the site begins. Hence this point needs to be examined very carefully as it will be enforceable. 7) Failures in the consultation process: In-person statutory consultation dates were not appropriately publicised by the developers or their PR company, additional dates for consultation were added surreptitiously to the website in a non-obvious place you had to actively look for to find. Such important activity would normally be expected to be published on the homepage if the drive for public engagement were sincere. Our household was not included on the postal mailout until Spring 2021, with others reporting the same, which means it’s fair to assume those without internet access were likely impacted. Longfield have stated the number of responses they received during the statutory consultation, given the number of parishes affected these numbers seem too low to be considered adequate. Our Parish Council have expressed their concern at the number of residents who were unaware of the proposal. It should not be the responsibility of a Parish Council to monitor the developers website on the off chance there are updates. We also have concerns about the two other major infrastructure schemes that will impact the area, namely the A12 widening proposals being advanced by a DCO application by National Highways, and the Chelmsford NE bypass being advanced by Essex Highways to Essex County Council. There is no evidence of public engagement to demonstrate joined up thinking between these separate applications and the Longfield Solar Farm developers, including the consequent impact they will have as a whole. 8) Are you really convinced that sacrificing farmland at a time of global food insecurity is a good idea? Are you convinced it is environmentally friendly to increase how much food we import from abroad as a result? Are you convinced the proposal provides acceptable evidence of a 10% increase in biodiversity even though there is no unbiased research to support the claim? We are keen to see an increase in sustainable energy, but we do not feel this proposal is the best course of action and consider it likely to leave us worse off further down the line."
Members of the Public/Businesses
Jeff Rice
"Climate Change is the greatest threat facing our planet, it’s a climate emergency, and we need urgent action on the issue. We need renewable technology solutions, such as this proposed solar farm, to tackle climate change."
Members of the Public/Businesses
Mr Nigel Richard Brown
"1.1 Summary It is clear that development of a solar farm on the scale of that proposed by the Longfield Solar Farm (LSF), will result in the loss of agricultural land and have an adverse impact on the rural landscape in which it is set. These issues are noted below (1.2) I would like to make some more detailed comments in due course. Should the LSF go ahead some essential points to maximise public benefit through increased knowledge and access are noted. (1.3) 1.2 Adverse impacts Agricultural land: Should the LSF go ahead there will be a considerable loss of agricultural land, given current concerns over food supply and food security that will be a significant detrimental impact. Whilst the serious nature of climate change requires a rapid change to renewable energy, that change must be sustainable. It may be that energy derived from large scale solar farms taking agricultural land out of production may not be the appropriate way forward. Solar power installations may be better placed on buildings, and brownfield sites Landscape: The proposed LSF will introduce large areas of essentially industrial installations into a rural landscape which will be visually intrusive. The LSF will be located in an area of central Essex with an ancient landscape, diverse archaeological remains and significant built heritage, and will inevitably have a variety of adverse impacts on the cultural heritage/historic environment. 1.3 Maximising public benefit\r\nClearly the adverse impacts noted above will need to be weighed against the benefits of the LSF. Should the LSF be granted permission public benefit should be maximised by:- i. providing a fully integrated account of the historic development of the landscape and its interrelationship with the natural environment should be set out and used to inform the long-term management of the landscape. An improved understanding of the cultural heritage/historic environment should be identified as an environmental enhancement. ii ensuring public access to the network of footpaths and trackways in the area of the LSF, ensuring adequate north south access to link with the main centre of population in Boreham will be essential."
Members of the Public/Businesses
Mr R. Golledge
"This project is a crime of extreme vandalism in the countryside Its 'DIRTY GREEN' and gives the illusion of being good for the planet but is something the planet cannot afford due to the massive carbon footprint when considering everything from photovoltaic panel production in a country where the only driving force is profit and has no concept of environmental destruction and an equally abominable track record of social justice and lack of human rights to the necessary importation of basic food staples, which will be required due to the loss of such fertile arable land. The stated need to remove the topsoil to enable 'meadow' to grow around the solar panels is a testament to the arable land we will be losing. Taking this fertile land out of crop production begs the question of where will our food come from and the increase in carbon footprint to get it here. Studies have shown the British climate isn't best suited to production of solar power and lags behind wind power generation. The current photovoltaic technology falls short of efficient energy production in Britain, meanwhile technical advances being made in the fields of fusion energy production, such as the Tokamak approach, are rapidly advancing and are likely to make this type of installation obsolete well within the expected life of this solar farm. The probability that energy production will be superseded by other developments in the near future will make Longfield nothing more than an unwanted, unnecessary white elephant and an irreversible scar on our landscape having destroyed the habitats of many animals."
Members of the Public/Businesses
response has attachments
Addleshaw Goddard LLP on behalf of Network Rail Infrastructure Limited
"We act on behalf of Network Rail Infrastructure Limited and wish to submit a Relevant Representation in relation to Longfield Solar Farm. In anticipation of the deadline for submission on Thursday 2 June 2022, we now attach our client's Relevant Representation."
Members of the Public/Businesses
Nigel Barnes
"Proposed site is on high grade agricultural land and is far, far too big. We need food farms, not wind or solar, especially as food security is compromised by the actions of the Russians. Ukraine now, which country next? The safety of the battery farm is very questionable and a number of fires have be reported around the world. No details have been provided about how the site would be de-commissioned and the materials recovered. There is a great fear that it will end up in landfill like all the old wind turbines in the USA. There are many enormous warehouses which could have panels fitted to the roof. Land is then only wasted once for two reasons. The whole of NE Chelmsford is proposed for housing. Adding this plan would mean the Parish of Boreham would almost cease to exist. A number of ancient woodlands would be surrounded and local footpaths turned into corridors with loss of view and enjoyment. Free movement for wildlife will be lost."
