Rampisham Down Transmitter Station from Hot Air Balloon
Despite the sun shining upon us for much of the late Spring and Summer, the Solar industry has not had such a happy time of it.
Eric Pickles has decided he doesn’t like solar farms, possibly because of their impact on the landscape, possibly for some other reason. His failure to decide why he doesn’t like them caused his move to block a Suffolk Solar farm to be thrown out by the high court.
The bigger threat to Solar Farms comes from the Government’s proposal to withdraw Renewable Obligations support for 5MW or larger Solar Farms as of April 2015. The Solar industry are lobbying to have the proposal abandoned.
Solar Farm Best Practice for Biodiversity
The Solar Trade Association, perhaps stung by criticism that there are Solar Farms popping up everywhere spoiling the view (or worse) has come up with 1o commitments to best practice. Commitment 2 states that “we will be sensitive to national….conservation areas, and we welcome opportunities to enhance the ecological value of the land”.
To show their sensitive side, the Solar Industry have come up with some best practice guidance for biodiversity and solar farms. The BRE National Solar Centre Biodiversity Guidance for Solar Developments, has – I am somewhat surprised to see, been endorsed by a wide range of conservation NGOs. If I had been asked to endorse a piece of industry promotional material, I would have wanted to be very clear that I was happy about what it was saying.
The BRENSC guidance says a lot of good things about enhancing agricultural land that has lost its value for biodiversity, when building Solar Farms. So far so uncontroversial. It’s what it says about existing high biodiversity sites that is more interesting. For instance should a Solar Farm ever be built on a Special Protection Area (Birds Directive)? The STA says SPAs are “very unlikely to be appropriate” for Solar Farm development, though even this is caveated with “depending on the designated feature”. I can’t really think of any SPA designated feature where a Solar Farm would be appropriate. Since the qualifying features for which SPAs are designated are wild bird populations, none to my knowledge benefit from having large glass panels on posts stuck in their habitats, along with the artificial lights, security fencing, buildings, tracks and all the other infrastructure of Solar farms.
For SACs and SSSIs it only says “unlikely to be suitable”. Why differentiate between SPAs and all other designations? Are birds more likely to be upset by having a Solar Farm built in their Special Protection Area? Would bats find it easier to navigate through the array of panels than birds? Would habitats benefit from having thousands of glass roofs and metal posts stuck into them? No, I think it’s more likely that the RSPB drove a harder bargain when negotiating about whether their logo would appear on the booklet, than the other NGOs.
For Section 41 species and habitats – these are the Priority Habitats and Species or Habitats and Species of Principal Importance, basically the UK habitats and species which are highest priority for conservation, the guidance says that the presence of these features “should guide the appropriateness of solar developments to avoid harm to these interests”.
For SNCIs (Local Wildlife Sites) and undesignated semi-natural grasslands it says that an ecologist should be consulted “to avoid damage to such sites.” This is confusing though because all undesignated semi-natural grasslands would already qualify as Habitats of Principal Importance, as do many SNCIs.
I think this is all exceptionally weak and mealy mouthed. For an industry that seeks at every opportunity to portray itself as “green by default” it should be setting a high standard when it comes to impact on wildlife. The guidance should be unambiguous and say that solar farms should never be developed on sites with statutory protection, or on priority habitats unless it can be shown that there will be no impact on their natural value. For SNCIs there should be a strong presumption against development of Solar Farms, indeed many local authorities already have similar policies for other forms of development, within their local plans.
How can all these NGOs sign up to an industry document that states in black and white that SSSIs are only “unlikely to be suitable” for Solar Farms – come on NGOs. How would they have reacted to a proposal from, eg, the House Builders Federation, to sign up to industry guidance on housing that stated that SSSIs were “unlikely to be suitable” to housing development?
Return To Rampisham (Ransom)
The Solar Trade Association which produced the biodiversity guidance has amongst its membership British Solar Renewables, which you will recall, proposes developing a Solar Farm on Rampisham (locally known as Ransom) Down in Dorset. Rampisham was designated as a SSSI on account of its large area of unimproved acid grassland. Indeed BSR were recently part of the Solar Trade Association’s publicity event “Independence Day” and held an open day at their Crossways Solar Farm here in Dorset.
