Letter of Objection from The South Hams Society

The South Hams Society interest
For the last 50 years the South Hams Society has been stimulating public interest and care for the beauty, history and character of the South Hams. We encourage high standards of planning and architecture that respect the character of the South Hams. We aim to secure the protection and improvement of the landscape, features of historic interest and public amenity, and to promote the conservation of the South Hams as a living, working environment.  We take the South Devon Area of Outstanding Natural Beauty very seriously and work hard to increase people’s knowledge and appreciation of our precious environment. We support the right carbon saving renewable energy schemes – in the right places.

We are opposed to this application
On behalf of our members we object most strongly to the proposed major solar farm development at Creacombe. Major development within the heart of the South Devon Area of Outstanding Natural Beauty is strictly controlled by law and is prohibited, except in exceptional circumstances. No exceptional material planning grounds have been presented which can justify approving the application. We believe this is an inappropriately sited commercial development, masquerading as a “community” driven project, offering financial incentives to gain approval.  For the material planning reasons listed in this letter, we ask the Council to reject the application.

1.The development would cause harm
The Secretary of State, Planning Inspectors and Planning Officers have identified that solar farm developments do invariably detract from the unspoiled character and appearance of the landscape. It is axiomatic therefore that the proposed development would cause harm to the protected landscape. We ask that the Council rigorously apply the ‘National Trust AONB’ planning tests to this application.

2. Out of proportion
The solid structures of the proposed solar arrays would form a strong physical presence of industrial appearance which would change the character of the rural fields in which they are located. In particular the spread of the arrays across the highly visible sloping ground would be out of proportion with the surrounding agricultural landscape.
3. AONB Harmed by the proposal
The proposed development would be an incongruous industrial and alien intrusion that would be harmful to the landscape character of the area, and a discordant feature within the pastoral setting. It would clearly cause harm to the highly protected and sensitive Area of Outstanding Natural Beauty. The visual enjoyment of the AONB by those that live in, or visit would be significantly affected and harmed by the proposal.

4. Unacceptable and overriding harm
We intend asking the Secretary of State to intervene if the plan gets the go-ahead from South Hams District councillors.  We will request the application should be “called-in” due to its size, location in an AONB contrary to national and local planning policy. We consider in this case the significant harm to the character and appearance of the AONB and its component heritage assets would be unacceptable and overriding. These adverse effects would significantly and demonstrably outweigh any benefits from this scheme.

5. Changing the landscape
We believe the location of the proposed solar farm strikes at the heart of our stunning and highly protected landscape. We note that although renewable energy production is in the public interest, AONB have the highest status of landscape protection and their conservation and enhancement is also in the public interest. We are satisfied that renewable energy needs can be met from suitable sites outside protected landscapes or from small, carefully designed schemes within protected landscapes, at an appropriate scale. However, this proposal on a site of 10.9 hectares will completely change the character of the landscape.

6. Urbanising the AONB
We believe the development would have a major adverse and significant urbanising effect on landscape character, including the setting of the South Devon AONB, and is therefore contrary to Local Policy and paragraphs 17 and 109 of the National Planning Policy Framework.

 7. Out of keeping with rural character
The solid structures of the arrays would form a strong physical presence of industrial appearance which would change the character of the rural fields in which they are located. In particular the east west spread of the arrays across the slope would be out of proportion with the scale of the surrounding landscape. The eye would be drawn towards the site in views from public footpaths and from nearby roads. Whilst it is accepted that the successful growth of the hedgerows would, in time, do much to provide effective screening from some close views into the site, the development would be visible in wider views, and would form an incongruous expanse of metal structures out of keeping with the intimate and rural character of the area, and would be disproportionate to the scale of other landscape features. Appeal Decision APP/R3325/A/13/2197853

 8. Significant harm to the location
The Department of Communities and Local Government guidance states that with effective screening and appropriate land topography the area of the zone of visual influence of ground mounted solar panels could be zero. In the Creacombe proposal, having regard to the character of the topography, that would not be the case. When viewed in the context of the setting, the harm to the character and appearance of the area would be significant. The scale of harm in this location is such that, in our view, it would not be outweighed by the wider benefits of the renewable energy provision.