Members of the Public/Businesses
No To Longfield campaign
"The No To Longfield campaign was set up in response to a number of residents not being informed about the scheme or updated adequately. Residents reported to us that even though they were within the proposed areas, adjacent to, or close by, they had not received any leaflets. While offering this support, our campaign noted the following summary of concerns from residents: SIZE AND LANDSCAPE Residents are seriously concerned about the size of the scheme. They find it wholly inappropriate to place a single scheme of this scale in one place. This will have a devastating effect on the local community who enjoy this part of Essex, the scenery, the wildlife and the open spaces. This scheme will see closed hedge lines, heavily restricted views and it will be impossible to avoid for many residents. NOT CARBON NEUTRAL Residents have questioned the carbon neutral credentials of the scheme. They have concerns that the whole carbon footprint of the scheme, from manufacturing the panels through to installation, has not been thoroughly considered. Residents have concerns about removing productive farmland from UK food production. They note that this also contributes considerably to the carbon footprint of this scheme and are aware of the research done by Cranfield University proving that this scheme, like other solar farms of this size, is far from carbon neutral. VIABLE ALTERNATIVES Residents have suggested that solar panels would be better suited to commercial rooftops. They have read studies that suggest there is ample opportunity for this in the UK but that planning policy does not allow for local authorities to make it happen. This issue has been confirmed by District Councillor (Green) James Abbott who says that Braintree District Council has no power to require solar on new commercial buildings. Residents are aware that solar farms have not been championed in the UK by any non-commercial group and note that wind farms appear to be well supported. Residents do not believe this is the best use of farmland when there are good alternatives available. LAND LOSS & FOOD SECURITY Residents are concerned about the loss of productive farmland. Many residents are either local farmers or workers associated with the local farming industry. They note that all the land within the proposals has high yield and do not believe it should be removed from essential food production. They see for themselves also that many fields not formally classified as BMV land still produce high yield crops. Some residents have been affected by the increased cost of living and so have concerns that removing farmland from the UK will impact this considerably. Some residents are also aware, through the national Solar Campaign Alliance, of the total effect of all the combined solar schemes currently being proposed in the UK. Residents have serious concerns about the cumulative effects of this. BIODIVERSITY CLAIMS Residents are aware of the biodiversity claims by the Longfield Solar Farm developers and their proposed very high Biodiversity Net Gain (BNG) figures. They feel claims of this magnitude cannot possibly be proven since there are no schemes in the UK on this scale. Many residents are nature enthusiasts, appreciating the delicate nature of the local ecostem and have no confidence that the BNG figures proposed will be met. Residents have serious concerns that all solar panel fields will be fenced off, preventing all movement of wildlife from moving freely. Residents see many animals (deer, munjacks, hares, foxes and badgers) roam freely across farmland and do not feel the restricted new corridors proposed would be close to sufficient for wild animals. BATTERY SAFETY Residents have serious concerns over the proposed BESS site. Large scale battery storage safety currently has a very poor safety record. With increasing regularity of incidents related to battery storage facilities in the UK and worldwide, they have concerns that this is a technology to be used at scale yet. Essex Fire & Rescue have little interest in commenting on this scheme and HSE do not see it as a COMAH site either. There appear to be no details about accident prevention, containment or handling. CONSULTATION Many of our residents have had issues with the quality of consultation throughout the whole process. Many residents did not hear of the scheme as they were missed from the leaflet drop, some residents even directly in or beside the scheme. Many of our residents fall within a senior demographic and have struggled with the technology that was required for them to truly understand the impact of the scheme should it go ahead. Email lists managed by the scheme developers were barely used. Pre-consultation event dates were not well advertised. When new dates were set, only the developer’s website was updated, no attempt was made to use the mailing lists so many residents were unaware of new dates being available. Chair, No To Longfield campaign"
Members of the Public/Businesses
Paul Guppy
"Don't build solar farms on good agricultural land. Battery storage and safety Massive size of the solar farm and the effect on wildlife and landscape Negative impact on biodiversity Terling Parish Council not reflecting parishioners concerns"
Members of the Public/Businesses
response has attachments
Paul Harrison
"I wish to submit my comments via a PDF. Please see attached."
Members of the Public/Businesses
Penelope Jane Rickards
"There needs to be a Governmental National Policy on the use of Solar Farm applications - not PERVERSE FARMING INCENTIVES! It is very wrong that farmers are being forced into making more money from leasing their land to the developers than they can make out of farming! The size of the proposed development is equivalent to 857 football pitches, which at a time of increased food security risk will take 1134 acres of prime agricultural land out of food production. Solar panels should be placed on all NEW HOUSING, INDUSTRIAL PARKS, BESIDE MOTORWAYS - not on Green field sites. The risk of spontaneous fire and explosion to the battery storage facilities must be taken into consideration, along with the risk to human health. It will take 2 hours to walk from end to end of the scheme, totally dominating and industrialising the character and landscape and local amenity. The amenity of neighbouring property will be seriously harmed by secured boundaries of high fencing, 3m high solar panels and intrusive CCTV. Solar farms are not environmentally friendly - how will the panels be recycled at the end of their lives? Solar panels are hugely inefficient - producing up only 15% of the energy absorbed into electricity. It is unlikely that this land will be returned to agricultural use in 30/40 years time. Reinstatement bonds are worthless!"
Members of the Public/Businesses
response has attachments
Alan Swash
"See attached comments sent by email"
Members of the Public/Businesses
response has attachments
Boreham Conservation Society
"See attached comments sent by email."
