The Faversham Society enthusiastically supports the development of all forms of renewable energy. We recognise the importance of using wind, solar and tidal technologies for power generation to reduce the use of carbon fuels and meet the UK commitments to reduce levels of greenhouse gasses.  However, we have grave concerns about the negative environmental and amenity impact of the solar power station being proposed at Cleve Hill and across the surrounding marshes. There are alternative brownfield sites available, and distributed generation is both possible and more desirable.

Our major concerns are listed here:

1. Unprecedented Scale – What is being proposed on the outskirts of our town is an extremely large industrial development, as big if not now bigger, than Faversham itself. A development of this scale cannot fail to have a profound negative effect on the environment and reduce the economic and amenity value to those both living in and using the area. We will need to be convinced by the economic and environmental logic of building a single site at this scale.  If the logic for constructing a plant of this size is so convincing why are there not similar developments anywhere else in Europe and beyond?  Moreover, this is an experimental development. We understand that it is 15 times the size of the largest UK solar farm and we are told that neither the developer nor the builder has attempted a solar installation on this scale before.

During the consultation process, there have been many changes to the proposal. Plans for the battery installation are still unclear.

We are disquieted that our marshes are being used for this experiment. We are also worried that if the Cleve Hill development is allowed on this far- eastern edge of our Borough, it will create a precedent that over time, will allow marshland to the west to be sacrificed until the whole of Swale’s north Kent coastline becomes an industrialised zone.

2. Implications of Site Enlargement – there has been a significant increase in the size of the proposed site during the consultation period. This has been achieved by developers including a Site of Special Scientific Interest and the seawall, the latter to enable the developer to negotiate with the Environment Agency in order to mitigate the risk of managed retreat on the operator’s assets. (panels, batteries and other plant)   This has enabled the developer to now claim that the panels will only cover 55% of the site (as if this in some way reduces their impact) and to include the extra land and the SSSI as part of their calculations concerning the benefit to the environment that they suggest the power station will create. This raises serious issues regarding responsibilities and wider governance.

3. Flood Risk –These marshes are a protective floodplain for Faversham. The seawall is currently the responsibility of the Environment Agency and therefore under democratic control. If the Agency were to delegate responsibility to the operators of the site for the flood defences, they would be able to raise the height of the wall at will in order to protect their assets. This lack of public accountability for such important actions is unacceptable. We also have concerns about the impact of insulating such a large area of land from inundation – most particularly on increasing the flood risk in Faversham town - already prone to flooding. The marsh area has long been a coastal floodplain.

Proper quantitative modelling of the long-term risks of the flooding of our town and surrounding villages is required.

In addition, it is our understanding that a large battery area (apparently the size of 15 football pitches) that developers intend to construct, will be built so as to block the existing drainage ditch which separates Graveney and Cleve Marshes.  Moreover, the whole area is to be surrounded by a high earth bund.  This will increase the risk of flash-flooding across and more particularly beyond the site in the downpours that are occurring with increasing frequency.

4. The governance of the SSSI - We are equally disquieted about the fact that because of the recent enlargement of the site the future of an important SSSI will be put into the hands of a private sector developer. We know that the way that SSSIs are managed is critical and without oversight, by a public body we are not confident that the incentives of the developer and operator would ensure the long-term protection of the site. The SSSI appears to have been included to assist the developer in increasing the biodiversity of the site merely by acquiring land already managed for diversity.

5. The Height of the Solar Panels
   The proposed site was originally tidal saltings and is a Category 3a Rising sea levels and more violent weather events both threaten the site. As a consequence, if construction were to go ahead, the developer has said the panels need to be ‘around’ 4 metres high, just short of the height of a double-decker bus.* This would be a severe detriment to the amenity value of the marshes to all those local people and visitors who use them. 

The industrial landscape created by the panels will also be completely visible from viewpoints such as Graveney Hill and Graveney Church, from Oare village, from the Isle of Sheppey and from all vantage points around Estuary View just to the south of Whitstable.  On the lower ground, the Society questions the developer’s assertion that the panels will not be visible above the sea wall.   This hides the panels’ effect on the amenity value of the Saxon Shore Way, shortly to become part of the Coastal Path, because this path runs atop the wall, not on the shoreline below. Even so, the panels will be visible above the seawall when walking towards Nagden Cottages from Faversham on the east side of the Creek and from Faversham to Hollow Shore on the west side of Faversham Creek - including the views from Oare Nature Reserve at Harty Ferry.

6. Archaeology
   The Historic Environment Desk Based Assessment commissioned by the developer reveals that the site and its immediate environs make an important contribution to the historical and cultural setting of the town and that the creation of a large power station - albeit solar - would ignore Faversham’s historical importance and compromise the setting of the town and its neighbouring villages to the north, Graveney and Goodnestone. We have evidence of medieval saltings and of a historically significant duck shoot that would be obliterated by the panels. We have seen no assessment of the damage to the archaeology of the area covered by the site.
7. Noise and Disruption
   If developers are forced to halt work over each summer’s bird nesting season and to avoid disturbing overwintering birds, it is likely that the work will be spread over perhaps three or four years. This means that for residents close to the site and those living on or using the roads leading to it, there will be unacceptable noise and disturbance caused by construction traffic to and from the site over a long period.