9.  Considerable urbanising impact
In appeal (reference APP/D3505/A/13/2204846) the Inspector decided that “The development would result in the loss of arable land for 25 years, albeit this would be reversible. Nonetheless, for the lifetime of the development the regimented rows of hard surfaced solar panels would represent intrusive, utilitarian elements on an industrial scale in the open countryside. Together with its associated new buildings and structures, the proposal would have a considerable urbanising impact in this protected rural location, and would detract from the distinctive topography of the site and its surroundings”.

10. Strong presumption against approval
We believe the impact on visual amenity of the site security measures, fencing and on the existing ‘dark skies’ and the effects of sunlight and moonlight glare, will be greater than that claimed by the applicants. Even where harm might be categorised as being ‘less than substantial’. That doesn’t mean a less than substantial planning objection. In paragraph 134. of the NPPF it notes “Where a development proposal will lead to a less than substantial harm, the harm should be weighed against the public benefit of the proposal.” Where harm is identified, and the harm is being classified as less than substantial, then there should be a strong presumption against approval in a planning balance.

11. Council must Protect and enhance
Government policy, expressed in the National Planning Policy Framework at paragraph 17, recognises within its core planning principles the intrinsic character and beauty of the countryside, and paragraph 109. seeks to protect and enhance valued landscapes.

12.  A very high test
In the House of Commons oral statement of 29 January 2014, the then Planning Minister, Nick Boles, stated the “The policies in the national planning policy framework are clear that there is no excuse for putting solar farms in the wrong places. The framework is clear that applications for renewable energy development, such as solar farms, should be approved only if the impact, including the impact on the landscape – the visual and the cumulative impact – is, or can be made, acceptable. That is a very high test.”

13. Planning Policy Guidance
Also of relevance is the Planning Policy Guidance (PPG), paragraph ID 5- 007 of which indicates that local topography is an important factor in assessing whether solar farms could have a damaging effect on the landscape, and which recognises that impact can be as great in predominately flat landscapes as in hilly areas. At paragraph ID 5-013 the PPG goes on to say that “The deployment of large-scale solar farms can have a negative impact on the rural environment, particularly in undulating landscapes.” There is no dispute that this solar array, with an installed generating capacity of 7.8 Mega Watts (MW) in the proposed location, is large scale and a major development.

14.  Local land use is solely agricultural
The PPG at paragraph ID 5-010 says that “Renewable energy developments should be acceptable for their proposed location”, and indicates at paragraph ID 5-008 that distance away from a development is just one consideration, stating that “Distance plays a part, but so does the local context, including factors such as topography, the local environment and near-by land uses.” In this case the “near-by local land use” is solely agricultural.

15.  Inappropriate to an agricultural landscape
The UK Solar PV Strategy Part 1 of October 2013 sets out four guiding principles for solar PV, the third of which states, amongst other things, that solar PV should be appropriately sited with proper weight being given to environmental considerations such as landscape and visual impact. Following publication of this strategy, the then Minister for Energy and Climate Change, Greg Barker, produced a letter dated 1 November 2013 indicating that “inappropriately sited solar PV is something that I take extremely seriously and am determined to crack down on.” There is a clear requirement to conserve rural character and avoid types of farm diversification which are inappropriate to an agricultural landscape.