Members of the Public/Businesses
David John Belsham
"From a sustainability perspective, I do not believe that a solar farm should be built on good quality agricultural land. The most sustainable use of the UK's existing agricultural land must be to produce food for UK residents, using sustainable farming techniques. Such techniques mean that the land can, at the same time, be used for carbon sequestration by improving the carbon content of the soil. Carbon sequestration might also be achieved by maintenance of the land as pasture or by planting trees. Production of food on properly farmed land and the sequestration of carbon through agriculture are both critical needs for the UK and the planet, and should have higher priority than solar power generation, especially when off-shore wind provides such an efficient alternative to solar. A large solar farm represents industrialisation of scarce, beautiful and ancient countryside, and will result in biodiversity loss compared with the use of sustainable farming techniques. It also brings fire risk from the batteries. Solar panels should be situated primarily on brownfield sights and on roofs so that their adverse effects can be minimised. The current proposal is seeking to exploit the lack of a government policy in relation to the use of agricultural land for solar farms, and to fool the local residents by greenwashing. A proposal of this nature should not proceed until the government has set out a policy on the siting of solar farms that is genuinely sustainable and in the interests of future generations."
Members of the Public/Businesses
Debra Guppy
"The size of the project is far too large and will cause visual harm to the area as well as ruining many ancient public rights of way Building solar farms on good agricultural land is madness especially with food security being so critical due to Brexit and the war in Ukraine. Many alternative brownfield sites exist in Essex and have not been investigated by the applicants Battery safety and fire risk are a major concern and surprisingly Essex Fire and Rescue have had no input This is a very rural area with tiny roads and the vehicles and equipment required for construction will be a major issue. Biodiversity will suffer as the ground will be virtually sterilised by the panels It seems short sighted to destroy a large area of farmland and cover it with panels which only produce the same amount of electricity as 2 offshore wind turbines. This is a money making project rather than a green energy scheme. Rural unemployment will increase."
Members of the Public/Businesses
Essex Bridleways Association
"The proposed project includes a north to south green route via a new permissive path. This permissive path appears to be for use by pedestrians only, unless I am mistaken. We believe the new path should not discriminate against other users, and should therefore be available for use by, inter alia, equestrians, and should therefore be designated as a Bridleway. There are c.16 PROW's affected by this development, and there is an opportunity to upgrade the status of this extensive footpath network to allow equestrians to benefit from greater and safe off road access ton the countryside."
Members of the Public/Businesses
Margaret Morley
"We strongly object to this proposal on the following grounds. The land proposed for the erection of the solar panels is prime agricultural land which is desperately needed in view of world events and the uncertainty surrounding imports. This, along with other proposed sites will result in thousands of acres of food producing land which a small country like ours can ill afford. We take issue with the developers that only 34% of the proposed site is BMV land because according to ALC all of the site is grade 2 and therefore BMV. This means that the proposal will put a huge amount of food producing land out of action and negates any environmental benefit. There are other low grade land sites in Essex therefore it is obvious that the developer has not looked at alternatives one site with one owner to deal with is more convenient. Solar farms impact on biodiversity and Natural England recommends avoiding developments near land of high ecological value which this is. We will lose a highly distinctive lowland mixed woodland and whilst the developer has offered compensatory woodland there will still be a resulting loss of habitat. There is a threat to wildlife as the land is currently a rich mix of habitat and the effects of the development will be habitat loss and the fragmentation of habitats which affects smaller breeds in particular. Breeding population of birds, animals and insects will be displaced and lost for ever. Arable farmland currently supports golden plovers, skylarks, lapwings, yellow hammers, linnets and the great crested newts habitat may be directly affected temporarily or on a permanent basis by the development. The report states there has been no literature available on the effect of solar farms on bats. This is simply not true. Two studies have shown a negative impact and Natural England have raised concerns. Nearby there is an SSI. It will change forever the agricultural nature and the landscape of an area we visit regularly. The size of the development means that hedgerows will be too far apart to enable the smaller birds to use them and is far too big for what is essentially traditional rural Essex countryside. Finally, the Lithium ion batteries represent a significant safety risk as well as an environmental risk for the locals."
Members of the Public/Businesses
Mr Douglas Golledge
"Scar on the landscape that along with the Chelmsford Garden village will destroy Essex countryside. Save our countryside. Solar is not efficient in UK climate. Other more carbon neutral power is becoming available and this will be obsolete within 10 years. Desecration of the wild life will be terrible, restricted into a smaller area by the A120, A12 and Chelmsford City there will be nowhere for them to go, from 3500 acres to a few acres!!!! Look to the future and solar in this format is NOT the way to go."
Members of the Public/Businesses
Ms M. Golledge
"Scar on the landscape that along with the Chelmsford Garden village will destroy Essex countryside. Solar is not efficient in UK climate. Other more carbon neutral power is becoming available and this farm will be obsolete within 10 years. Desecration of the wild life will be terrible. Pinned into a smaller area by the A120, A12 and Chelmsford City there will be nowhere for them to go, from 3500 acres to a few acres!!!!"
