Newcastle Airport is consulting on plans for a huge solar farm in the Green Belt north of Havannah Nature Reserve. The proposed sites lies within the Ouseburn Catchment Wildlife Enhancement Corridor, close to several Sites of Local Conservation Interest.
While we welcome a move to renewable energy, we are concerned about further loss of Green Belt and the erosion of an important wildlife corridor.
We have submitted a detailed response to the airport’s online consultation, which is set out below.
Save Newcastle Wildlife is concerned with protecting wildlife and green space in Newcastle. This document is our response to Newcastle International Airport’s (NIA) consultation on the proposed solar farm project on land adjacent to the Main Road, Dinnington/Brunton Lane and Coach Lane junction.
We welcome NIA’s efforts to reduce carbon emissions and create renewable energy opportunities, however, are concerned by the prospect of further loss of Green Belt and natural green space to make way for more built development. If approved, this application would see the loss of moderate to good agricultural land, further fragmentation of an important wildlife corridor and could compromise important habitats in adjacent designated wildlife sites.
Newcastle lost 9% of its Green Belt with the inception of the Core Strategy and Urban Core Plan (CSUCP) and cannot afford to lose any more. CSUCP Policy CS19 states that the Green Belt should ‘safeguard the countryside from encroachment’ and ‘check unrestricted urban sprawl’. It also sets out the need to encourage the recycling of derelict and other urban land. In this case, NIA already has developed land with capacity to provide solar energy.
Paragraph 147 of the NPPF states that ‘inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances’. There are no very special circumstances to justify this development.
Paragraph 151 of the NPPF states that:
‘When located in the Green Belt, elements of many renewable energy projects will comprise inappropriate development. In such cases developers will need to demonstrate very special circumstances if projects are to proceed. Such very special circumstances may include the wider environmental benefits associated with increased production of energy from renewable sources.’
We do not believe very special circumstances exist to justify developing this land, given that NIA has suitable land in its ownership to create renewable energy opportunities and has not thus far optimised local renewable energy in its operations to date. The current proposals would compromise green infrastructure and biodiversity. Additional development on Green Belt land adjacent to Havannah Nature Reserve has already been given the green light by Newcastle City Council and these proposals, if approved, would result in further, unacceptable loss of Green Belt. Furthermore, NIA’s plans to expand the airport runway and increase passenger growth would undermine the environmental benefits of such a project.
The proposed development sites lies within area ‘E 30:South of Airport’ as detailed in the Newcastle Character Assessment, which considers existing plantations, hedges, hedgerow trees and Dinnington Road Fen as key strengths. A huge solar farm would be a blight on the landscape and detract from the landscape character of the area.
Planning practice guidance states that the deployment of large-scale solar farms can have a negative impact on the rural environment. The rural character of the surrounding area has already been degraded and further loss of Green Belt would exacerbate this. Guidance also stipulates that solar farms should be prioritsed on previously developed and non-agricultural land. With this in mind, we understand there has been a decreased demand for the airport car park, which will likely continue as more and more people choose not to fly. We would be interested to know what consideration has been given to the installation of solar panels on land that is already developed, such as the car park, or indeed the installation a roof on the car park with PV capacity, thus minimising harm to the natural environment.
Biodiversity and Green Infrastructure
The application site lies within the Ouseburn Catchment Wildlife Enhancement Corridor (WEC), which has already been fragmented as a result of overdevelopment in the area. CSUCP Policy DM29 states that:
‘Development which would have an adverse effect on the biodiversity value or connectivity and function of the Wildlife Enhancement Corridor as designated on the Policies Map, will only be permitted where adequate mitigation is secured.’
This development would have an adverse effect on biodiversity value and connectivity and function on the wildlife corridor, which cannot be adequately mitigated for.
Policy CS18 of the CSUCP seeks to maintain ‘a high quality and comprehensive framework of interconnected green infrastructure that offers ease of movement and an appealing natural environment for people and wildlife’.
The security measures likely to be associated with the proposed development, such as fencing, will severely hamper movement of wildlife. We are also concerned about the impact of associated infrastructure, inverters and connection boxes and the impact of this on green infrastructure assets.
Policy DM27 states that ‘any development that would have an adverse impact on green infrastructure assets will be required to demonstrate that the benefits of any development will outweigh the harm.’
We do not feel that further degradation of this important wildlife corridor can be adequately mitigated for and are concerned that any security measures, such as fencing and lighting will have a significant adverse effects on wildlife in the area. Lighting in particular has been found to be particularly harmful to invertebrates and other nocturnal wildlife and efforts should be made to minimise lighting around designated wildlife sites.
While research shows that solar farms may be more beneficial to biodiversity than intensively farmed land, it is acknowledged that ground-mounted PV panels have the potential to have the greatest harm on wildlife. The existing land is not intensively farmed and the proposed development would result in direct habitat loss, as well as displacement of species. There is also evidence to suggest that wildlife avoids solar farms. For example, ground-nesting birds require unbroken lines of sight and ground-mounted PV panels would have an adverse effect on visibility. PV panels on agricultural land would have an adverse effect on farmland birds, particularly Lapwing and Skylark, which are a priority species in the Newcastle and North Tyneside Biodiversity Action Plan (BAP) by reducing opportunities for foraging and breeding. It is worth noting that overdevelopment in the vicinity has resulted in significant losses in arable land and therefore opportunities for ground-nesting birds. Not only would the proposed development result in direct loss of habitat and forage for ground-nesting birds, but the introduction of more trees could further compromise nesting opportunities.