The Faversham Society is also concerned about the level of disruption that will continue during the normal running of the power station. Although there is some technical detail, we have seen little intelligible analysis about the cumulative level of noise generated by the inverters, transformers, battery packs and other elements of the energy production process.

Neither is there a convincing presentation about the level of, noise, light and air quality pollution caused during the construction phase.

8. Access and Traffic
   This is a very large site that would not only be covered with new solar installations but would also require substantial works to provide the roads, new ditches and the electrical plant - including a substantial compound for battery storage. The Faversham Society is concerned that the roads to the site, in particular, Head Hill Road and Seasalter Road are not suitable for the weight and frequency of traffic required to transport such a high volume of materials and equipment to the site.  We are unclear about future responsibilities for road maintenance, repair and general restitution.

 The developers have provided no information about the level of traffic to be expected nor any modelling on the effect that this will have not only on roads leading to and from the site but those in the wider area such as the M2, the A2 and the Thanet Way.  Society members know that it only takes a little extra traffic or a small accident to reduce the entire local road network to a standstill.

9. Wildlife
   Although the noise and disturbance is a cause of anxiety for residents and the loss of amenity value distressing for those all who currently use the marshes, there is a much more serious and detrimental impact on wildlife. Construction of roads and excavation of ditches, the creation of culverts, clearing of the ground by removing plants and topsoil and installation of equipment would result in the whole site being unavailable as nesting habitat for ground-nesting birds nor as a feeding /foraging habitat for birds, bats and other animals and insects over a long period.

The site forms part of the North Kent Marshes Environmentally Sensitive Area. It is also directly adjacent to the Swale Ramsar site which is designated because it has an important assemblage of bird and plant species.  The site will also affect the Swale Special Protection Area and the Swale Site of Special Scientific Interest, the South Swale Nature Reserve and the Swale Estuary Marine Conservation Area and on the opposite side of Faversham Creek, the Oare Marshes Nature Reserve managed by the Kent Wildlife Trust.

Source: www.kentwildlifetrust.org.uk/campaigns/planning-and-development/cleve-hill-solar-park

The Faversham Society’s initial analysis suggests there should be particular concerns about the following species:

The developers propose to preserve and improve a small part of the marsh at the eastern end of the site specifically for Brent geese, lapwing and golden plover. (It is worth noting that this includes the additional area within the SSSI to the east of the site proposed in the original scheme.) The Faversham Society considers that this gesture would not compensate for the loss of wildlife habitat across the whole site and cannot be considered mitigation for this wider destruction of habitat.

The Society notes that a recent European Court of Justice ruling regarding Habitats Regulation Assessment suggests that a full ‘appropriate assessment’ will have to be completed to prove that there is no harm to the Swale Special Protection Area beyond reasonable scientific doubt for the scheme to be acceptable.

10. Soil and Soil Erosion
    Developers propose to create what they have called ‘grazing land’ under the panels with a mix of grasses and wildflower They propose the grazing of sheep. Even if this were to prove possible, such plans are less than adequate compensation for the loss of such a large, grazing marsh so productive of wildlife.

The solar panels will prevent the soil from absorbing rainwater and will concentrate the flows so that rainwater will cascade onto the ground, causing soil erosions and general degradation. Moreover, the Society has yet to be assured that the ground beneath the panels will have sufficient sunlight to permit much vegetation and therefore animal life beneath the canopy of panels. We have seen no evidence to allay our fear that a ‘desert’ will be created over a very large area. Comparison with other solar panel sites is of little relevance because of the size, height and density of panels proposed for Cleve Hill.

11. Landscape, Amenity and Economic Value
    The site forms part of a Kent Area of High Landscape Value and a Swale Area of High Landscape Value. The site is visible from long distances including Wraik Hill on the A299 at Whitstable, from Estuary View, from Boughton Hill on the A2 and from Oare village to the west of Faversham Creek – all which have extensive views encompassing the whole marsh, grazing land, fruit farms and orchards. It is an area of high amenity and economic value. However, the developer’s intentions will completely change this view of open arable and wildlife marshland to a landscape with column after parallel column of dark panels stretching into the distance from almost every point of view.

The extent of this change is hidden because of the photograph viewpoints that the developers have included in their promotional material for the public to assess the full impact of the proposal.  Those images chosen by the developers suggest that the panels will only be seen when people are close to them rather than showing the more important views of the middle and long distance.  We believe that a 3D computer model allowing the public to ‘see’ the site from all viewpoints would allow a more realistic assessment of impact.

The size of the site and the multiple points from which the panels and other site infrastructure will be visible will change the character of what has been a huge, open area of grazing and arable marshland into a heavily industrialized and developed landscape. This will create a loss of inestimable value to visitors and to local people, not just in the immediate future but for generations.