Members of the Public/Businesses
Samantha Hall
"AGRICULTURAL LAND LOSS - Developers should aim to use areas of poorer agricultural land and show that they have searched for sites that are of low agricultural value and explain why these are not suitable. The setting of land loss, the effect on food security as well as potential job losses due to less farming is a collective loss from the Longfield proposal and will result in the loss of thousands of acres of food producing land. The result will be more food imports at greater cost and with more uncertainty regarding food availability. Based on facts it is reasonable to regard the whole of the site as productive agricultural land. On this basis, planning approval should be refused. It is also obvious the developer has not made a serious attempt to look for or consider alternative sites. The convenience of a single owner and a continuous site has overridden other concerns. In Essex there are over 30,000 ha of poorer grade land providing ample opportunities for alternative sites for solar farm development. BIODIVERSITY AND LONGFIELD SOLAR FARM - Solar farms do impact on biodiversity. In 2019 a survey by BSG Ecology stated “evidence of solar farms impact on biodiversity remains limited. Natural England recommends the avoidance of solar developments in or near to areas of high ecological value. In the same report it was stated that “the lack of evidence available relating to the ecological impact of solar farms is concerning”. “The proposed development results in a loss of 6.35 units of high distinctiveness – lowland mixed woodland, and the provision of lower distinctiveness woodland to compensate for the loss of habitat is contrary to published net gain trading rules”. Overall, the conclusion must be there is a possible damage to biodiversity and the BNG is not valid and does not follow the trading rules as set out in JPO 39. Ecological Survey details are either confidential or not available, so therefore no comments can be provided in this effect. A direct loss to all animal species due to habitat loss, displacement of populations of wildlife due to increases in noise levels and total disruption and inevitable irretrievable damage to their surroundings. The report states “there is currently no scientific literature available on the impact to bats from solar farms”. This statement is not true. There were two studies that showed a negative impact on bats and Natural England concluded research was inconclusive, but raised overall concerns. Noted the potential impact on bats from a disturbance and ultimate loss of their habitats which is mainly agricultural land. The existing site is of significant value with its woodland areas, ponds, proximity of valuable sites and the range of species identified in the surveys. There is a probable negative impact on biodiversity and more ecological study is needed. It would be premature to give approval for large scale solar schemes such as Longfield Solar Farm proposals as after a few years considerable ecological damage could be achieved that would be difficult to correct. Current advice from organisations such as Natural England is to site solar farms away from areas of value. The Longfield Solar Farm site would be classed as an area of value.\r\nLANDSCAPE - Longfield Solar Farm will have a significant impact on the landscape and a visual impact on what is a beautiful part of the Essex countryside. Specified points to note regarding landscape are the fact that the scale and speed required to meet the current and future need identified is likely to have some negative effects on the landscape and visual amenity which may not be able to be mitigated. The scheme would result in the loss of some key characteristics, namely the agricultural character and reduction in the sense of openness given the change of land use. People walking the Essex Way would experience moderate adverse effects. These effects are considered to be significant and directly affects myself and friends and family as we often walk throughout the Essex way regularly, to which is something I do for exercise and mental well-being. NOISE - In the construction phase mitigation appears to be primarily by informing those most affected by the noise when this will happen. Noise and vibration will come from inverters, transformers and switch gear. This is an adverse effect of the scheme. OTHER SIGNIFICANT CONCERNS - Construction Traffic will occur with daily maximum moves of 96 HGVs on the strategic road network of which 50 HGVs would be on the local highway network via Wheelers Hill, Waltham Road and Cranham Road. I travel daily through this area to go to and from work, which will impact on travel time for me personally as well as the disruption to my journey times. There is no reference to the Chelmsford NE by-pass which will cut across the local highway networks during the construction phase. In the construction period there will be 600 workers and the construction will be from 7AM to 7PM Monday-Sunday. Statement of Reasons - Compulsory Acquisition Powers. These are requested as it has not been possible to obtain all interests by agreement. Accepted this may infringe human rights. It is quite clear the construction phase will be very disruptive to local residents. BATTERY SAFETY – Concerns for the significant risks of fire and explosion from thermal runaway from Lithium-ion batteries. The storage for the Longfield site will be one of the largest in the country and near population centres, particularly the proposals for the Chelmsford Garden Village. No reference was made to the recent report produced on a BESS explosion in Liverpool. This explosion at the BESS facility at Carnegie Road, Liverpool was a result of a failure within one of the battery racks in one container which led to a thermal runaway which in turn produced gases within the container culminating in a large explosion. Parts of the container had been blown across the compound to a distance of 23m The main fire took 6 hours to bring under control but the continual recycling of heat from the Li-ion batteries remained an issue and defensive fire-fighting continued on-site for a total of 59 hours. The fire and explosion were deemed to have been caused by the failure of one or more battery units, but the root cause of the battery failure remains unknown. The Liverpool site had only 3 BESS containers (Longfield is multiple enclosures). The report stated there was a significant risk to emergency responders. The Longfield proposals should not be granted a DCO on the basis they are not Carbon neutral, are relatively inefficient and do not accord with the government strategy as set out in the recent energy security strategy namely that large schemes should be sited on lower value land. Overall, the potential loss to agricultural land, animals and wildlife habitat, as well as the detrimental effect on local householders within the immediate and surrounding areas of the proposed Longfield site is too big to comprehend and I believe that no one can actually calculate the damage this will do to the environment both locally and beyond. Alongside the Chelmsford NE by-pass that is currently in construction to run virtually adjacent to the Longfield site and within recent weeks a planning application for a new infrastructure power line that is proposed to be sited over the Longfield site and new road, is in the very worst case devastating to what is a part of Essex’s rich and agronomic land. All three infrastructures of a new by-pass, solar farm and power lines would have an inevitable catastrophic impact to the area in which I live and call home."
Members of the Public/Businesses
Sheila Mary Alder
"The issue of fire and explosion from the BESS proposal is a serious concern for local residents. The proposed BESS is very large and there have been many examples of fire and explosions from such units in the UK and other countries. The proposed site is close to the main railway line, the A12 and residential properties. I am not aware that the developers have applied for any Hazardous Substance planning approval which I understand is needed. Longfield are obviously aware of the dangers associated with BESS units but it is difficult to fully understand their documentation which concentrates on compliance with various codes, design principles and regulation. There are some specifics quoted in the documents eg, water storage. The water quantity quoted would be inadequate for a major fire. Access to the site by fire services would be difficult and residential properties less than 500m from the BESS could easily be affected by any toxic gases released by a fire. As an individual who has lived in the area for many years I believe there will be huge disruption during the construction phase which is scheduled for 2025. The number of vehicle movements together with the number of people working on the site, the hours they will be working and the fact that this could be 7 days per week will all have a significant impact especially as there is only one site entrance. The Inspectorate need to be aware that the construction phase for the solar farm will coincide with the A12 widening and the construction of the Chelmsford NE-bypass. Landscape and visual amenity is another concern which I hope the Inspectorate will consider. The proposed solar farm will be situated on one of the most beautiful parts of of rural Essex. It is close to the city of Chelmsford, particularly the planned Garden Village, and is very well used by walkers and cyclists. These visitors in turn support local businesses, shops and pubs within the parish of Terling and Fairstead. The developers concede that there will be adverse landscape effects from their proposals and they cannot mitigate against them all. I believe the solar farm proposals should be rejected on their landscape impact alone as it will take approximately 20 years for any mitigation measures to have a significant effect. I am also very concerned about the loss of good agricultural land. We lose land to housing and general infrastructure every year but to lose such a large amount of good agricultural land to such an inefficient source of energy production is unacceptable. There are many brownfield sites, wasteland, industrial rooftops and housing rooftops that should be considered before the proposed land which is recognized locally as being very productive. This land should be used to grow crops to feed the population. We cannot afford to become ever more reliant on food imports as the international food chain is increasingly unreliable. I conclude by asking that the Planning Inspectorate do not recommend to the Secretary of State that he grants a DCO. At the very least I would ask that the scheme be significantly reduced in size to minimize the fire dangers from the BESS, landscape and environmental damage plus the loss of valuable agricultural land."
