Thanks again for getting in contact and providing your detailed feedback on behalf of The Faversham Society. I have since been in contact with our environmental and technical team and can provide now you with some more information regarding your feedback.
Regarding the Environmentally Sensitive Area (ESA) the site lies within, although the ESA will not be addressed directly (as it is not a planning designation), as part of the DCO process a full Environmental Impact Assessment (EIA) will be undertaken, which will include a number of environmental surveys and assessments relating to wildlife designations and the biodiversity of the area. The impact on the existing agricultural land use will also be assessed. The findings of these surveys and studies will inform mitigation and enhancement measures. We will consult on these measures with statutory environmental authorities and local interest groups. We are in ongoing conversations with Natural England, RSPB and Kent Wildlife Trust regarding our bird data collated over the past 4 years and discussing mitigation proposals. Moving forward, we will continue to consult with stakeholders on our proposals to develop a strategy to ensure that adverse effects on birds as a result of the proposals can be appropriately mitigated. The drainage ditches currently in place will remain, and in some areas, the ditch habitat areas will be enhanced where possible. The agricultural land classification is relevant to the consideration of future land management provision within the site during the operational phase, and the potential for continued agricultural use (e.g. livestock grazing) is under consideration for the project.
Regarding footpaths, all your comments have been noted. We are open to the idea of enhancing or upgrading public rights of way in the area and have been receiving input from members of the public on this during this consultation period.
Regarding the shoreline and potential flooding, we have met with the Environment Agency to discuss our proposals and have commissioned a detailed flood modelling exercise to inform our project design. When we have received the flood modelling results, we will produce a project design which takes these results into account to ensure a safe and appropriate layout. Cleve Hill Solar Park Ltd are engaging with the current consultation exercise on the Medway Estuary and Swale Strategy which will conclude in February 2018.
Regarding traffic, your comments have been noted. We will be producing a comprehensive Construction Traffic Management Plan (CTMP) to control traffic movements throughout the construction period. The local community will be given the opportunity to comment on the CTMP before it is finalised. There is also some flexibility in how the solar park is constructed, e.g. quickly, with higher traffic volumes over a short period of time, or more slowly, with lower traffic volumes over a longer period of time. There are various influences on this, including wildlife, impact on local residents and likely weather conditions.
Regarding potential landscape and visual impacts, we are currently in consultation with the Council’s landscape consultants to seek agreement on the viewpoints which we will present and assess in our Landscape and Visual Impact Assessment (LVIA). As we obtain more information on the project design, we will begin to model the visibility of the solar park from key viewpoints. This work will feed back into the project design, which will evolve to respond to the LVIA work undertaken.
The deadline for this first phase of consultation ends today. Once all comments are received we will be analysing the feedback and reporting this in an interim consultation summary, which will be circulated to our distribution list of over 12,000 local homes, businesses and interest groups. All feedback received to our proposals will also be reported in the final Consultation Report, which will accompany the Development Consent Order application for the scheme.
We are pleased that The Faversham Society is engaging with our proposals, and providing us with feedback. We will endeavour to keep you updated on our proposals and welcome your member’s valued input into how we can develop our proposals. Whilst the first phase of consultation ended on 22 December, all our lines for feedback are still open and we will continue to welcome the views and suggestions of your members.
Cleve Hill Solar Park.
The Faversham Society’s response to the first phase of consultation 22 December 2017
The Faversham Society supports the development of renewable energy recognising its importance in reducing carbon emissions. However, the Society has some specific and serious concerns about the scale of the Cleve Hill Solar Park and its likely impact on wildlife, public amenity and food production.
Issues of concern
- Environmentally Sensitive Area.
The North Kent Marshes extending from the Medway along the Swale including Nagden, Graveney and Seasalter marshes are included in an Environmentally Sensitive Area. This is a national designation and there are only 22 in the UK. This is because the farmland is particularly good for wildlife and agriculture. This was not mentioned in any of the publicity material which states that the land is lower grade agricultural land, grade 3b.
The land within the site is a mix of arable over most of the area and some grazing marsh, but this mix of crops/habitat is particularly good for wintering ducks and geese and also for waders in summer such as lapwing which is a species that has been in major decline over the last 20 years.
After the marshlands were flooded in 1953 extensive field drainage was undertaken. This offered grazing for cattle and flocks of Romney and Suffolk sheep as well as land in which peas, beans, potatoes, mangolds, barley, wheat and mushrooms were grown.
(Source Farmer & Stock Breeder April 1958 and Lyn Powell who, together with her sisters were born at Nagden and whose father worked on the land for the then owner Arthur Frith).
- Wildlife Designations
The coast outside the seawall along the whole boundary of the site is a Site of Special Scientific Interest and a Special Protection Area. These are both national designations, indicating that this coast is of national importance for wildlife, in particular birds. This area is also designated under the Ramsar Convention, which means that it is of European importance for bird populations, particularly migratory birds in winter. The birds, particularly ducks and geese also use the marshes and arable land inside the seawall for feeding, so that the loss of most of the land to solar panels would be greatly detrimental to the habitat available for migrating birds. Although only 60% of the land will be used, with the exception of the refuge area at the east end, all the other land will be gaps between the lines of panels and drainage ditches. This will result in a significant reduction in flat, open land. There is only a small area set aside for birds at the east end and it is not likely that geese would overfly the panels and only land on this area. The geese fly along the Swale from the mud along the shore of the Isle of Sheppey or at Castle Coote and mostly land on the arable land which will be the site of the panels.
Lyn Powell whilst living at Nagden observed Brent geese, mallard ducks, Bewick swans, Whooper swans, curlews, reed warblers, owls and more.
