Botley West Solar Farm

BBOWT’s initial response to the Botley West Solar Farm proposals

Monday 5 December 2022

Summary

We are aware of the proposals for the Botley West Solar Farm and have reviewed the limited information currently available. Whilst we understand the need for greater renewable energy, we have concerns over the scale of the plans and the lack of information on the impact of the proposals on the local natural environment. As a wildlife conservation focused organisation, our comments refer specifically to impacts on species and their habitats which may occur as a result of the proposed development.

Issues

We understand the need for sustainable renewable energy in order to tackle climate change. However, it is important that the impacts of new solar farms on the local environment are properly assessed and areas of existing high wildlife value habitat are avoided. We are concerned that the true nature of the potential impact of the proposals on the local environment cannot be adequately ascertained, given:

• the scale of the proposed Botley West Solar Farm
• the lack of comparable solar farms in terms of size
• the limited research into the effects of solar farms of this scale on the local environment.

We set out a number of our concerns below.

Industrialised areas, not green spaces, for solar farms

Green spaces should not be the first choice location for solar panels. Our region is under huge development pressure with a never-ending stream of proposals for new housing or the industrialisation of areas. New developments, particularly warehouses with huge roofs, should be seen as the first choice for new solar panels. It seems peculiar that enormous warehouses are permitted with huge bare roofs that could have solar panels on them when we have such a need for renewable energy. Solar farms on green fields represent a semi-industrialisation of part of our countryside, so covering our already industrialised areas with panels where possible, should be the first choice. The more solar there is on buildings the less need for land take there is for solar farms.

Risks to farmland birds

One particular area of concern is the impact of covering such a large area in solar panels on farmland birds. The impact of the change of management of the site on farmland birds must be fully assessed, particularly on ground-nesting birds such as skylarks. The impact on wintering birds which tend to gather in large open arable fields such as lapwing and golden plover should be considered if they have been present in the fields concerned. Such a huge solar farm could potentially cause huge damage to local bird populations so the risks need to be fully assessed.

The lake effect

A further area of concern is the “lake effect”, particularly for birds and insects. Natural England Information Note (Natural England Technical Information Note TIN101 Solar parks: maximising environmental benefits) states:

“Solar parks can affect wildlife where they are near sites of high wildlife value … There are some indications that very large, unbroken expanses of uniform solar panels may mimic water surfaces on which insects may attempt to settle and breed ... Some birds and invertebrates are also likely to be affected by solar parks developed close to areas of high wildlife value. Where a solar park is proposed within or close to such sensitive sites, the planning application should include a detailed assessment of the likely impacts on the ecological interest of the sites and contain practical measures which avoid or minimise any adverse effects on their features of interest. Any solar park close to a designated site will need to demonstrate that it would not compromise the objectives of the designation.”

The potential risk to birds and invertebrates is increased by the close proximity of the proposed solar farm to water bodies such as Cassington Gravel Pits (200m), Farmoor Reservoir (adjacent), and several rivers, such as the Evenlode and Thames. We do not believe it is possible to install panels in such close proximity to Farmoor without harm being caused to certain species. If, despite this, the proposal does go ahead so close to Farmoor Reservoir and Cassington Gravel Pits then much more buffering would be needed between the panels themselves and these sites. There is a particular risk with the southern site that, as it almost touches Farmoor Reservoir, the fields of panels and reservoir could look like one large lake to birds.

Additionally, steps would need to be put in place to prevent the “lake effect” within the fields such as adequately spacing out the panels and researching the effectiveness of panel coatings at preventing collisions with the panels and invertebrates laying eggs on them leading to mortality. However, at the moment we have no confidence that a solar farm of this scale could be developed in such close proximity to the water bodies identified above without risking wildlife at the sites.

Assess all solar farm proposals at the county-scale to assess their strategic impact

When the proposal is looked at alongside proposals for a solar farm close to Otmoor, Manor Farm at Denchworth, Red House Farm near Botley and other solar farms in our area, given the lack of definitive research and evidence on the impact of solar farms on aquatic birds and invertebrates, it seems a colossal experiment is being carried out on our local nature. We want to see much more evidence on the potential impact of the plans on wildlife and the mitigation to be put in place.