16.  Mitigation takes time
The site of the proposed solar array is on the side of a hill and the internal area is visible from many viewpoints. It is accepted that the growth of the hedgerows would do much to provide effective screening from close views into the protective security compound. But, the industrial development would be visible in wider views, and would form an incongruous expanse of metal structures, out of keeping with the intimate and rural character of the site, and would be disproportionate to the scale of the other landscape features.
Again, we note that the site can be seen from viewpoints within the South Devon AONB. The full effects of mitigation of the visual impact of the proposal, by hedge or tree planting, could not be satisfactorily achieved until towards the end of the proposed temporary use period of 25 years.
The applicants image (planning file viewpoint 10) clearly shows that the currently uninterrupted panoramic views across the AONB would be harmed by the proposed discordant feature of the solar arrays.  http://www.cotswoldsaonb.org.uk/userfiles/file/planning-responses/straford-ilmington-pv-aug2014.pdf

17. No exceptional circumstances
With regard to paragraph 116 of the NPPF (and the associated guidance within the NPPG), we consider that no exceptional circumstances of any significant weight exist to outweigh the impact of this proposal on the nationally designated AONB.

18. Enhancement of the AONB
Further to this in terms of paragraph 116 of the NPPF the conservation and enhancement of the AONB (Section 85 of the CRoW Act 2000) is also a matter of public interest and should therefore be afforded weight in the planning balance.

19. AONB the highest status of protection
Paragraph 115 of the NPPF confirms that “Great weight should be given to conserving landscape and scenic beauty in AONBs” which have the highest status of protection.

20.  Who the applicants are is not material
Although the application has been ‘supported’ by “Yealm Community Energy Ltd” and any level of community support towards this proposal is a matter for general consideration, we do not consider this matter to be an exceptional circumstance in its own right. As the Minister for Housing and Regeneration has previously stated: “Planning decisions should be based on an assessment of the impacts of any proposed development irrespective of who the applicant is.”

21. Enhancements can be provided anyway
The applicants offer of additional bio-diversity enhancements is considered by us to only carry little weight in the planning balance. The proposed enhancements can be provided for generally and more suitably across the AONB without the need for it having to accommodate major inappropriate industrial development.

22.  Limited or no weight should be given to the undertaking
We also believe the offer of “surplus funds” to be secured through the purchase by ‘Yealm Community Energy’ has yet to be completed. We question the Council as to whether such it falls within the scope of Section 106 (1) of the Town and Country Planning Act 1990 or the Community Infrastructure Levy Regulations 2010, in that such an offer does not appear to be required to make the development acceptable in its own right and accordingly limited, or even no weight, should be given to the undertaking.

23. Winter of discontent
In terms of landscape impact, we also note that 1.5 meters in height of the proposed solar panels will reduce, to a degree, the visual impact on the wider landscape. However, the solar farm, associated equipment and access tracks and approximately 1.5 kilometres of security fencing will still be visible from various locations and public viewpoints, particularly in the winter months when lack of leaf cover to trees and hedges will allow further views through to the development.

24. Reversibility not a factor
The Secretary of State has also previously agreed in recent solar farm decisions, that 25 years is a significant length of time over which harm would be endured, accordingly the reversibility of the scheme should not be an influential factor in the decision-making process and should be given little weight.

25.  Not sustainable development
We also note an appeal decision in respect of a site in Oxfordshire (outside but within the setting of the Cotswolds AONB). Even though this scheme was outside the AONB, the Inspector still dismissed the appeal stating “Notwithstanding the benefits of the scheme to Renewable Energy targets and reduce Greenhouse Gas emissions, and the contribution it would make towards the local economy and biodiversity, I do not consider that the impacts of the appeal scheme are, or could be made, acceptable. The proposal would conflict with relevant policies of the Local Plan, and would not accord with the requirements for sustainable development set out in the Framework. There are no material considerations here that would indicate that a determination other than in accordance with the development plan was justified.”

26.  Should use previously developed and non-agricultural land
Although the proposed scheme will make a contribution to meeting renewable energy needs, the NPPG published in March 2014 stated the Government’s intentions were “encouraging the effective use of land by focussing large scale solar farms on previously developed and non-agricultural land, provided that it is not of high environmental value.” Accordingly, although greenfield schemes may still be considered, “proper weight” should be given to environmental considerations such as “landscape and visual impact”.

