PINS Letter

Cassington Parish Council have asked on multiple occasions why alternatives to the proposed scheme have not been considered?

If this project was a public project undergoing submission under Greenbook Rules it would require the listing of alternative options including their costs and benefits (monetised and qualitative) and then selection of a preferred option based on careful analysis.

• The geographic location of the current scheme, especially given that land further north which may be more suited for this development (i.e. is flatter) is present and is in the hands of the main land owner.
• The mix of renewable energy which currently comprises only solar power when wind is available and also, potentially hydropower.
• Whether a smaller scheme using more advanced and more efficient solar cells would achieve national, regional and local objectives with respect to renewable energy.

Indeed, at no stage have we seen a written justification of the proposed scheme, which has changed little since the project was first revealed to the public, compared to other options which are clearly available.

Pluvial flooding is a significant issue in the Parish of Cassington, affecting or potentially affecting the village of Cassington (Elms Road), Jericho Barns, and Worton Farm/village.

Concerns about flooding were not addressed during the public consultation event at Cassington because PVDP’s consultants failed to send their hydrologist to the meeting.

PVDP and their consultants dismissed Cassington Parish Council’s view that such a large number of sloped solar panels on the land above Cassington and Worton posed an increased flood risk. We believe this risk lies in three areas:

·       Solar panels will likely form a drip line increase the rate of runoff from arrays, a view backed up be the latest peer-reviewed scientific papers on the subject.

·       Compaction of the ground during construction and maintenance.

·       Disruption of land drainage systems lying underground.

Flood risk has been emphasised by several homes in Elm’s Road Cassington being flooded in autumn of this year, a repeat of flooding in 2007 and near-miss flooding events in the intervening years. Worton Farm and the Yarnton Road are also subject to flooding from runoff of the fields above the Cassington Sewage works which are also part of the proposed scheme. This has resulted in December 2024 of spillage of sewage as well as flood water into Worton Farm.

Cassington, Jericho Farm and Worton are vulnerable to flooding because they lie to the south of hills and the land comprises clay which includes numerous springs.

Some verbal reassurances that flood prevention measures would decrease flood risk to Cassington are not an appropriate response when people’s homes are at risk.

Although not part of the consultation, the ES provided as part of the application still fails to acknowledge the role of solar panels in increasing runoff and increased risk of pluvial flooding, the complexity of the watershed around Cassington or other potential impacts on drainage from construction. Furthermore, the offered solution to flooding in Cassington is vague (a number of balancing ponds etc) and detailed plans will not be considered until later in the planning process. This provides little reassurance for the Parish Council or residents of Cassington.

The solutions offered in the ES have not considered Jericho Barns or Worton and we note that information in Appendix 10.1 of the ES where it is stated there is no risk from sewage in flooding events has been proved wrong by the events of this week.

Large solar power stations such as the one proposed here have the potential to increase local temperatures in a similar way to the urban heat island affect. This is because solar panels absorb and then re-radiate heat, a phenomenon known as the Photovoltaic Heat Island Effect. Given the close vicinity of Botley West Solar Farm to residential properties this could lead to elevated summer temperatures affecting residents during the summer including both in the day and at night. Measurements over a solar power station, nearby urban environments and surrounding wildlands have indicated a warming effect of up to 3-4^oC depending on the season and time of day. Such heat retention could have significant impacts on residents in villages surrounding the proposed solar power station which is a particular concern given temperature rise resulting from climate change.

50% of the Parish of Cassington is taken up with the proposed Botley West Solar Farm. 71% of the solar farm is located on the city of Oxford’s Greenbelt which WODC have recently commented “is functioning well” around the village of Cassington. The proposed solar farm will severely impact on the landscape around Cassington Village, damaging its aesthetic and amenity values as well as damaging the Greenbelt.