- Swale Landscape Character and Biodiversity Appraisal
This is an important historic and cultural identity landscape. At the least the landscape west of a line drawn northwards from Nagden farm to the Swale coast (the landscape enclosing the lower Creek and entrance) should be preserved.
The Swale Landscape Character and Biodiversity Appraisal (2010) which is used by Swale Borough Council as Supplementary Planning Guidance identifies the Graveney Marshes as intensively farmed land with straight drainage ditches. The ditches are of some interest for wildlife. The eastern end is grazing marsh. The whole area is very exposed. Parts of the area are important for corn bunting, which is a nationally declining species. The area is remote marshland enclosed by the sea wall. The land is described as being in moderate condition and of moderate sensitivity. It is considered that this would not justify the conversion of the whole of this area of land into a solar installation.
There are two footpaths across the site. One is part of a footpath running from Seasalter Road onto the marsh. The main footpath affected is the track from Nagden Cottages to the seawall at Castle Coote. Although neither of these paths would be closed, the character of both would be substantially changed from paths across farmed land with an open character with wide views to paths through a dense landscape of solar panels. For the main footpath, this would be on both sides and as far as the eye can see until the walker reaches the sea wall. The Saxon Shore Way is also the England Coast Path and runs along Faversham Creek along the seawall and continues past Castle Coote on its way to Seasalter. This has open coastal view on the seaward side and at present open views over marshland fields inland. The character of this route would be changed substantially by introducing an extensive solar installation over the whole marsh area as far inland as Nagden Cottages and the Sandbanks ridge.
The Environment Agency’s Shoreline Management Plan is relevant and has implications for the proposed Solar Park:
“Faversham Creek to the Sportsman Pub marks the interface between the eastern landward limit of the Medway Estuary and Swale SMP and the open coast (Policy Unit E4 24: Faversham to Nagden – Medway Estuary and Swale SMP. The preferred policy for the estuary frontage is to Hold the Line in the short, medium and long terms). The frontage comprises extensive tidal mudflats to the west and a narrow beach extending to a small sand, shingle and shell spit at Castle Coot in the east, A concrete seawall, extending along the majority of frontage, protects undeveloped low lying coastal grazing marsh. The intertidal habitats along the frontage and a small section of wetland (immediately west of the Sportsman Pub) is of international nature conservation value. Under rising sea levels and a limited supply of contemporary beach building sediment, it is anticipated that the sparse section of beach will become increasingly difficult to maintain in the future. If the current alignment were to be held in the long-term, coastal squeeze, together with a diminished supply of natural beach building sediment would lead to substantial hard defences and / or significant beach management. Managed realignment would avoid the need for such defences, possibly creating cost savings and environmental enhancement.
No specific realignment ‘line’ has been defined but a maximum extent has been identified (see map). Further studies will be required to investigate and define the extent, location and implementation of the realignment i.e. the best technical, environmental and economic option that best manages flood risk, as well as to investigate the exact standard and alignment of any defences for this frontage and any mitigation measures required for loss of designated habitat. However, it is recognised that the greatest environmental benefits would be realised if the non-designated areas underwent realignment first.
A set back here would involve the loss of agricultural land and freshwater habitats. Realignment would however, create a coast that will not require ever increasing expenditure to maintain in the coming centuries, negate the effects of coastal squeeze and create important brackish and saline habitats.(The loss of the designated freshwater habitats would normally require mitigation measures to be implemented – and this aspect will require a more detailed appraisal in the strategy study).
The short term plan therefore, is to continue protecting the low-lying assets, which include footpaths, agricultural land and freshwater habitats. There remain opportunities for managed realignment to be implemented, for habitat creation purposes, in the short-term; however, this will be subject to further studies. In the medium and long term the plan is to realign the defences, along the majority of this frontage, allowing the shoreline to respond in a managed approach. The potential environmental, engineering and coastal process benefits will then be realised under a policy of managed realignment.
There is the p potential for a loss of buried unknown heritage within realigned areas in the latter two epochs.” Faversham Creek to Sportsman Pub (2010) p. 72
All traffic to the site to deliver the panels and all other materials will be brought from the A299 via Head Hill and through Graveney Village. The panels are large objects and will need to be brought by lorry. This will mean a period when there will be a large number of heavy vehicle movements through the village to the detriment of the amenity of the occupiers. A lesser number of vehicles will be required over the 25 years the installation is expected to be in place to service the site and/or bring in any replacements if necessary.
The panels will be set in pairs facing east and west with the ridge line running north to south. It is anticipated that these will be raised off the ground by at least 1 metre so that sheep can graze under them, but no section was provided to show whether or not this is the case. Since areas on the Isle of Sheppey across the Swale are higher than the coastal marsh, the large solar installation would be visible from parts of Sheppey. There is also higher land in Graveney which overlooks the marshes and the large solar installation would be visible covering an extensive area of open land. This includes views over the whole marsh area from the A299 Thanet Way at Wraik Hill as this road leaves the built-up area of Whitstable. It is likely that since the seawall around the Nagden side of the site is quite low that the top of the panels would be visible from the outskirts of Faversham instead of just the successive sea walls between Nagden and Castle Coote.
This first consultation has been on a tight deadline, and we have not been able to consult our members nor to consider the views of other groups with expertise in farming, wildlife and amenity. We look forward to seeing the results of this first round of consultation, and the developer’s proposed measures to mitigate or avoid negative impacts such as a) the intended construction process, b) the protection of existing footpaths and the creation of new ones c) flora and fauna and d) the landscape.
We would welcome the opportunity to engage in a constructive dialogue with the developers and to consult our members before coming to a considered view on the scheme in the Phase Two Consultation.