27.  Discordant and industrialising feature,
We consider that the need in terms of Paragraph 116 of the NPPF can be met in other ways. The Government itself recommended the focus should be on “domestic and commercial roof space and on previously used land” (Greg Barker DECC April 2014). Therefore, the loss of this area of farmland, within the open countryside of a nationally protected landscape to a solar development would introduce a discordant and industrialising feature, which would fail to conserve and enhance the South Devon AONB, which is the purpose of designation under the CRoW Act 2000

28.  Not in accord with plans
The proposal is not in accord with the South Hams Development Plan and Local and National Planning Guidance. It would not conserve or enhance the designated landscape of the AONB. The commercial benefits that would be gained by the applicants and the local community are heavily outweighed by the significant harm that would be done to the visual quality and landscape character of the area.

29. Significant harm to AONB
No amount of promotional spin, freshly planted wildflower meadows and promised economic sweeteners can hide the fact that the proposed industrial development is essentially a commercial undertaking, where the greatest benefit will flow to the applicant and equipment suppliers (not a material planning matter) while significant harm will be caused to the highly protected South Devon Area of Outstanding Natural Beauty – and to the millions who enjoy, live in, or visit it – which is a material planning matter!

30.  Protect and enhance
Our Councillors have a legal duty to protect and enhance the South Devon AONB. It is in a nationally prized landscape which is the county’s major economic asset.

31. Duty to protect land assets
The Councillors have a duty to protect our agricultural land resource. As the applicant notes, the fields included in this proposal were being ploughed, in cultivation and providing harvests during the period when the land quality assessments attached to the application were being carried out.

32.  Elevated material consideration
It is a matter of national planning policy and, therefore, a matter of law, that the impact of development on an AONB is elevated above the status of an ordinary material consideration, and is a matter which must be accorded great weight in the overall balance of benefits and dis-benefits.

33. Conserving and enhancing the land
The Countryside and Rights of Way Act 2000 places a statutory duty on the relevant authorities “to have regard to the purpose of conserving and enhancing the natural beauty of the AONB when exercising or performing any functions affecting land in the AONB.

34.  Major attraction for investing in Devon
It is noted in the South Hams Local Development Framework that “The high-quality environment in the South Hams helps to sustain the important tourism industry and is a major factor which attracts investment into Devon”.

35.  High-quality design
DP1 notes, “All development will display high-quality design which, in particular, respects and responds to the South Hams character in terms of its settlements and landscape”.

36. Conserving what’s special and distinctive
DP2 requires that the applicants visual impact assessment should include a demonstration of how the location, siting, layout, scale and design of the development “conserves and/or enhances what is special and locally distinctive to the site”. The application does not contain the required ‘demonstration’ and the development would not conserve the sites distinctive character.

37.  Conserving quality
The Devon Structure Plan supports “The evolution of farm types, modernisation activities, diversification enterprises and added value operations that conserve and enhance the South Devon AONB special qualities”.

38.  Maintaining distinctive landscapes
The AONB Management Plan states that critical to the AONB future is “A profitable, sustainable and environmentally beneficial farming and land management sector, providing high-quality food, fuel, timber and benefits to people and wildlife” and that it will be “fostered as one of the principal means of maintaining the special qualities and distinctive landscape of the AONB”.

39.  The area’s greatest asset
The conservation of Devon’s special landscape character is an objective that relates to the countryside, and the protection of the rural environment, and is one of the main elements of the Structure Plan strategy. The Council’s approach for sustainable tourism is in its Tourism Strategy. It states that “the aim of the regional and local tourism strategies is to seek to lengthen the season, widen the range of facilities available and improve the quality of attractions and accommodation. All this has to be achieved within the context of protecting the area’s greatest asset – the distinctive environment and cultural heritage of the South Hams.”

40.  Preserving the setting of heritage assets
The Secretary of State, in the recent Winslade Farm decision, paid special regard to preserving those listed buildings affected by the application, or their settings, and the features of special architectural or historic interest they possess. There are many historic and other heritage sites and listed buildings close to the proposed solar farm at Craecombe.

