Feb 2025 - Parish Council Final Response

Scopwick and Kirkby Green Parish Council
https://scopwick.parish.lincolnshire.gov.uk/
 
Scopwick and Kirkby Green Parish Council
Village Hall 
Scopwick
Lincolnshire
LN4 3PA
 
11th February 2025
 
 
Dear Sirs, 
 
As a Parish Council, we recognize there has been some reduction in the magnitude of the Springwell Solar farm development down from the original proposal of 4200 acres to the revised 3163 acres. However, having consulted with our parishioners [Appendix 1], we are not able to support the project due to the fact it is still far too big by several factors and as we have highlighted throughout the process the significant risks it poses to the local community, environment, national food security and key MOD establishments far outweigh any perceived benefits. We ask that the inspectorate puts this into perspective, currently the largest solar installation in the UK is Shotwick in Flintshire at approximately 250 acres. The enormous scale of the proposed Springwell Solar installation magnifies the risks that we outline below. Springwell Solar will be 12.5 times the size of Shotwick. 
 
We also feel that the information being shared by the applicant is disingenuous. In the original scoping documents based on a 4200-acre site they were claiming to be able to provide up to 800MW into the national grid and provide energy for 180,000 homes. The site is now 25% smaller but they still claim the same potential import values. Is the applicant now expecting the sun to shine more due to the reduction in the size of the development?
 
We also highlight the High Grove application in Swaffham where they are claiming they would see over 50% Biodiversity Net Gain. This applicant is proposing 10%. How are we to interpret these wildly different claims? There is a degree of scepticism that all these claims are rather dubious and rather difficult to substantiate and inserted to meet a planning requirement.
 
Our Parish support reasonable plans to transition to renewable energy, such as installing panels on all industrial units, new homes and using old contaminated industrial areas. 
 
As a Parish Council we worked hard to develop our Neighbourhood plan. This plan identified areas for development and encouraged the implementation of solar panels on roofs and other environmental efficient policies, integrating and taking guidance from the National Planning Policy Framework.
 
 
 
Our main concerns as a Parish Council are outlined below:
 
1. Significant Loss of Agricultural Land
The proposed development would lead to the loss of a considerable amount of high-quality agricultural land, graded 2, 3a, 3b [BMV) it has also benefitted from considerable EU grant aid to provide irrigation. This quality land is vital for food production and ensures the UK can provide food security in times of local conflict or international conflicts such as Ukraine which had a material impact on grain availability. What we don’t grow we import at a cost to the environment and the desire to be Net Zero.
 
The National Planning Policy Framework is clear that where significant development of agricultural land is demonstrated to be necessary, areas of poorer quality land should be preferred to those of a higher quality. To be clear there is no poor land within the envelope of this development.
 
It is very clear there are alternative options that companies such as EDF should be exploring before they materially changing the landscape in Lincolnshire.
 
Whilst there are many potential innovations, we felt it was important to share one example. Power Roll, a developer of ultra-low cost and lightweight flexible film for energy generation and storage, have concluded that commercial roof space can easily support the levels of solar PV required to meet the UK’s net-zero targets – without putting further pressure on greenfield sites.
 
Power Roll’s analysis shows that there are around 2.5 billion square meters of south-facing commercial roof space in the UK, which could support over 400 GW of solar power; well in excess of the latest estimates of the capacity required to deliver net zero.
 
https://solarpowermanagement.net/article/112553/Analysis_of_UK_commercial_roof_space_shows_solar_PV_film_can_achieve_net_zero_without_greenfield_sites
 
If the Springwell Solar complex was consented to, the loss of this extremely fertile, irrigated land will have long-term consequences, particularly at a time when the UK needs to prioritize its self-sufficiency in food supply.
 
The various stakeholders in this application, Blankney Estates, EDF Renewables UK and Luminous Energy cloak this application in Net Zero rhetoric. The community of Scopwick & Kirkby Green should not be sacrificed for the commercial benefits of the applicant and the estate that is proposing to lease the land.
 