This will have a knock-on effect on the local economy.  The Faversham and Graveney Marshes ‘brand’ attracts a large number of visitors – whether interested in history, marine life, birds or general recreational walking - to this part of Swale. Although developers assert that for Kent the impact will be negligible, we have seen no analysis of the short and longer economic impact the development will have on Faversham and the businesses that support and service our visitors.

12. Footpaths
    The entire footpath through the site from Nagden Cottage to the seawall near Castle Coote, would – if the development goes ahead as proposed  - run between lines of solar panels 4 metres high making it impossible for walkers to see over them. Any additional permissive paths provided as part of the development would have similarly stark industrial views.

As we have noted above, the Saxon Shore Way runs along the top of the seawall, and so any walker from Faversham to Seasalter would start by looking along the parallel ranks of solar panels and then as they turn east looking over row after row of panels stretching east to west to the back of the marsh. The monotony would only be relieved as walkers passed gaps for the spine road and the drainage ditches. At the eastern end of the site, walkers’ next view would be the battery compound and sub-station across the grazing marsh.  Walking the Saxon Shore Way from the Seasalter Road end, there would be views of the sub-station and other works and across the marsh towards the solar panels extending to the sea wall. New security fencing and surveillance is also expected to be installed along all footpaths which would add to the unsightliness and serve to intensify the hostile industrialised atmosphere across the marshes. The character of all of these well established and much-used footpaths that are part of the Saxon Shore Way would be changed beyond recognition. On a more detailed point, we would want to be assured that the footpath across the site from Nagden to Castle Coote would remain open during the construction phase.

The Faversham Society considers that the detrimental impact on the amenity of users of the footpaths both through and around the Cleve Hill Power Station would be unacceptable both in the short term during building works and in the longer term once the panels were connected to the grid and battery storage was installed.

13. Identification and Mitigation of Long-Term Risks
    There are two questions about which the Society, local elected representatives and in time the wider public will need more assurance. Our first concern is the business assumptions on which the development is based. As we have seen recently with the Swansea Bay Tidal Lagoon scheme, huge developments like the Cleve Hill Power Station are highly dependent on the demand for and the pricing of electricity over the long term.   We believe the assumptions made by the developers about this should be made public. We want to know how sensitive those assumptions are to national and global shifts in the energy market over what timescale.

We also want to know what account developers have made for the growing acceptance that the days of old national grid-based approaches to energy production and supply are numbered because they will be supplanted by the much more cost-effective and environmentally ‘green’,  distributed  generation,

 This vulnerability to national and global events over the long term leads to our second major concern.  If the site ceases to be economically viable – and most especially if the developer’s company fails and goes into administration - who will be responsible for decommissioning the plant and restoring the marshes to their original condition? Without explicit reassurances and guarantees from developers and planning authorities, the risk of having a very large and redundant industrial plant covering such a large area would be unacceptable to the Faversham Society, to the public at large and most likely to their elected representatives.

We are concerned that there has been no information about the public health and security risks associated with the development.  We understand it is proposed to construct the largest battery in the world covering ground equal to that of 15 football pitches. We would like to know about the environmental risks of fire and/or explosion and what arrangements will be made to mitigate the effects. It may surprise developers to learn that the people of Faversham and their elected representatives are particularly sensitive to the risk of large industrial explosions and the social, economic and environmental damage they wreak.

14. Alternatives Sites

There are numerous alternative brownfield sites – even in this corner of the country. Kingsnorth and the Hoo Peninsular are obvious candidates.  The Faversham Society needs clarification about why the Cleve Hill site has been chosen above others.  If – as has widely been rumoured – it is attractive to developers solely because of the spare capacity on an existing and underused national grid connection, we do not believe that this is sufficient justification for the devastation which such a large - albeit solar - power station will create.

 We also understand that although there can be economies of scale with other forms of energy production, this is not the case for solar energy since solar technology (panels and batteries) can be scaled incrementally, having numbers of smaller sites would deliver much the same returns. We would like to see the differences in long-term viability between a far less intrusive multi-site model and the single site devastation that is being proposed for Cleve Hill and the surrounding marshes.

 Losses and Benefits

As we have made clear, this unprecedentedly large solar power station will have a profound negative impact on the people that live in Faversham and the surrounding villages.  Although it is these local people who will suffer the losses if this development goes ahead, it appears that as currently conceived, it provides no direct benefit for them either in the short or long term.

That lack of attention to what in other large development schemes would be known as ‘planning gain’, demonstrates the lack of regard or concern that developers and builders of the Cleve Hill solar power station have for the interests of the people of Faversham and the surrounding villages.

The Faversham Society’s response to Phase 2 of the statutory consultation

The full response can be viewed in PDF format here

*The new London Routemaster is 4.38m high

The Kent Wildlife Trust view is here
CPRE

British salt marshes 'to disappear' as sea levels rise

Save Graveney Marshes

Helen Whately

Planning Inspectorate  Cleve Hill