Studies have shown that species diversity around PV sites is lower than in adjacent grasslands. PV panels have the capacity to reflect highly polarised light, which can have an adverse effect on wildlife, particularly bats, birds and insects, which can mistake solar panels for water. Birds that drink on the wing can be at risk from collision with PV panels, while water birds may also confuse reflections from solar farms with water bodies. This would adversely affect their foraging and reproduction. Bats, farmland birds and bumblebees are all priority species in the BAP. Should the plans progress, the creation of pollen and nectar strips would support pollinating insects.
In addition to the loss and fragmentation of habitat and displacement of priority species, this application would see further loss of agricultural land, which poses serious questions around food security. Soils in the area are considered moderate to good and emerging soils policies highlight the need to protect soils. We understand that the site will be decommissioned after use, however, it is unclear how soils will be protected for the 25 years in which the site will be operational. We would be interested to know if there would be plans to keep the land in agricultural use, for example through the growing of shade-tolerant crops, during the operational phase. We understand the management of solar farm grassland often requires pesticides to prevent weed growth. It is unclear whether pesticides would be used on the solar farm, however, we would advise against this to protect local amphibian and invertebrate populations and to prevent run-off into adjacent watercourses.
Natural England recommends the avoidance of solar developments near to designated sites. Fox Cover Woods Site of Local Conservation Interest (SLCI) lies immediately to the west of the proposed development. Native woodland at this site is listed in the BAP as a priority habitat. This mature woodland is covered by a group TPO and provides connectivity with other wildlife sites within the area, as well as supporting ancient woodland indicators and a range of woodland birds. We are concerned about the impact of development on this site and would like to see a proper management plan in place.
Sunniside Pond SLCI is in close proximity to the proposed development site and supports Great Crested Newts. Amphibians are a priority species in the BAP and could be harmed from run-off during construction works. We understand there was a management plan in place for this site, but that it has not been implemented. We would like to see this plan revised and implemented as part of the proposals and to understand how this development will impact local amphibian populations, particularly the Great Crested Newt population, which has been adversely affected by overdevelopment in the area. The same would go for the impact on the Ouseburn.
Dinnington Road Fen SLCI is also in close proximity and supports fen and marsh habitats that are rare within the Newcastle area. The BAP set a target to improve the condition and increase the extent of Dinnington Road Fen. Surface water run off is not expected to affect local watercourses but we hope this will be fully explored before any development commences, as well as detailed plans for management of the fen area.
The proposed application site is in close proximity to Havannah and Three Hills Nature Reserve, which is already being hemmed in by residential development. This proposal would further compromise the wildlife corridor that supports wildlife in and around the LNR.
Paragraph 180 of the NPPF states that:
‘When determining planning applications, local planning authorities should apply the following principles:
if significant harm to biodiversity resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused;
Development in this location can be avoided, by introducing solar capacity on existing NIA structures. The airport recently developed a 175,000 square foot commercial site at AirView business park, however, we understand none of this development incorporated renewable energy. We would expect to see proposals to retrofit existing buildings, before encroaching on the city’s Green Belt.
We understand the planning application will be supported by mitigation measures and proposals for Biodiversity Net Gain, which is due to become mandatory for all new developments in England, however, it is not possible for this development, which would result in loss of Green Belt, displacement of wildlife and the fragmentation of an important wildlife corridor, to provide a net gain for biodiversity. We welcome proposals for tree planting to screen the development and provide ecological benefits but other important habitats, such as shrub, scrub and hedgerows should be considered. Should the proposals progress, we would expect to see detailed mitigation, as set out above for designated sites. We would also expect to see detailed ecological monitoring reports secured by condition, including pre- construction and post-construction monitoring to understand the impact on birds, bats, invertebrates and other priority species in the BAP.
While the proposals would support CSUCP Policy CS16 on Climate Change, consideration must be given to the additional environmental impacts that would arise from such a development. The manufacture, maintenance and disposal of PV panels has a significant impact on the environment, from the harvesting of raw materials and the energy used in cooling and cleaning, to the energy and chemicals associated with decommissioning and recycling these products.
We also understand NIA has not ruled out a new runway and is negotiating with airline providers to increase passenger numbers and therefore demand for flights. If NIA is indeed serious about reducing carbon emissions, we would expect to see more discussions taking place around the introduction of electric planes and alternative fuels, ahead of discussions around developing Green Belt land. It would therefore be very difficult to demonstrate how the environmental benefit gained from this renewable energy project would outweigh the harm caused by ongoing growth and expansion of the airport and its operations, so there would be no very special circumstances for more development in Newcastle’s Green Belt.
To summarise, the impact of the proposed development on Green Belt, green infrastructure and biodiversity would be too great to be deemed sustainable.