I might be misunderstanding this, but if BSR are a member of the Solar Trade Association, and the STA requires its members to abide by the 10 commitments, which includes being sensitive to national conservation areas (such as SSSIs) then isn’t BSR in direct breach of this code of practice?
That’s the trouble with voluntary codes of practice; they are just voluntary – will anyone police them?
British Solar Renewables’ first Solar Farm is on its founder, Angus MacDonald’s, family Farm, Higher Hill Farm, on the hills above the Somerset Levels. This array is just about 5MW in size, and would have cost around £5M to build, perhaps a bit less. It earnt BSR nearly £500,000 last year in electricity production and solar subsidy. So for this farm at least, the return is 10% per annum – pretty good by anyone’s standards.
In 10 years the Solar farm has paid for itself, and for the remainder of its active life it is generating clear profit. You can see why BSR were so enthusiastic to install a much larger array at Rampisham, to such an extent that they were happy to ignore or deny the environmental impact. Although MacDonald won Best Cider Orchard at the Bath and West Show this year, the remainder of Higher Hill Farm appears (from Google Earth) to be in intensive maize production. Perhaps this Maize is sold into the “ecofriendly” biogas market at a large profit. And of course it’s just another area of Maize contributing to the problems of the Somerset Levels.
Current proposals for Rampisham indicate a 24MW output, which should generate an income of nearly £2.5M a year. Even if BSR paid through the nose for Rampisham, the electricity and subsidy will still have paid for the land and construction costs and be in straight profit in 12-15 years. With the guillotine potentially coming down on subsidies for large (>5MW) Solar Farms next April, you can see why BSR are so keen to get their planning permission for Rampisham as quick as possible (despite the fact that it is now a SSSI).
Now that Rampisham is an SSSI, BSR are trying to persuade the local planning authority that their Solar Farm won’t damage the SSSI interest features, because they will space the panels out a bit more, tip them up so they create less shadow, and put some clear glass in the panels to let the light through. They are even doing some experiments to see just how biodiversity friendly these new panels are.
the new grass-friendly holey solar panels are still very opaque (this view from underneath, from a BSR report)
Now you or I might think it blindingly obvious that if you cover a large area of unimproved grassland with what are effectively a combination of roofs and windows, it might alter the floristic composition of the grassland. But no, BSR’s planning consultants argue that there is no evidence to support NE’s view that the Panels will have an adverse impact on the SSSI grassland. It’s true, in the same way as there is no scientific evidence based on experiment, that unimproved grasslands would suffer any damage from being covered in custard, or used for the UK annual lawnmower-racing championships. Or having alien spacecraft land on them.
BSR have set up a “test plot” to test their new holey panel and have already been monitoring them for a whole 39 days. They have erected three arrays, each with 40 solar panels (10 x 4). Then they are going to monitor the light, moisture and so on under and around the panels. They will also monitor the vegetation under the panels and nearby in unshaded areas. Given that the grassland on the site is quite varied over the whole site, I would have thought a proper experimental set up would have reflected this and included a number of replicates on different grassland types, covering slope, aspect, soil depth etc. 4o replicates perhaps? 3 seems wholly insufficient.
In 39 days of continuous recording they have found that the soil moisture under the panels is 47% higher than in the open, while soil temperature is 16% less under the panels. In other words under the panels it is cooler and damper. They have also been monitoring sunlight in the frequencies that plants use. They have found that shade directly under the panels receives 20% of the light compared to an unshaded spot, 34% at the back edge of the panels, and 88% between the panel rows.
So let’s just summarise their findings. Under the new holey panels, it’s
- much damper,
- quite a bit cooler
- much darker
than in the open. And this is during the critical time of year for plant growth, the late spring and early summer.
Now if I were thinking, what would happen to a grassland that became 4 times shadier than it had been, nearly half as much again damper, and 20% cooler, I might think it would turn into something very different. Much more bryophyte growth for starters, and I would expect it to get grassier, with fewer herbs.
Needless to say, in 39 days they haven’t found any change in botanical composition of the grassland under the panels, or indeed between the panels. But then they have only monitored the vegetation plots once, so they wouldn’t find any change anyway.