Members of the Public/Businesses
Toby Golledge
"Against Longfield Solar Farm project due to location and substantial concerns about how realistic the figures proposed on longevity are. This time next week, you’ll find me standing in a supermarket car park more than 80-miles away from Westminster leading a protest against plans to build the United Kingdom’s largest solar farm. To give you an idea, the proposed site would be the size of 2,115 football pitches and cover swaths of my Essex constituency in glass and metal sheeting. It is not just the outlandish scale of the development that concerns me and the community I’ve been honoured to represent for more than a decade. For alongside the solar panels, will come giant batteries – some the size of a shipping container – to store electricity for the National Grid. They are a known fire hazard and have no place in any residential setting, let alone a rural village. To be clear, I am a supporter of solar power. I have backed many solar installations in the right place with strong and even enthusiastic local support. As a former Energy Minister, I am a huge champion of renewable energy and I am proud that 99 per cent of the solar panels on the roofs of houses, factories and offices in this country have been installed since 2010 under Conservative governments. But the proposed battery and solar farm in Essex would be a gross intrusion into the lives of my constituents, and a dangerous one at that. The developers, Sunnica, have shown absolutely no regard for the people who live in the area or the devastating effect the proposals will have on their community. The plans envisage a horseshoe of development around several of our villages, turning them from rural settlements into industrial zones. And if you think this is an isolated example, think again. Talking to colleagues in the House of Commons, I’ve discovered that similar solar developments are springing up right around the country. Large oppressive schemes have been threatened with no attempt to site them in the most suitable place, let alone win local support. The heart-breaking events in Ukraine have reminded us of the importance of becoming energy self-sufficient once again. It was encouraging to see the Government announce this week that the UK will phase out the import of Russian oil and oil products by the end of 2022. As we wean ourselves off of Russian gas, it is vital we renew our call for renewable energy – including solar. Large oppressive schemes have been threatened with no attempt to site them in the most suitable place, let alone win local support. Large oppressive schemes have been threatened with no attempt to site them in the most suitable place, let alone win local support. But we must also be smart in how we install it. Let’s put panels on the roof of every new home, let’s put them on factories. But we must not destroy our green and pleasant land in an effort to go green. That’s utterly counterproductive. Worse still, I’ve been advised that the Essex proposal won’t even help our carbon emissions – with estimates suggesting this vast development would pump out more carbon into the atmosphere over its lifetime than it actually saved! This would make a mockery of our net-zero ambitions. There is, bizarrely, no requirement for an independent carbon assessment to be carried out for all such developments. I have asked why – but am yet to receive an answer. Then there is the matter of the giant batteries, which increasingly form part of planned solar developments. These batteries are supposedly there to store the energy generated by the solar panels, but they can also make money for the landowners by storing energy that the National Grid wants to keep for times of high demand. Even the most ardent supporter of renewable energy can surely see that putting a huge battery farm right next to villages is a bad idea. There are significant safety issues, after all, not least the risk of serious fires. The last three years have seen 38 fires at battery energy storage depots around the world. Water is no use for tackling such blazes. Fire authorities have said that once one of those fires starts, there is nothing that can be done to stop it except wait and hope that it does not lead to toxic fumes. We cannot risk this potential hazard harming our health, homes and wildlife. In some cases, the developers of solar farms have tried to hide the fact that their true objective is installing battery storage units rather than panelling without the consent of local residents. Such lack of transparency is an insult to the British public. That’s why I have joined the protest against Sunnica – to save ancient villages and farmland from being changed forever. It is not just the picturesque setting we are set to lose, it is our celebrated history too. The world famous Royal Worlington Golf Course is at risk from the development. There would be a significant impact on Newmarket’s Limekilns – one of the most famous training grounds in the world, and one of the reasons that Newmarket is pre-eminent as the home of horseracing, which is incredibly important. It is not only disappointing but alarming how those behind this proposal have failed to bring the community with them. Sunnica has not, as far as I know, set foot in the villages and towns affected to answer residents’ questions since July 2019. It is striking that when I held a public meeting together with Lucy Frazer, MP for South East Cambridgeshire, Sunnica didn’t bother to turn up. They have treated residents with utter contempt through their arrogant, high-handed manner. Sunnica has refused to meet me. It has refused to attend any public meetings and has been contemptuous and dismissive of my Essex constituents. I thought we were the only one with this problem, but it turns out the same playbook of speculative development around villages is regrettably and shamefully being used elsewhere too. On Wednesday, I attended a debate in Parliament on large solar farms. I was shocked to hear how MPs from all parties, in all parts of the country, had similar tales to tell. Each one of their stories sounded worryingly familiar. The overwhelming majority of MPs and the public believe we need to increase renewables and become more self-sufficient, when it comes to energy. But big developers are damaging the case for renewable energy through their reckless and dismissive approach. We should be championing renewables in a way everyone can be proud of. Proposals for solar farms are often sited on high grade agricultural land around the country, land which should be used for food production, not for battery plants. We must not allow this ‘wild-west’ style approach from developers who, from where I am standing, are simply looking to ram through unsupported projects at the expense of livelihoods and our natural landscapes. In many cases, the planned developments run to within a few hundred yards of people’s homes. Yes, we need to increase our solar provisions, but we must do it in the right places, in already industrialised areas, rather than by harming our precious countryside. Proposals like the ones in Essex should be stopped and sent straight back to the drawing board. To deliver on the noble goal of energy self-sufficiency once again, we need to bring people with us by engaging with constituents rather than treating them like mere inconveniences. I urge not just my constituents but people right across the country to protest against these and other such damaging proposals. It is time our voices are finally heard."
