Little Crow Solar Park

The views expressed in this page do not represent those of the Planning Inspectorate. This page consists of content submitted to the Planning Inspectorate by the public and other interested parties, giving their views of this proposal.

Little Crow Solar Park

Received 26 February 2021
From Natural England

Representation

Relevant Representation PART I: Summary of Natural England’s advice. No outstanding concerns other than Best and Most Versatile Soils PART II: Natural England’s detailed advice 1.1. Natural England’s advice in these relevant representations is based on information submitted by INRG SOLAR (Little Crow) Ltd in support of its application for a Development Consent Order (‘DCO’) in relation to Little Crow Solar Park. 1.2. Natural England has been working closely with INRG SOLAR (Little Crow) Ltd to provide advice and guidance since 31 January 2018 through our Discretionary Advice Service. A Statement of Common Ground was drafted between the Applicant and Natural England in April 2020, however this needs to be updated. Natural England would be pleased to work with Applicant to produce this. 1.3. These relevant representations contain a summary of what Natural England considers the main nature conservation, landscape and related issues to be in relation to the DCO application and indicate the principal submissions that it wishes to make at this point. Natural England will develop these points further as appropriate during the examination process. It may have further or additional points to make, particularly if further information about the project becomes available. 1.4. Natural England has worked successfully with INRG SOLAR (Little Crow) Ltd and there are no substantive outstanding matters. 2. The natural features potentially affected by this application 2.1. The designated sites relevant to this application are: 2.1.1. The Humber Estuary Special Protection Area (SPA), Special Area of Conservation (SAC) and Ramsar site. 2.1.2. The Humber Estuary Site of Special Scientifc Interest (SSSI), Broughton Far Wood SSSI 2.2. The following areas of non-designated but valuable countryside that could be affected: Best and Most Versatile Soils 2.3. The main issues raised by this application are: 2.3.1: Soils and Agricultural Land Classification Under the Town and Country Planning (Development Management Procedure) (England) Order 2015 (DMPO) Natural England is a statutory consultee on development that would lead to the loss of over 20ha of ‘best and most versatile’ (BMV) agricultural land (land graded as 1, 2 and 3a in the Agricultural Land Classification (ALC) system, where this is not in accordance with an approved plan. 2.3.2 Natural England welcomes para 10.3.10 of the Preliminary Environmental Information (Vol1) which makes it clear that a full soil survey will form part of the final application submission. The final Environmental Statement should provide details of how any adverse impacts on soils can be minimised. 2.3.3 From the description of the development this application may impact on ‘best and most versatile agricultural land’. We consider that the proposed development will note necessarily lead to lead to significant long term loss of best and most versatile agricultural land, as a resource for future generations. This is because the proposal can be designated in such a way to avoid significant losses, for example the solar panels can be secured to the ground by steel piles with limited soil disturbance and could therefore be removed in the future with no permanent loss of agricultural land quality likely to occur, provided the development is undertaken to high standards. 2.3.4 Although some components of the development, such as construction of a sub-station, may permanently affect agricultural land this would be limited to small areas. 2.3.5 However, during the life of the proposed development it is likely that there will be a reduction in agricultural productivity over the whole development area. Your authority should therefore consider whether this is an effective use of land in line with planning practice guidance which encourages the siting of large scale solar farms on previously developed and non-agricultural land. Paragraph 170 and 171 of the National Planning Policy Framework (NPPF) states that: ‘Planning policies and decisions should contribute to and enhance the natural and local environment by: recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland.’ And Plans should: distinguish between the hierarchy of international, national and locally designated sites; allocate land with the least environmental or amenity value, where consistent with other policies in this Framework2; take a strategic approach to maintaining and enhancing networks of habitats and green infrastructure; and plan for the enhancement of natural capital at a catchment or landscape scale across local authority boundaries. 2.3.6 Local planning authorities are responsible for ensuring that they have sufficient information to apply the requirements of the NPPF. The weighting attached to a particular consideration is a matter of judgement for the local authority as decision maker. This is the case regardless of whether the proposed development is sufficiently large to consult Natural England. 2.3.7 Should you have any questions about Agricultural Land Classification or the reliability of information submitted with regard to BMV land please consult Natural England's Technical Information Note 049 on Agricultural Land Classification. This document describes the ALC system including the definition of BMV land, existing ALC data sources and their relevance for site level assessment of land quality and the appropriate methodology for when detailed surveys are required. We would also draw to your attention to Planning Practice Guidance for Renewable and Low Carbon Energy (March 2014) (in particular paragraph 013), and advise you to fully consider best and most versatile land issues in accordance with that guidance. General guidance for protecting soils during development is also available in Defra’s Construction Code of Practice for the Sustainable Use of Soils on Construction Sites, and should the development proceed , we recommend that relevant parts of this guidance are followed, e.g. in relation to handling or trafficking on soils in wet weather. ? Part II: NATURAL ENGLAND’S RELEVANT REPRESENTATIONS IN RESPECT OF LITTLE CROW 3. Planning Inspectorate Reference: RM/P17-0718 3.1. Natural England has no objection to the project for the following reasons: 3.1.1. The applicant has submitted a thorough Environmental Statement which we are satisfied demonstrates beyond reasonable scientific doubt that there would be no significant effect on the integrity of the European site. 3.1.2. Natural England is satisfied that the project is unlikely to have a significant impact on the nearby Humber Estuary SSSI or Broughton Far Wood SSSI. 3.1.3. The project site currently supports habitats of negligible ecological interest and all protected species issues (including any licensing requirements under the Habitats Regulations or the 1981 Act) can be addressed by the proposed draft DCO requirements. 3.2. Natural England’s advice is that in relation to identified nature conservation issues within its remit there is no fundamental reason of principle why the project should not be permitted. 3.3. Natural England’s headline points are that on the basis of the information submitted: 3.3.1. Natural England is satisfied with the conclusions reached in paras 7.4.4 to 7.4.6 of the Preliminary Environmental Information (Vol1) that the proposal is unlikely to have any direct impacts on the Humber Estuary designated sites and that the proposal site is not likely to be functionally linked to the designated site for mobile species which are qualifying features of the designations. 3.3.2. Natural England is satisfied with the assessment of Broughton Far Wood SSSI and welcomes the mitigation measures set out in section 7.6 of the Preliminary Environmental Information (Vol1). Provided that appropriate avoidance and mitigation measures are addressed in the Construction Environment Management Plan (CEMP) we are content the proposed operations are not likely to damage the interest features of Broughton Far Wood SSSI. 3.3.3. Natural England notes that the proposal site and access route via B1208 both lie adjacent to land identified as Far Wood Ancient Replanted Woodland on the Ancient Woodland Inventory (for more information see the gov.uk website at https://www.gov.uk/guidance/ancient-woodland-and-veterantrees- protection-surveys-licences). Natural England is satisfied that, on the basis of the information provided, that adequate measures will be put in place to protect the neighbouring ancient woodland, i.e. buffer zones and woodland planting. We are satisfied with the mitigation measures set out in section 7.6 Preliminary Environmental Information (Vol1). Natural England 26 Feb. 21