I was very surprised that these monitoring plots will be excluded from grazing. Why? Surely grazing is a critical element of grassland management, whether under panels or in the open. At the very least plots should be monitored grazed and ungrazed. How would livestock react to the panels? They might prefer grazing under the panels, or they might prefer grazing away from the panels, or they might not differentiate between the two. Who knows? Would sheep not take shelter under panels in the rain? Would they preferentially poo there? There are many impacts which would result from placing solar panels on unimproved grassland, far beyond how much light gets through them. None of these are being assessed in this experiment.
Despite all these limitations, BSR ecological adviser John Feltwell has felt the need to carry out a technical assessment to review the results of the monitoring programme set up by BSR. Presumably he thinks this review will lend the experiment scientific credibility. He has decided that the experiment is not only very scientific, but is already showing results. After 39 days.
His scientific review rapidly heads off into the long grass though.
“A baseline condition predicted to occur on site, in the absence of solar development, would be that the site would be overrun by Bracken, a succession process that has already started.”
This remember is supposed to be a technical assessment of the experiment. Feltwell seems keener to tell Natural England the site will only get managed if BSR get their Solar Farm. Indeed he is only repeating what BSR owner Angus MacDonald said at the SSSI confirmation hearing.
Now one could argue, from an ecological perspective, that, in the absence of any grazing, the site would eventually develop into Oak and Beech woodland on the plateau with some Ash woodland on the slopes. One could argue that, with the reintroduction of extinct megafauna, Rampisham Down could develop into a dynamic mosaic of mature woodland, woodland glades and rides naturally maintained by passing elephants. Or one could argue that Rampisham Down could continue to be managed as a Downland (a clue in the name) through the grazing of domestic livestock, as it has been for millennia.
From an ecological perspective, one would not normally include externalities such as Solar Farms being built, nor nuclear waste facilities, rocket launching stations or Theme Parks.
Remember the data which showed the area under the panels getting darker, cooler and wetter?
Feltwell dismisses the findings of the first 39 days of monitoring, on account of
1. It being too sunny – “the normal weather at Rampisham is generally cloudy” he states. Actually Rampisham is one of the sunniest spots in the whole country (over 1600 hours a year), which is exactly why BSR want to build a massive Solar Farm there.
2. Recordings were made around Midsummers day when incident light onto the unshaded areas was at its greatest. In other words the days were too long.
While this is true, it doesn’t deflect from the reality that at the height of summer, when the plants are growing and flowering, they will be in the dense shade of the panels and they will be cooler and darker than otherwise. In any case it was quite within BSR’s powers to set up the experiment to run at another time of year, – or over perhaps a whole year, or even several years, before pontificating about what the results might mean.
Regardless, Dr Feltwell concludes that based on 39 days of physical data, which he has ignored,
“there is evidence there is a trend towards evidence indicating less harm to the suite of plants that comprise the notified SSSI flora than might otherwise have been found with traditional panels.”
This is of course arrant nonsense. Not only does it make no grammatical sense, but it makes no ecological sense. There has been no measurement of change in the floristics of the grassland under the panel, near the panel or flying past the panel on the back of an aerial pig. There is only one data point. Where is the trend?
Even if after several years of monitoring it had been found that there was a difference between the grassland under the holey panels compared with the traditional ones, this also has no bearing on the important question – will erecting hundreds and thousands of solar panels on an SSSI grassland cause it damage? If it is just a little bit less damaged as a result of the new improved flower-friendly panels, it is still damaged.
What is even more extraordinary is that former Director of Kew gardens Professor Ghillean Prance, puts his name to a foreword to this travesty. Prance states that “Rampisham Down is a severely damaged area of grassland.” and that Solar Farms “increase biodiversity rather than diminish it.” It’s a pity Prance didn’t turn up to the SSSI confirmation hearing – I would have enjoyed debating these points with him. Prance is a very devout christian and feels a strong ethical duty to protect the environment, a duty derived from his faith. I guess those ethics don’t extend to unimproved acid grassland.
Perhaps Prance is a purist re-wilder; and that all unimproved grasslands, heathlands, lowland raised mires, fens and blanket bogs are severely damaged habitats; and that only Holocene Forest is the real undamaged habitat of Britain. Or perhaps he believes that the Holocene Forest was also severely damaged habitat, on account of the Elephants and Rhinos that were hunted to extinction in the Pleistocene preventing them from returning at the end of the last Ice Age. I think we should hear what Prof Prance really thinks. We know the bible is his “final authority“. What does it have to say about unimproved acid grassland?
