industry insights

Everyone knows we need renewable energy – but not at any cost. So where should we put these industrial installations then?

Potterne Solar Action Group has been discussing with our local MP’s, Councillors and CPRE the need for a simple framework to help decision makers assess individual applications against a balanced set of Wiltshire’s strategic priorities

Strategic energy infrastructure should be sited where it makes sense.  

It needs to be a question of balance when assessing the case for ground mounted solar.  To ensure that the need to protect the environment, our countryside and our farmland is factored into decision making as well as the need for green energy.  

This framework is drawn from material produced by CPRE and Wiltshire Council.

10 Dimensions to consider:

1.  Strategic Fit of the site with the needs of the national grid

·  is there grid capacity in this area or is the grid constrained?  

·  Does the proposal meet the strategic direction set out by Ofgem (2023 BEIS/Ofgem Connections Action Plan)?

·  Are the claimed benefits of houses powered and carbon footprint gains credible according to the UK Government Clean Power 2030 Action Plan (Dec 24)?

2.  Landscape sensitivity and amenity

·  is the site a “hidden project” or is it in an area of high sensitivity as expressed in Wiltshire Councils planning guidelines – Wiltshire Council Renewable Energy Study (March 2023).  

·  To what extent is the site impacted by PRoW’s that are used for physical and mental well-being.

3.  Agricultural Land

·  Is the site on valuable agricultural land?  

·  Will ground mounted solar on this site fundamentally alter the character of the landscape and rural way of life of the area?

4.  Ecology

·  To what extent is the site of importance to wildlife and the local ecosystem? - Our wildlife is in chronic decline.  Britain has the worst record of habitat and ecology depletion in Europe.  It is important to recognise the need to protect endangered species as they cannot protect themselves.  

5.  Heritage 

·  is the site of cultural and historical significance?

6.  Access and operation

·  To what extent is the site readily accessible for construction or does it pose a threat to safety and unreasonable disturbance during construction and operation.

7.  Cumulative Effects

·  Wiltshire has already more than met its 2030 targets for solar.  We can afford to prioritise other needs and still lead the way by placing solar investments in areas that do not overload villages and take away the very reasons why “Wiltshire is such an attractive place to live in” – as per the motion raised by Cllrs Alford & Botterill at the Wiltshire Council meeting in May 2024

8.  Local and Neighbourhood Plans 

·  is the site compliant with local plans or is the site in an area designated as not for development?

9.  Professionalism of the application

·  to what extent has the applicant followed due process, been accurate in their submission and provided comprehensive studies to ensure these decisions can be taken based on fact.  

·  Is there a credible organisation (including financial capability) in place that can deliver the proposal and will meet all requirements deemed necessary by the planners.

10.  Regulation

·  How is the applicant being held financially accountable for returning the site to agricultural land in 40 years’ time. 

We have a food crisis, a countryside crisis, a biodiversity crisis and a mental health crisis as well as an energy crisis.  It should not be a case of “any solar is good solar”.  We can have it all and we should insist that we do.  

The NPPF states that planning authorities should not require applicants to demonstrate the overall need for renewable energy and should give significant weight to the benefits associated with renewable energy. However, IF there is considered to be a fine balance between benefits of a particular solar farm proposal and its adverse local environmental and societal effects, THEN careful scrutiny is required to ensure the quoted green benefits of the development are indeed achievable. Potterne Park Farm Solar is palpably one such case. 

Typically, solar farm developers quote annual carbon benefits by using an estimate of annual solar energy generation and applying an offset factor that assumes that the ‘clean’ solar energy displaces electricity generated by fossil fuels. For instance, for Potterne Park Farm, the developers assume a factor of 430g carbon dioxide eq. per kWh electricity generated. This factor is consistent with the carbon emissions intensity of electricity supplied by using a mix of non-renewable fossil fuels. 

However, the standard way of calculating carbon benefit for renewables is by using the ‘average grid carbon intensity’ — the average amount of CO2 emitted for each kWh of electricity produced for the grid, taking into account the prevailing mix of ALL fuel types, renewables and nuclear. This is a fairer reflection of carbon benefits as it better reflects the grid carbon intensity during typical periods of major electricity generation from solar (during the day in sunny months when the grid carbon intensity is lower). 

The recently published UK Government Clean Power 2030 Action Plan (Dec 24) predicts a reduction in the average carbon intensity of our electricity generation “from 171g carbon dioxide eq. per kWh in 2023 (ref. Digest of UK Energy Statistics 2024 Table 5.14) to well below 50g carbon dioxide eq. per kWh” in 2030. Obviously successful delivery of these targets will require rapid deployment of new clean energy capacity across the UK, but for the marginal renewable energy projects that need to be carefully deliberated due to adverse local impacts, these carbon intensity factors should be considered. For Potterne Park Farm Solar, using the 2023 average grid intensity factor would reduce the annual carbon benefit (as quoted by the developers in the planning application) by 60%. Furthermore, it would reduce to less than 12% of the quoted annual benefit in 2030 (using the planned average grid intensity of less than 50g carbon dioxide eq. per kWh instead of the 430g figure). 

Another important issue to consider is the inherent carbon footprint of the solar development. The Potterne Park Farm developers acknowledge in Section 8.1.3 of their Design and Access Statement that it will take 2.5 years of generation to offset the carbon footprint associated with the manufacture and transportation of the solar panels. For Potterne Park Farm Solar there is also an additional carbon footprint from having to build a new substation (estimated based on a similar design as 9,000 tonnes CO2 eq. or approximately an additional one year of the solar farm benefits). 

Numerous comments by the public on this portal have highlighted the grid congestion challenges in this area (as evidenced by information on the current SSEN website). This is likely to lead to curtailment of generation which would only defer benefits further into the future when the grid intensity is planned to be lower. Indeed Potterne Park Farm, as a generation only project into a constrained grid, will only compound the problem of historical underinvestment in the local and national electrical infrastructure. It does not align with the current Department for Energy Security and Net Zero strategic vision which underpins the National Energy System Operator (NESO) Connections Reform. Wiltshire Council should only consider renewable projects that meet their county objectives of energy security combined with grid resiliency. 

The incremental carbon benefit from Potterne Park Farm Solar would only turn positive well into the 2030s, and then, due to the expected low national grid carbon intensity, the incremental benefits would be marginal and would certainly not justify the very serious immediate and lasting local environmental impacts. 

Solar technology is a force for good …but not when it is sited in the wrong place.