Members of the Public/Businesses
Jackie Gregory
"We are objecting to this proposal because of the following: We believe it to be in the wrong place, taking good farm land that already produces crops, we need this more than ever especially due to the Ukraine war, We have been here for more than 20years and seen crops produced from wheat to potatoes. The most important thing is to be able to feed ourselves. The adverse impact it will have on our live; the traffic impact will be constant and unacceptable. It will be immediately in front of our house/windows. It will be better to find a site that had a more suitable infra structure to handle the traffic. Further impact will be made by constant noise pollution, traffic pollution which will impact on our health (as an asthmatic) Farm land should be used for farming not farmers being paid for this type of use . It will destroy the ecological and environmental balance of this area for years to come."
Members of the Public/Businesses
Merlin Wynne-Golledge
"hello, i am very much against this project. its simply not needed and will cause more harm than good to the surrounding areas. this part of the country side is beautiful and un touched by us, this is what we need to save and preserve, not destroy and build on. whats the point in bulding a solar farm to save the enviroment when you destroy the enviroment anyway. the solar farms are not carbon nuteral, its proven that there are plenty of other options that are more efficient in building and producing power. another point is the land its on is very valuable and will be more benifical to the area and local towns to be used as farm land as has been for the past."
Members of the Public/Businesses
Neil Leigh-Collyer
"I wish to strongly oppose the Longfield Solar Farm application. Greg Baker stated we must be thoughtful and sensitive to public opinion, and mindful of the wider environmental and visual impacts (of solar farms)’ LSF will not follow his advice. Solar farms are hugely inefficient compared to off shore wind farms. There will be disastrous consequences for the landscape and local amenity which will be a cumulative effect and will intensify the harm. Significant harm to heritage assets. BMV land should not be used for industrial purposes - will decrease arable land and increase need for imported food. Not environmentally friendly - transitory animals have their traditional routes blocked, deer directed onto road (which is already a problem). Bird and bat deaths from reflection of panels. Land degradation - half land in shadow, water run offs affected.\r\nNeighbouring property harmed by secured boundaries and intrusive CCTV. Solar farms are unsightly and will damage the wonderful countryside that is part of the proposed site of Longfield. I strongly oppose the Longfield Solar Farm."
Members of the Public/Businesses
Nicholas John Whiteley
"Objection on the grounds of mis appropriate use of prime agricultural land and the environmental impact, disruption etc"
Members of the Public/Businesses
Essex Local Access Forum ELAF
"1) The development should conform to NPPF paragraph 100 at all stages. 2) The development should conform to the Overarching National Policy Statement for Energy EN-1 Draft consultation document September 2021, in particular to Paragraph 5.11.23 3) Development Consent Order (DCO), Schedule 6, Part 2 details… “Public Rights of Way to be temporarily stopped up” BUT there is NO diversion. Stopping up with no alternative route is NOT acceptable - a suitable and convenient alternative route must be provided 4) There must be a safe route where PROWs & the primary and secondary construction access tracks appear to be contiguous. Where the construction access tracks cross PROWs, the crossings must remain passable on foot and be well signed so that construction vehicle driver’s are aware. 5) The fencing around the solar panels must be set back from the PROWs – as per the 5 metre offset proposed in the 2021 consultation. The fencing and the proposed plant / warehouse building must be softened by planting. 6) The proposed north – south green route /geenway is welcome but it should be a multi-user route available for ALL users - walkers, cyclists, runners, horse-riders and mobility impaired / wheelchair users. There should be no stiles or gates across the route. This route and the permissive paths should be a permanent addition to the network. 7) Monies to cover the decommissioning costs should be deposited in a safe account / as a bond as much can happen to companies in 40 years. 8) As Cranham Road & Wheelers Hill are within the Order Limits, measures to increase the safety of walkers, cyclists, runners and horse-riders using these west-east roads should be part of the widening works. 9) There is no longer any means of crossing the railway line and the A12 at south end of Boreham FP 21 [213_21]. A new PROW bridleway connection is requested west & north-east, within the Order Limits of the cable route corridor; west with Boreham Bridleway 48 [213-48] and north-east to Boreham PROWs 20 & 19 [213_20 & 213_19]."
Members of the Public/Businesses
Laurie Wood Associates
"I wish to object to the scale of the proposed solar farm development. The scale of the development will result in the loss of higher quality agricultural land. The applicant has failed to demonstrate that alternative, lower grade agricultural or brown-field land is unavailable and, therefore, to justify the loss of Best and Most Versatile land for up to 55% of the proposed development area. The scale of the development will be to the detriment of the amenity of residents of Terling and Fuller Street and the surrounding landscape character. The construction-phase impacts and the scale of development, particularly on to its northern edge, is contrary to Braintree District Council policies ADM50 & 53 in that the height of the proposed arrays and the associated features [perimeter fencing, CCTV masts] will degrade the Ter valley and the setting of ancient woodland. The applicant's own assessment notes moderate adverse to significant effects on landscape visual amenity, and a reduction in the sense of openness due to the impacts of the arrays [height of] and associated fencing. The proposal should not be granted a Development Consent Order in its current form and scale as it does not accord with the government's energy security strategy [BESS April 2022, p.19]. The location is not on previously developed or lower value [agricultural] land. The proposal does not demonstrate mitigation or compensation for the impact on this greenfield site."