41. The proposed agricultural site
The Craecombe Farm site consists of agricultural land surrounded and divided by mature hedgerows of various native species. As such its character and appearance are entirely in accord with the landscape character of the AONB of which it forms part.

42. Inevitable detrimental effects
In his consideration of the Tetbury appeal, the Secretary of State was of the view that he ” agrees that the primary concern about the impact on the AONB is the loss of fields to housing development (IR14.53). Despite the visual improvements that would result from the landscaping proposals, and to some extent moderate the impact of the new buildings, he agrees that the loss of open fields must inevitably have a detrimental effect on the landscape and environment”.

43.  All three 116. criteria have to be met
Clearly the Secretary of State considered in the Tetbury case that simply the loss of “open fields” was harmful to an AONB, and therefore the detrimental effect of that proposal could not be moderated. The same applies to this application. Thus, the third criterion in 116. would not be met. It should be noted that all three criteria have to be met for the “exceptional circumstances” test to be met.
ref: APP/F1610/A/11/2165778 for residential development at Tetbury in the Cotswolds AONB file:///C:/Users/ianbr/Documents/Gnaton/wychavon-averill-close-23sept2013.pdf

44. Significant water quality issues
The Devon County Council Flood and Coastal Risk Management Team have warned the applicant that concentrated rainwater runoff from the panels is likely to lead to erosion of the ground surface below, contributing significantly to water quality issues downstream and downslope.

45.  Temporary weighting
The Secretary of State for Communities and Local Government gives very little weight to the, so called, “temporary nature” of these solar farm developments.

46.  Recognising the public benefit
We recognise the contribution that the proposed scheme would make to energy security and that meeting national renewable energy and carbon reduction targets weighs significantly in favour of the proposed development. However, these matters are ‘significantly’ out weighted by the Councils duty to give “great weight” to the protection and enhancement of the AONB and by the weight that must be given to the protection of the other important heritage and landscape assets that clearly would be harmed by this development.

47. Local Economic Benefits
We believe the applicants have overestimated the local economic benefits the proposed development would generate. No rational evidence to support their claims has been presented within the application.

48. National Planning Policy Framework NPPF 115. requires that “Great weight should be given to conserving landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty. The conservation of wildlife and cultural heritage are important considerations in all these areas, and should be given great weight.”
From <https://www.gov.uk/guidance/national-planning-policy-framework/11-conserving-and-enhancing-the-natural-environment>

49.  Test for exceptional circumstances
NPPF paragraph 116. sets out the criteria against which the application has to be assessed to meet the “exceptional circumstances” test for permission to be granted for major development in a nationally designated landscape.

50. The criteria are:
● The need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;
● the cost of, and scope for, developing elsewhere outside the designated area, or meeting the need for it in some other way; and
● any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.

51.  Must weigh all material considerations
Where an application is made for a development in an AONB, the relevant committee or other planning decision-makers are required to take into account and weigh all material considerations – and not consider non-material planning matters.

52. Very special category of material consideration
The NPPF places the conservation of the landscape and scenic beauty of an AONB into a special category of material consideration: as a matter of policy paragraph 115 requires it to be given “great weight”, and paragraph 116 of the NPPF requires permission for a major development in an AONB to be refused, save in exceptional circumstances and where it can be demonstrated the proposed development is in the public interest. In this context, exceptional is defined as rare.

53. Must be refused unless In coming to a determination of such a planning application under policy 116. the committee are required, not simply to weigh all material considerations in a balance, but to refuse an application unless they are satisfied that (i) there are exceptional circumstances, and (ii) it is demonstrated that, despite giving great weight to conserving the landscape and scenic beauty in the AONB, the development is in the public interest.

54. Great weight
We believe that following the decision in the Winslade turbine Local Inquiry, the Planning Committee appreciate that it is required to refuse permission unless there are exceptional circumstances in the public interest which outweighed the weight required to be given to the scenic beauty of the AONB and any other material matters, and that they also appreciate that NPPF policy requires the scenic beauty factor be accorded “great weight”.