The UK climate is also not conducive to solar energy as highlighted by The World Bank Report Global Photovoltaic Power Potential By Country. 
 
https://documents.worldbank.org/en/publication/documents-reports/documentdetail/466331592817725242/global-photovoltaic-power-potential-by-country
Whilst solar plays a role in a few months of a British summer there will be many days where little or no energy is produced. This does not justify taking grade 2,3a & 3b farmland out of production.
 
2. Impact on the Mental Well-being of Local Communities
The scale and visual impact of the solar farm will irreversibly alter the rural character of the area. Many residents highly value the natural beauty and tranquillity of the region, and its industrialization could negatively affect the mental well-being and quality of life of the surrounding communities.
 
3. Risk Posed by the Battery Energy Storage System [BESS]
The inclusion of a Battery Energy Storage System introduces substantial safety concerns. Such systems are known to pose a significant fire risk. In the event of a fire there would be a very large volume of black smoke carrying toxic fumes. As we are aware current policy requires the fire to be left to burn or to be doused with significant quantities of water. The water is used to douse the fire and to help cool surrounding infrastructure in the attempt to prevent the fire spreading into other BESS units. The requirement of significant amounts of water and no fail-safe way of capturing all the contaminated water raises serious risks to the Lincolnshire Oolitic primary aquifer which is vulnerable to permeation. We also have serious concerns about the toxic smoke deposition on land downwind and the risk to communities living or working in its path.
 
The applicant is reluctant to be drawn on the specifics of the technology that will be installed, but is it right that the community is asked to sit back and trust the developer, who ultimately has a financial interest and will balance cost against safety? We request the inspector insist on a clear path regarding the technology that will be implemented if consent was granted. The community of Scopwick & Kirkby Green urge the inspector not to be swayed to recommend inappropriate or untested technology. Our community should not be used as a test.
 
Whilst the Inspector will only examine the Springwell Solar application site we are aware of a further 3 BESS sites currently in planning that will be in the same proximity. You must be aware of the cumulative impact this will have!
 
Lithium-ion batteries typically contain the following key components:
Metals:
• Lithium: A reactive metal critical for energy storage.
• Cobalt: Often used in the cathode but raises environmental and ethical concerns due to mining practices.
• Nickel: Another common cathode material, contributing to energy density.
• Manganese: Used for thermal stability in certain battery chemistries.
• Copper: Found in the anode current collector.
• Aluminium: Used in the cathode current collector.
• Iron [in some chemistries like LFP Lithium Iron Phosphate].
 
Electrolytes and Other Chemicals:
• Lithium Hexafluorophosphate [LiPF6]: A commonly used electrolyte salt that is highly reactive and can release toxic gases when exposed to moisture or heat.
• Organic Solvents: Such as ethylene carbonate and dimethyl carbonate, which are flammable and can release toxic fumes when burned.
• Polymeric Binders: Like polyvinylidene fluoride [PVDF], which degrade under heat. 
This threat jeopardises local residents, wildlife and the local water supplies and could have far-reaching environmental consequences. 
 
Supporting Examples:
• The Moss Landing Fire in January 2025, the 4th fire at this location in as many years, highlights the fire risks and environmental impacts associated with Battery Energy Storage Systems [BESS]. Repeated fires demonstrate the inherent risks and challenges of safely managing these systems. On each occasion the fire burned for several days.
• The Liverpool incident further emphasizes the potential consequences of BESS failures, including contamination of surrounding water and land. This fire burned for over 50 hours.
Please also refer to the EPRI's Battery Energy Storage System Failure Incident Database that demonstrates a more comprehensive list of BESS incidents.
 
The applicant in this case will only have enough water on site for 4 hours! In their submission the applicant endeavours to diminish the potential risks of BESS fire incidents, however there are real and present examples as highlighted by Moss Landing 2025. The inspector must not allow the applicant to sidestep these issues.
 