Members of the Public/Businesses
Matthew Lewen Tugwell
"My main concern is the sheer size of this scheme. Why does it have to be so large in this 1 particular location of high quality farm land when there is lesser quality land that could be used. The impact for crop production for future generations is a concern. I also feel the efficiency of solar power is questionable. The carbon footprint for installing the farm and infrastructure is much higher than we are led to believe. Wind and wave power are much more efficient and don’t affect crop production The need for maintaining our own crop production, especially wheat/corn has become a lot more important especially in view of what is going on in world news. Other concerns include: 1. Safety of battery storage 2. Impact of construction work 3. Impact on wild life with CAREFUL PLANNING we can achieve our re-newable energy goals WITHOUT MAKING POOR SHORT TERM CHOICES . Please please bear this in mind. A much smaller scale solar farm really should be considered. I understand the need for local farmers/land owners to diversify especially in terms of diminishing subsidies however the sheer size of this solar farm needs to be seriously questioned."
Members of the Public/Businesses
Timothy David Hancock
"The Secretary of State should not be recommended to approve the proposals since it has not been demonstrated that the application site represents the optimum location for the proposals even if it can be demonstrated that there is any need for these facilities within a properly developed national plan. The site selection is based on the convenience of the ease of site assembly arising from the control that the current landowner enjoys over an extensive holding. A policy based approach should be developed for the allocation of sites for solar power generation to allow the adoption of a principled method of site selection and development plan allocation. Green field agricultural land and open countryside should be protected in this hierarchy. This approach should take account of both existing and potential contribution to regional and national food security and the harm to the open countryside as well as the additional development pressures that will arise over time as a result of the creation of extensive areas of new brownfield land. Preference should be given to existing brownfield sites and roof allocations. Reducing development costs will compete profitability away to landowners. The site has been selected on an opportunity basis; the proposals are not considered coherent. To say "here is a site we can use let's bring it forward" makes a mockery of the planning system". Evidently the estate considers it appropriate to scale back food production at a time when food security should be a key national priority. Sheep grazing would represent a sub-optimal and incidental use of this land even if it can be demonstrated to be sustainable given the issues of fertilising it. The large scale of the harm over an extensive area in this case outweighs any benefits and the proposals should be refused. There are no particular benefits that arise in using this particular site for the proposed use that justify the consequential harm and blight that would arise."
Other Statutory Consultees
Jacobs on behalf of National Highways
"1 Summary Position 1.1.1 This response represents our formal representations with regards to the Development Consent Order (DCO) submission. In order to formulate this response, we have undertaken a detailed review of the DCO submission and the supporting information which includes the documentation relating to traffic, the construction phase of the scheme and the location and use of compounds, as follows: • Framework Construction Traffic Management Plan (CTMP) • Outline Construction Environmental Management Plan (CEMP) • Environmental Statement (ES) Chapter 13: Transport and Access • ES Appendices 13A and 13B. 1.1.2 For the purposes of clarity, National Highways interests relate solely to the construction phase of the Longfield Solar Farm (LSF). Having reviewed the DCO documentation, we are satisfied that there are no significant adverse transport implications for the SRN once construction is complete and the scheme is operational. 1.1.3 National Highways concerns regarding the construction phase, relate to the proposed A12 to A120 Widening Scheme (A12 Scheme) which is a Nationally Significant Infrastructure Project (NSIP) preparing for a Summer 2022 submission. National Highways has identified a number of areas from ongoing discussions with Longfield Solar Energy Farm Ltd and associated DCO documentation which remain to require clarification and agreement between parties. The matters on which National Highways requires further information and/or clarification are set out below in each relevant section and listed in full at the end of the document. 1.1.4 On receipt of clarification requested, National Highways may seek requirement(s) to be imposed by the DCO to manage the impact of the construction phase, particularly relating to A12 Scheme use of the private road from the Radial Distributor Road (RDR) during construction. These requirements will be detailed in our Written Representations at the Examination stage. 1.1.5 National Highways are currently negotiating Statement of Common Ground (SoCG) with the applicant as expeditiously as possible to agree our requirements. This will be submitted to the Planning Inspectorate prior to Examination. 2 Development Consent Order (DCO) proposal 2.1.1 Longfield Solar Energy Farm Ltd has been working to promote a scheme to provide solar farm with energy storage which will generate and store renewable electricity for export to the National Grid. 2.1.2 The DCO sets out a list of consents being sought by Longfield Solar Energy Farm Ltd. Those relevant to National Highways include Framework Construction Traffic Management Plan (CTMP), Outline Construction Environmental Management Plan (CEMP), Environmental Statement (ES) Chapter 13: Transport and Access and ES Appendices 13A and 13B. 3 Strategic Road Network (SRN) 3.1.1 The development proposal is parallel to the A12 between junction 19 and junction 20a. The closest point the scheme comes to the A12 is some 30m to the north of the A12. It is proposed within LSF’s DCO that during construction the main access route to the site with be Waltham Road via Cranham Road, though other access routes will be used to access Bulls Lodge Substation via Boreham Junction/RDR. 4 Pre-application Consultation 4.1.1 Early discussions began in June 2021 with Longfield Solar Energy Farm Ltd to gain an understanding on the access strategy and routing strategy and begin initial scoping discussions for each DCO's Transport Assessment (TA) and Outline CTMP. 4.1.2 Continuous meetings have since occurred between National Highways and Longfield Solar Energy Farm Ltd to discuss potential cumulative impacts, construction traffic management, SRN impact and capacity assessment and SoCG. 5 Statement of Common Ground 5.1.1 National Highways are working with the Longfield Solar Energy Farm Ltd to progress a SoCG, which will be submitted to the Planning Inspectorate prior to Examination. The SoCG will cover areas of assessment that remain to be agreed and accepted, notably those concerning the construction phase and any necessary requirements. 