Solar Farm Response Part 2 - 24/03422

Ecological Impact Assessment (EcIA) Issues

• Survey Deficiencies: Botanical surveys were conducted outside optimal periods, reducing accuracy. Key species such as Great Crested Newts, Hazel Dormice, and reptiles have not been adequately surveyed, and assumptions about their absence are unreliable. Birds like Turtle Dove and Corn Bunting are overlooked despite the site being a priority area.
• Biodiversity Net Gain (BNG) Concerns
• The proposal fails to meet the emerging 20% net gain target, achieving only 14%.
• Unrealistic habitat proposals: The feasibility of creating Lowland Deciduous Woodland and Wildflower Grassland is questionable, with inadequate methods outlined.
• Soil suitability has not been assessed properly, raising doubts about habitat creation claims.

Need for Expert Review

A professional ecologist should review habitat classifications, survey methods, and policy compliance while proposing alternative biodiversity solutions.

The application contains serious flaws in ecological assessments, breaches national policy on irreplaceable habitats, and fails to maximize biodiversity net gain. Further professional scrutiny and revisions are required.

5. Fire and Safety Concerns
The development includes lithium battery storage, which carries a significant fire risk, particularly given the site’s limited access for emergency services. The amount of water required to control a lithium battery fire could cause severe environmental contamination, including potential groundwater pollution. The risk assessment provided does not sufficiently address these concerns.

6. Highway and Access Issues
The proposed access routes for construction and maintenance vehicles are unsuitable, all depending on one C grade road. The narrow rural roads leading to the site are in poor condition and not designed to accommodate large construction vehicles. This will cause severe disruption to both local residents and the neighbouring Parish and would also lead to prolonged construction timelines. Furthermore, the required cabling works will pass close to residential properties, exacerbating disruption for residents.

7. Heritage and Visual Impact on Local Settlements
The application fails to fully acknowledge the heritage value of the surrounding area. The proximity to Berry’s Maple and other historically significant sites raises concerns about the visual impact on the local character and cultural heritage. Any industrialisation of this rural landscape is contrary to the original vision of New Ash Green, which was designed to maintain a green and open environment.

8. Site Selection and Justification
The justification for selecting this site is weak. The applicant has not demonstrated that this is the most suitable location for a solar farm relative to the grid connection point. More appropriate sites exist that would have a lesser impact on the Green Belt and local communities. The claim that power generation must be evenly distributed across the county is not a valid planning justification, as the National Grid is designed to transport power where needed.

9. Noise Pollution
The noise assessment for the battery storage area is insufficient. Given the valley’s topography, sound is likely to carry to nearby residential areas, impacting residents’ health and well-being. There is minimal background noise in this location, making even minor noise emissions more intrusive.

The Parish Council fully supports the request from the Senior Archaeological Officer, Heritage Conservation at Kent County Council, for further archaeological investigations to be undertaken. Additionally, the Council endorses the concerns and recommendations put forward by the West Kent Area Manager – Public Rights of Way & Access Service.