Pollutants Produced When a Lithium Battery Burns.
When lithium-ion batteries catch fire, they can release a range of harmful substances:
• Hydrofluoric Acid [HF]: Extremely toxic and corrosive; produced when the electrolyte decomposes.
• Carbon Monoxide [CO]: Produced from the combustion of organic solvents.
• Hydrogen Cyanide [HCN]: Can form under certain conditions, particularly when plastics burn.
• Particulates: Including heavy metal particulates, which are hazardous to human health and the environment.
• Other Toxic Gases: Including dioxins, furans, and volatile organic compounds [VOCs].
 
Given the high risks posed by the inclusion of a BESS, it is essential for truly independent assessments to be conducted regarding its safety and potential environmental impacts. We note the Environment Agency has already highlighted this as a significant concern. The Inspector should not rely solely on assurances from the applicant. The potential contamination of a primary aquifer and surrounding land would have devastating and long-lasting effects on the community and wildlife far outweighing any short-term benefits of renewable energy generation at this location.
 
4. Cumulative Impact of Similar Developments
Scopwick and Kirkby Green are facing an undue burden due to the presence of other large-scale developments that are also pending planning. The cumulative impact of these projects risks overwhelming local infrastructure, disrupting the rural landscape, and further eroding the quality of life for residents. This part of Lincolnshire is blessed as a picturesque area and it should not become an industrial landscape spoiled for a generation.
 
5. Increased Flood Risk
The installation of the panel supports by percussion piling will destroy the efficient land drainage systems that are in place which deliver millions of litres into ditches that successfully discharges into Scopwick Beck, once this land drainage infrastructure is destroyed by both impact and vibration shock waves from the percussion piling. Currently rainwater is discharged by these drainage systems, once the ground is saturated this water from 80ha of land will simply run off the surface of the ground downhill into the village settlement.
 
This could have devastating consequences for homes, businesses, and local ecosystems, particularly in a village already susceptible to water-related issues.
 
Please see Lincolnshire County Council’s Section 19 Flood Report, conducted in the aftermath of recent flood events in Scopwick. The Flood Forum also have an ongoing survey into the affects of flooding specifically in Scopwick.
 
6. Concerns Over the Origin of Equipment
A significant portion of the equipment for this project is likely to be sourced from China, particularly polysilicon [a crucial raw material], originates from China’s Xinjiang region. There have been allegations of forced labour in the production of polysilicon, leading to concerns about ethical sourcing.
 
In response, countries like the U.S. have implemented trade restrictions, such as the Uyghur Forced Labor Prevention Act [UFLPA], to prevent imports linked to forced labour. Approving a development with such associations undermines the principles of sustainability and human rights that should guide renewable energy initiatives. The applicant has avoided clearly answering where they will be sourcing their panels, Lithium batteries and associated materials from.
 
In addition to the ethical concerns there really needs to be a comprehensive assessment of the environmental impact of manufacturing solar panels and associated products. The production of solar panels, particularly in regions with high coal-based electricity [such as China], has raised concerns about the carbon footprint of manufacturing. Chemical waste from solar panel production, if not properly managed, can also contribute to environmental pollution. It seems there is very clear evidence that whilst the applicant can claim to be providing a Net Zero solution the reality is they have simply exported the issue to China and then shipped the product to the UK. Is this really a green solution? Throughout the consultation period the applicant was very reluctant to discuss their sourcing strategy.
 
The environmental impact of the mining processes and industrial methods used to manufacture solar panels must not be overlooked. The carbon footprint and human cost of these practices are significant and contradict the sustainable principles renewable energy projects aim to uphold. The applicant provides a marketeer’s view of panels in a beautiful setting. The process of manufacturing panels is anything but green. The long-term risks of panels and their chemicals leaching into the soil needs much more examination from truly independent bodies. Whilst we currently have not had a solar farm operational for 40-years the reality is the land will never return to agriculture. We have been told that there is serious risk that the soil will be contaminated. Furthermore, panels are categorised as toxic waste in the US. The applicant glibly wants us to believe and trust in them that the panels will not contaminate the soil and that they will be recycled. The communities around Dupont facilities in the US believed the lies promoted by Dupont that the chemicals used in the manufacturing process of Teflon were not harmful. These PFAS were polluting the atmosphere and were also infiltrating local water supplies. Until a Class Action court case was ultimately successfully won Dupont denied all responsibility.  
 