6 DCO Transport Assessment (February 2022) 6.1.1 The TA for LSF has been produced by AECOM on behalf of Longfield Solar Energy Farm Ltd, dated February 2022. It can be found ES, Appendix 13A: Transport Assessment. 6.1.2 The TA presents an assessment of the transport impacts of the scheme during construction, operation and decommissioning phases. 6.2 Construction sites, site compounds and access routes 6.2.1 The strategic highway impacts during LSF construction, are reported in Environmental Statement, Chapter 13: Transport and Access and the Framework CTMP. 6.2.2 As mentioned in the Framework CTMP and shown in ‘Appendix B – Surrounding Highway Network’, LSF proposes to utilise a private road via Boreham Interchange/RDR for Bulls Lodge Substation compound and construction. The A12 Scheme also proposes to utilise this private road’s access for construction purposes including a haul route, compound and lay down area and soil storage. Effort is being made between both parties to ensure the private road is shared between both schemes during construction. 6.2.3 However, there remains uncertainty with regards to the status of the private road. The private road is currently owned by Countryside Zest (Beaulieu Park) LLP and is expected to become an adopted highway upon completion of the Beaulieu Park development, the timing of which is unknown. Prior to the adoption of the highway, it is still to be agreed which entity will act the Principal Contractor, therefore highway rules to be complied with remain uncertain (i.e. speed limits, access controls). National Highways and LSF are working together to agree and establish this in the SoCG. 6.2.4 National Highways are seeking to ensure access is retained from the RDR/private road to access A12 order limits for proposed haul route, compound and lay down area and soil storage. National Highways will seek to implement this as a requirement within LSF DCO if necessary. 6.3 Construction traffic movements 6.3.1 As mentioned in the TA, LSF construction period is 2024-2046, peak construction in 2025. The A12 Scheme construction programme and peak construction of 2025 mirrors that of LSF. It is noted within 3.5 of the Framework CTMP, that the A12 Scheme’s construction will begin in 2025, however it is 2024-2027. 6.3.2 As mentioned in paragraph 6.2, LSF will utilise Boreham Interchange, which at the time of their construction will be the responsibility of National Highways. There is estimated movement total of 92 HGVs and 188 vehicles per day at 2025 peak construction. 6.3.3 Within paragraph 5.4 of LSF Framework CTMP, it states there is expected to be no daytime closures at Boreham Interchange during the A12 construction, which National Highways can confirm is correct for Monday-Friday with weekend closures occurring for the structure. However, on Boreham Bridge, lanes in both directions will be narrowed to enable extension works on the northside of the bridge. Similarly, the mainline on the existing A12, will be narrowed, pushing traffic away from the verge towards the central reservation. 6.3.4 The narrowing of lanes may have an impact on LSF HGV movement, particularly abnormal loads, therefore National Highways suggest Longfield Solar Energy Farm Ltd should be reflect this highway constraints within the detailed CTMP. 6.4 Operational Traffic Impact 6.4.1 The strategic highway impacts once the scheme is operational, are reported in Environmental Statement, Chapter 13A: TA, chapter 6. Proposed Trip Attraction and Distribution. 6.4.2 The TA states that a maximum of eight vehicles (or 16 daily two-way vehicle trips) are expected daily. This number of trip will be negligible on the SRN and therefore National Highways have no comment at this time. 6.5 Decommissioning Traffic Impact 6.5.1 The strategic highway impacts once the scheme is at the decommissioning phase, are reported in Environmental Statement, Chapter 13: Transport and Access. 6.5.2 LSF documents state that the decommissioning assessment year is assumed to be no earlier than 2066 and is expected to be similar in duration and nature to the construction phase, albeit slightly shorter in duration and with fewer vehicle trips. 6.5.3 Therefore National Highways have no comment at this time. 7 Summary and Further Information Required 7.1.1 National Highways do not object to the LSF application subject to agreement on the use of the private road via Boreham Interchange/RDR and clarification on the Principal Contractor, conversations for which are ongoing. 7.1.2 It is noted by National Highways that a separate CTMP will be prepared for the A12 Chelmsford to A120 Widening Scheme (7.2.5 Framework CMTP). In addition, National Highways are scheduled to share the A12 Scheme Outline CMTP with Longfield Solar Energy Farm Ltd prior to submission. 7.1.3 We look forward to working with the applicant in respect of agreeing the SoCG."
Other Statutory Consultees
response has attachments
Historic England
"Please see attached."
Members of the Public/Businesses
response has attachments
Deborah Brown
"Please see attached."
Members of the Public/Businesses
Ramblers-Essex Area - Braintree District Footpath Secretary
"These comments are specific to Braintree District and are in addition to the comments submitted by Ramblers Essex Area - Walking Environment Officer [Interested Party reference number 20031536] 1) Development Consent Order (DCO), Schedule 6, Part 2 details… “Public Rights of Way to be temporarily stopped up” BUT there is NO diversion. FC-T1, FC-T2, FC-T3, FC-T4, FC-T5, FC-T6, FC-T7 and FC-T8 are all stopped up for cable works. Stopping up with no alternative route is NOT acceptable as it disrupts the PROW network. A suitable and convenient alternative route must be provided during the cable works. 2) It is not clear how pedestrian/walker and vehicle interactions will be managed where PROWs & the primary and secondary construction access tracks appear to be contiguous e.g. Terling FP 32 [113_32] and Terling FP 30 [113_30]. There must be a safe route for walkers. Similarly where the construction access tracks cross PROWs, the crossings must be well signed so that construction vehicle driver’s are aware and the PROW crossings must remain passable on foot. 3) The fencing around the solar panels must be set back from the PROWs – a 5 metre offset was proposed in the 2021 consultation. The fencing must be softened by planting but NO advanced planting is shown along several PROWs where it is proposed to site solar panels on both sides of the footpaths e.g. Terling FP 33 [113_33], Terling FP 25 [113_25], Terling FP 30 [113_30], Terling FP 32 [113_32] . The proposed permissive paths are not shown in the Advanced Planting Plan (ES 6.3 Figure 10-14)."