55. Inability to connect is not an exceptional circumstance
We do not believe that the electricity transmission company’s apparent inability to provide reinforcement to their transmission and distribution supply systems, in a reasonable time and cost, can be cited as an “exceptional circumstance” which overcomes the “great weight” which must be given to the harms which would be caused to the protected AONB by the proposed development. The definition of exceptional, in this context, is rare! Clearly, delay is not “rare”.

We also believe that the merits of the applicant’s case must be decided upon and against the national and local plans – not the separate Yealm Community Energy Ltd ‘aspirational’ business proposal.

56. Material Planning Matters!
We believe that the location of the proposed solar farm strikes at the heart of our stunning and fragile landscape. The AONB Management plan notes that although renewable energy production is in the public interest, AONBs have the highest status of landscape protection and their conservation and enhancement is also in the public interest.

57.  Complete change of landscape character
We are satisfied that irrespective of the applicant’s claims, that Devon’s renewable energy needs can be met from suitable sites outside protected landscapes, or from carefully designed schemes within protected areas at an appropriate scale. However, this proposal at 10.8 hectares will completely change the character of the landscape and can be looked onto and into from many public viewpoints.

58.  Incongruous, industrialising impact
The topography of the agricultural fields where development is proposed, is such that the solar arrays would be prominent. We also appreciate there is scope for strengthening the boundaries of the site with additional planting, which would screen or filter views from passing walkers and drivers. However, as the applicants fairly accept, the imposition of solar arrays and buildings of the extents proposed on the 10.8 hectares, with nearly 1.5 kilometres of security fences and machinery, on an otherwise pastoral landscape, would be bound to have an incongruous, industrialising impact upon it that would reduce the sense of pastoral tranquillity and visual amenity. This impact would be most apparent as one passes the existing and proposed gate accesses to the site and from more distant viewpoints.

59. Historic Environment Team objects to this application
We note that, given the high potential for survival and significance of below ground archaeological deposits associated with the known prehistoric activity in the immediate vicinity, and indicated by the geophysical survey actually within the application area, and the absence of sufficient archaeological information, the Historic Environment Team objects to this application.
From <http://apps.southhams.gov.uk/PlanningSearchMVC/Home/Details/171109>

60. Avoid our most sensitive and precious locations.
The Solar Trade Association represents many of the leading developers in the UK. At a Parliamentary Briefing “Planning and Good Practice Guidance” Patrick Begg, then Rural Enterprises Director at the National Trust, said: “New renewable sources, such as solar farms, are vital if we are to generate the low carbon, clean energy that we need to power the nation. However, it is essential that these schemes are realised in tune with landscapes and the natural environment and avoid our most sensitive and precious locations.” At that Parliamentary briefing, Dr Jonathan Scurlock, Chief NFU Adviser on Renewable Energy and Climate Change, a key stakeholder in developing the ‘10 Solar Trade Commitments’, said: “The NFU is delighted that lead solar developers have signed up to such a strong charter of good practice.”

61.  Nine out of ten cats prefer!
We do not believe that the “community consultation” exercise, described in the application, accurately, or fully, represents the views of the affected local community. It was undertaken almost two years ago by a team of professional advisers working for the solar industry who have promoted more than 73 solar farms across the country. With an estimated target show audience in excess of 10,000 and some 900 letters sent to “residents”, the applicants report that only 66 attendees (which included many local councillors) completed survey forms. There is no evidence presented as to who the 66 were, or what area they are “residents” of. It is claimed the completed exhibition feedback forms demonstrate 92% support for solar farms. However, the actual solar farm proposed at Creacombe is now (2 years later) to have 46% higher output, which compromises the promotional events ‘survey’ results.

62. More than marginal
Though the applicant’s documents describe the increase in the area of the proposed development as “marginal” it’s output has been increased from 5 MW to 7.3 MW i.e. an increase of 46%.