Whilst we don’t fully know what toxins could potentially enter the atmosphere or the aquifer our community does not want to be put in harm’s way where exposure could result in similar issues as those impacted by the ‘Forever Chemical’, Dupont and the Teflon scandal resulted in birth defects, induced hypertension and testicular and kidney cancer and miscarriages. 
 
In the UK corporations convinced developers to clad tower blocks, as we saw with Grenfell this had tragic consequences. Large corporations typically serve their own and shareholder interests.
 
In many cases these solar developments are sold on if planning is consented. In this scenario, we need to question who and where liability resides when the 40-year lifecycle ends. Who is ultimately responsible for the site clearance. There are many examples in the UK and worldwide where industrial sites are abandoned and never de-contaminated resulting in a wasteland. What absolute guarantees are there that this could not happen, and will any bond be sufficient to guarantee this land will have all contamination removed and be fit for first class agriculture in the future?
 
7. Proximity to Ministry of Defence Facilities and Fuel Lines
The site’s proximity to Ministry of Defence facilities, RAF Digby & RAF Waddington and high-powered fuel lines poses additional security risks. Any potential interference with these critical infrastructures could have broader implications for national security, which must be treated as a priority.
 
8. Impact on Property Values
Although not a material planning concern, parishioners are concerned about potential property devaluation due to the proximity of a solar farm and associated infrastructure. We reference two studies below, that show there is an impact on property prices within the catchment of much smaller projects. The impact is very likely to be larger the larger the project.
 
https://www.tandfonline.com/doi/full/10.1080/13504851.2024.2308586
 
Using hedonic analysis, manually traced solar farm footprints, and difference-in-differences identification, we find a 6.86% negative capitalization of solar farm proximity that does not appear to be attributable to glare and is driven by the impacts of very large solar farms. The results are robust to concerns of negative weights associated with bad controls. To limit economic losses associated with the renewable energy transition, solar farms should be strategically located to minimize the number of nearby homes regardless of whether glare is likely to be a concern.
 
https://research.birmingham.ac.uk/en/publications/the-disamenity-impact-of-solar-farms-a-hedonic-analysis
 
This paper analyses the disamenity impact of photovoltaic solar farms on households in England and Wales revealed by changes in property prices. Using a property fixed-effects model we find that properties ≤750m south of a >5MW operational solar farm suffer a 5.4 percent reduction in relative prices. The impact of solar farms ≤5MW or >750m or situated south of properties is statistically insignificant.
 
Finally, our Parish Council concludes that a core planning principle is that developers should do no harm when seeking consent for any development. We question whether the Secretary of State or the Planning Inspectorate would be prepared to face accountability should the assurances provided by the applicant on such issues such as improving biodiversity, avoiding aquifer contamination, and preventing increase flood risk prove unreliable or false. The scale of the risks involved necessitates a cautious and principled approach to this application.
 
In conclusion, we urge the relevant authorities to reject this proposal which would overwhelmingly reflect the views and concerns of the vast majority of the community that we serve. While renewable energy is one element for addressing climate change, it must not come at such a high cost to local communities, agricultural resources, and national security. We believe alternative, more suitable locations should be explored to minimise these impacts.
 
Thank you for considering our concerns and we welcome the opportunity to address the Inspector at the public enquiry.
 
On behalf of Scopwick and Kirkby Green Parish Council.
Sincerely,
 
Jack Sargent
 
Jack Sargent
Parish Clerk
Scopwick and Kirkby Green Parish Council
clerkscopwick@gmail.com