I sense that the ecological consultants tasked with jumping through these hoops, Landmark, are squirming with embarrassment at all this. They were asked to undertake a literature review of the evidence that solar panel shading causes damage to grasslands. Naturally there was no literature to review – and sensibly they concluded there was no evidence that making solar panels a bit more transparent would make any difference to their impact on the grassland.
They were also asked to investigate opportunities to enhance the Rampisham grasslands. They suggested a move from sheep grazing to cattle grazing. I think this is absolutely right, Rampisham has been only sheep grazed for years and the sward has reacted to that grazing. Cattle would open up the sward and create bare ground for flowers to seed into. Unfortunately cattle and solar panels do not mix. Cattle like to rub against any upright fixture in an area where they graze. They would have no trouble rubbing against the panels and probably break quite a few. This is why The Solar Trade Association guidelines promote sheep grazing, not cattle.
SSSIs under Threat
Rampisham is one of two key cases live at the moment which, depending on how each of them conclude, will affect the future of all SSSIs in England. The other one is Lodge Hill in Kent. Both sites are under threat from development, and the key question is how the balance between protecting nature and promoting economic growth in the National Planning Policy Framework will be interpreted.
The NPPF enshrines the Mitigation Hierarchy, whose first commandment is “thou shalt avoid doing damage to very important wildlife sites.” If that damage is unavoidable, because there is nowhere else for that Solar Farm or that housing development to go, then move onto the next test, mitigation. In both the Lodge Hill and Rampisham Down cases, they can both be built elsewhere.
The other key issue is “does the benefit of the development outweigh the harm?” This is of course an “apples and pears” argument, as the benefits, in terms of economy (jobs, company profits) and environmental ones (CO2 reduction) are not even remotely comparable with the loss of biodiversity (tangible and intangible values, including intrinsic value) and landscape (tangible and intangible values).
If you would like to object to the proposal at Rampisham Down please make a comment to West Dorset District Council here BY THE FIRST OF AUGUST.
I have submitted a response using the online form, which should be published in the next couple of days so you can see what I have said.
More Dorset Solar Farms
Two more Dorset solar farms have been proposed recently, including one at Manor Farm, Verwood, directly adjacent to the 28ha Homeland Solar Farm, which has already been built. Homeland was where the proposed environmental benefit was to create a wildflower meadow on former heathland, next to a heathland SSSI, SAC and SPA. At least Good Energy revised their proposals to mention heathland – though only in passing. The main emphasis is still on “wildflower meadow” creation, though the photo show a cornfield mix. I guess I’m being pedantic again – splitting hairs over things like the difference between heathlands, wildflower meadows and arable weeds. Still, overall I think there will be a benefit for wildlife, given that it was previously arable land.
Manor Farm Solar Farm, right next door, would be on former intensive dairy land so it seems almost certain there will be an environmental benefit. The two new proposals together cover 102ha of farmland, or 240 acres in old money. The Manor Farm ecological management plan notes that wildflower seed will be sown in areas that are not shaded by the panels, and just a grass mix is sown under the panels
“wildflower mixtures will be sown between the panels, rather than underneath panels, to ensure they receive adequate levels of sunlight to facilitate growth and establishment”. It still bothers me that on an area that was heathland until relatively recently, there is this insistence on creating wildflower meadow. Manor Farm does include a pitifully small area heathland creation (0.25ha).
I think we need as many solar panels as we can possibly install – on roofs. There must be millions of hectares of roofs in this country – almost all of them could have panels. Economies of scale would mean that large roofs would be cheapest to put panels on – big warehouses, factories, shopping malls.
I would even be happy to see some solar farms be developed, and contribute to habitat creation – but keep them away from our few surviving valuable wildlife sites please.
Photo of Rampisham Down from Wikimedia Commons “View of Rampisham transmitter site, Dorset, England” by Foxmeadows – Photo from hotair ballon arround 2005. Licensed under Creative Commons Attribution-Share Alike 3.0 via Wikimedia Commons.