Unassessed/unclear impacts on Conservation Target Areas

In addition to the sites mentioned above, there are also a large number of local wildlife sites in the area and Conservation Target Areas, such as Oxford Meadows and Farmoor, Oxford Heights West, Blenheim or Ditchley Parks, Glyme and Dorn and the Wychwood and Lower Evenlode CTA. Detail must be given on how the proposal would impact on the ability to achieve the aims of the CTAs.

Impact on Biodiversity

The site currently outlined for development as the Botley West Solar Farm is 1,400 hectares. 400 hectares have been set aside as a mitigation and enhancement area, which means the biggest impact of the development will come from the 1,000 hectares to be covered in solar panels and other infrastructure. For this reason, it is important that if the solar farm does proceed, the biodiversity enhancements are not limited to the “mitigation and enhancement area” but are also embedded in the design of the 1,000-hectare panelled area.

For example, we note that wildflower grassland is to be planted under existing power lines. However, there is no detail on how the panelled fields which make up the majority of the site will be planted. The community leaflet says the intention is to keep the panels as low as possible whilst allowing opportunities for sheep grazing. Whilst we support the mixed use of land, the developer should research the successes of other solar farms in planting wildflowers alongside solar panels. Research should be carried out so that the height of the panels and the spacing between them allows sufficient light underneath to support species-rich grassland. Conservation grazing in parts of the site should also be explored to provide varied habitats.

As the largest (as far as we know) solar proposal in the UK, if the proposal does go ahead it must be exemplary in terms of doing everything possible to achieve the most species-rich grassland it can amongst the panels. Numerous ponds should also be provided in the margins around the panels to encourage colonisation by amphibians, reptiles and invertebrates. Hedgerows around the panels should be managed so as to maximise their benefits for wildlife, with rotational trimming at not less than a three-year interval, and also trimming further out so as to allow the hedgerows to slowly grow out in size. This management in and around the 1,000 ha of panels should all be additional to the biodiversity provision proposed on the other 400 ha of land.

As well as managing the space under and around the panels in a way to promote biodiversity, it is vital that all existing trees, hedgerows and woodlands are protected and the impacts of a solar farm on such features and habitats are known. We understand there is published concern around the impacts of solar farms on bat populations. As the area neighbours ancient woodland (see map, below) which often supports bats, we are particularly concerned about the impact of the proposals on bat populations. We are concerned that the middle section in particular of the proposed solar farm will create a break between areas of ancient woodland which could otherwise be improved for connectivity. The panelled areas appear to go up to the edge of ancient woodland which is unacceptable. Buffers for ancient woodland must be greatly increased or panels simply not put in the proximity of ancient woodland.

In terms of the mitigation and enhancement area, we will review proposals for such areas when they are published. However, we trust the developer will consult with local conservation organisations and ensure proper management plans are put in place. We also note that the community leaflet states that “following the end of Botley West’s operation, the solar equipment will be removed, and the site will be returned to agricultural use.” Biodiversity enhancements and new habitats created in the mitigation and enhancement areas must be maintained and long-term funding provided to ensure they are managed in perpetuity.

Security fencing and security lighting if included in the proposal would also be a great concern. Fences can have an impact on connectivity, since many mammals will not be able to pass it, and lighting should not be permitted at all as the impact in a rural area on wildlife would be significant.

The proposed solar farm must also not restrict people’s access to nature or their enjoyment of the countryside. Walking along footpaths through farmlands with hedgerows is an entirely different experience to walking alongside security fences, security lights (themselves a threat to nature), security cameras, and panels and people’s engagement with and appreciation of nature must be factored in to plans.

In conclusion

The Natural England report: 'Evidence review of the impact of solar farms on birds, bats and general ecology' states at the end of its conclusion:

“The lack of evidence available relating to the ecological impact of solar farms is concerning ... more needs to be done to understand the interaction between these new technologies and the ecology that they are ultimately designed to protect.”

At the moment there is insufficient evidence and detail to enable the true potential impact of the Botley West Solar Farm on our local natural environment to be known. More research is needed on the effects of solar panels on wildlife. Therefore a precautionary approach should be taken and the solar farm should not proceed until detailed assessments of the impacts of solar farms on biodiversity are carried out and the impacts of previously constructed solar farms in the UK are known. The proposed solar farm is clearly absolutely huge so its potential impact on our local wildlife cannot be underestimated.