63. little or no weight in the planning balance.
The claims made in the application about the levels of public support for solar power is not, as the applicants claim, remarkable “5.6 These were the highest levels of support the team of professional advisers have ever seen.” The STA commissioned its own YouGov poll about solar farms. When asked specifically about support for solar farms, two thirds of people (67%) said they supported either ‘good quality’ or ‘all’ solar farms. In one of the letters of support for the application, the writer (Taymar Bourn from Totnes!) states “the ambition to find a way to sell the locally generated power to local homes is innovative”. But, at the moment, it is just that; an “ambition” and one we suggest should carry little or no weight in the planning balance.

64.  Ten out of ten cats prefer!
We would point out that if all the councillors who attended the solar industry’s promotional events were asked whether they have a legal duty to protect and enhance the AONB? we would confidently expect 100% of them to say yes!

65. Significant soil erosion predicted

The applicant has been advised, by the Devon County Council Flood and Coastal Risk Management Team, that the soil surface of the site may be significantly vulnerable to erosion, particularly during intense precipitation events. The applicant is also advised that concentrated runoff from the panels is likely to lead to erosion of the ground surface, contributing significantly to water quality issues downstream or downslope.

66.  Surrounded by the public
The site is entirely surrounded by public roads and two Public Rights of Way are close by (footpaths 14. and 15. not just one as shown In the application.) The nearest is approximately within 200 metres of the site and both ‘feed’ walkers onto the lanes which surround the proposed site.
From <http://map.devon.gov.uk/dccviewer/MyLocalPaths/>

67.  Adding alien structures in the AONB
We would expect the counsellors undertaking their duty to “enhance” the AONB, through the planning system, would seek to reduce the number of overhead power supplies and support poles, rather than installing more within the protected areas. We have been unable to find any reference to, or application for, the proposed developments connection to the local electricity distribution system.

68.  Not low-grade land
The application is not in accord with the published aspirations of Yealm Community Energy Ltd. In its web prospectus, it states that “All (it’s) renewable energy projects will be selected on the basis of minimal visual and other environmental impacts.  For example, ground-mounted solar will only be on brownfield sites or on low grade agricultural land.” Clearly the Creacombe site is neither “brownfield” nor, low grade land. Grade 3b is valued “moderate” quality soil not “low-grade”. In any case Grade 3b is moderate quality land, and well capable of producing moderate to good yields of a narrow range of crops, principally cereals and grass or lower yields of a wider range of crops, or high yields of grass which can be grazed or harvested over most of the year.

69. Borderline 3a/3b land
The recorded rainfall last year, close to the site, was 970mm (rather than the 1234mm used in the soil report) i.e. lower by 21.4%. That in itself could raise the soil grade to 3a. (good). The crops mentioned in the survey, grass ley, oilseed rape and the stubble from a wheat crop, indicate to our members who are farmers, that the fields are borderline 3a./3b. The 7% slope of the site appears not to have been considered significant in the saturation calculation.

70. Covering the AONB
The applicants soil report classes the 27.8 hectares surveyed (only ten hectares to be used as the development site) as class Subgrade 3b (Moderate quality). It’s heavy clay loam topsoil falls into that category only as a result of the high annual rainfall.  Broadly, in South Devon there is close to Zero ALC Grade 1. Land. Only 9% of the land is grade 2. And 62% is grade 3. Again, this is mainly because of climate/rainfall. So, it could be argued that if grade 3. and below land can be used, then solar panels could be allowed to cover 91% of South Devon and its highly protected landscapes and Areas of Outstanding Natural Beauty! This is clearly not what the local and national plans, Government and NFU and solar industry guidance intends.

71. Conclusion
For the material planning and other pertinent reasons, we have listed in this letter, we ask that the Council refuses to allow this inappropriate development in the South Devon Area of Outstanding Natural Beauty.

Ian Bryan
For and on behalf of the South Hams Society

Replies to:

Ray Long
The South Hams Society
1 Croft Road,


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