Three out of five of the main footpaths from Cassington to surrounding areas identified in the Cassington Village Neighbourhood Plan are severely affected by the proposed scheme. This is because these footpaths for some or the majority of their length will be flanked on either side by solar arrays and other infrastructure. These footpaths go to Eynsham via Eynsham Mill (Footpath 4), to Purwell Farm (Footpath 1 ) and to Begbroke (Footpath 2).

Likewise, the loss of Greenbelt has been justified by the national requirement for renewable energy. However, the reason that the impacts of this scheme are so severe on both the Greenbelt and landscape surrounding Cassington is the location of Botley West Solar Farm on several river valleys in the area (also why flooding is an issue). This landscape characterised by river valleys and surrounding hills mean that the solar farm will be seen from some viewpoints for miles.

We also point out that the NPPF with respect to Greenbelt still requires strong justification for its use/loss. We believe that if PVDP had examined different options for the configuration of the Solar Farm not including the sloping land of the middle section, then this loss of Greenbelt could have been avoided.

At no stage, as a result of the comments of both Cassington Parish Council or many other residents of the areas affected by this proposal has PVDP or the landowners offered to re-examine the spatial configuration of the Solar Farm. We further note that in the Consultation Report submitted as part of the application in November “no comment” is made to Cassington Parish Councils identification of this issue.

We further note that Oxford County Council have pointed out that the landscape impacts of this scheme have been underestimated. No response has been given to this in the application.

We also note that West Oxfordshire District Council proposed that the Solar Farm be removed from the high ground to the north of Cassington. The response to this has been that the solar arrays will be screened by existing vegetation and new planting. This is an inadequate response and as it stands fails to mitigate from the visual impact of the scheme on the residents of Cassington and Jericho Farm.

Cassington Parish Council has pointed out in several of its responses that a large area of Best and Most Versatile Land (BMV) will be lost to this development for more than 40 years and potentially permanently damaged through compression of the land by groundworks and construction and alteration of hydrology. The PEIR identified that 38% of the land take for Botley West was BMV land. However, these figures require clarification as does the relative amount of BMV land covered in the northern, central and southern sections of Botley West. We have been advised that the proportion of BMV land covered in the central section of the proposal is much higher than 40%.

A buffer zone of 25m (extended from 20m) to residential property is used in the scheme. This is wholly inadequate to protect the views and amenity of properties on the northern side of Cassington, and at Jericho Farm. It also poses a risk to properties from the effects of noise during construction and operation, Photovoltaic Heat Island Effect, accidental fire and the effects of destructive weather such as tornados (three experienced in the vicinity of Cassington and Eynsham in the last 10 years) which may damage or break solar panels and scatter pieces of glass and other infrastructure over a considerable distance.

The information provided includes comments on 57 boundary changes along with thumbnail maps showing where boundary changes are proposed. These maps and associated descriptions of the changes to the proposed scheme were wholly inadequate, in many cases lacking important detail or left so open as to leave the reader unable to assess what likely impacts were going to be (for example, making a substantial boundary change for a cable crossing point somewhere within the designated area). Examples of inadequate information included:

• Not showing the actual rights of way on thumbnail maps.
• Not providing any information on the environment other than general habitat types that may be affected in some cases. This was of material consideration as it left the reader unable to assess neither the amount of habitat lost nor the quality or the habitat (i.e. whether or not a hedgerow is “ancient”).
• Not showing local designations for nature recovery or habitats of national significance even though these are available on national databases and environment maps.
• Not showing nearby heritage assets so that potential impacts on archaeological sites for example can be assessed (e.g. Sansom’s Platt).
• In one case maps being so ambiguous that it is not possible to identify where the proposed change is (see 35 below).

This significantly lowers the value of the consultation as the nature of the proposed changes are not clear to the public as well as the environmental, amenity and heritage impacts. This suggests that as with the First Public Consultation, this second Targeted Consultation is inadequate, being deficient in the information it presents to the point where the public are unable to comment on many aspects.