2nd February 2021
20/03403/FUL – Site at Minchens Lane Bramley
Installation of renewable led energy generating station, comprising ground-mounted photovoltaic solar arrays, battery-based electricity storage containers together with substation, inverter/ transformer stations, site accesses, internal access tracks, security measures, access gates, other ancillary infrastructure, landscaping biodiversity enhancements including a Forest School, associated car parking and Nature Area.
Bramley Parish Council has now met to consider this application. After a thorough review Bramley Parish Council has concluded that it OBJECTS to the application. The objection is based upon a number of criteria including the application being in contravention of a number of Local Plan and Neighbourhood Plan polices alongside a number of other issues.
The following policies are contravened and the evidence is covered in the points below:
- EM1, EM7, EM4, EM5, EM8 of the Basingstoke & Deane Borough Council Local Plan
- T1, RE1, T2, RE3, D1 of the Bramley Neighbourhood Plan (NP)
Bramley is adjacent to the northern boundary of the MOD training area, which means that the more rural footpaths in the Parish now lie in the northern quadrant of the Parish. A very well used route includes the Brenda Parker Way, which will be surrounded by this proposed development. Bramley footpath 7 and Silchester footpath 15 runs for around 1900 metres from Frith Wood to Three Ashes. 1475 metres of this would have panels on one or both sides. Silchester footpath 16 runs along the northern edge of field 2 for 850 metres and would have panels on one or both sides. Hedges and trees are to be planted to screen the solar panels, but this will completely remove the view across open fields that these footpaths currently enjoy, and will take several years to become effective. There have been paths through Bramley and Silchester since Roman times and before and the open connection between the two communities remains very important and essential to all.
Bramley PC recognise that green outdoor spaces are of prime importance to the mental well-being of people across the country – by removing these views of and walks through green open space is not acceptable at this time or indeed at any time. The adverse mental health issues resulting from the stress of “lockdowns” and the pandemic in general will last a long time, and to help ease the long-term burden on the NHS and the people it serves, everything must be done to protect those rights to access open space now and in the future.
It should be noted that planning application BDB/75469 for solar panels at Church Lane Farm was refused with the reason being “The proposed development by virtue of its siting in close proximity to a public right of way (PROW Silchester 13) would be highly visible and prominent and as a result would have a significant harmful impact on the visual amenity of the area and people’s enjoyment of the landscape from the PROW”. This proposal would be more prominent and massively greater in extent.
Bramley Parish Council therefore contend that the application does not comply with Local Plan policy EM1, which states that “Development will be permitted only where it can be demonstrated, through an appropriate assessment, that the proposals are sympathetic to the character and visual quality of the area concerned.” It further states that “Development proposals must also respect the sense of place, sense of tranquillity or remoteness, and the quiet enjoyment of the landscape from public rights of way. Development proposals will not be accepted unless they maintain the integrity of existing settlements and prevent their coalescence.” This application does not do that in any way. It also does not comply with Bramley Neighbourhood Plan policy D1, for the same reasons.
In the flood risk document, it states that “it is not considered necessary to undertake infiltration testing or provide a controlled discharge to a watercourse.” Bramley Parish Council believes that at the very least infiltration tests should be conducted – local knowledge suggests that rain tends to run off the surface, as evidenced by the balancing pond at the Minchens Lane development and the irrigation lagoon included in the site. The run off from field 2 will be increased as the panels cover a significant proportion of the surface and flooding on the adjacent Bramley Road will be increased. Local Plan policy EM7 should be considered, as well as Bramley NP policy RE1.
Bramley Parish Council has severe misgivings about the transport assessment. In the section dealing with the access from Minchens Lane no mention appears to be made of the volume of traffic which already uses this single-track road. The Bramley Parish Council traffic survey in 2019 (https://www.bramley-pc.gov.uk/wp-content/uploads/2020/10/Bramley_Traffic_Review_2019_local_optim.pdf) put this figure at about 1500 per day. Avoiding the traditional rush hours will not be sufficient even if policed. School times lead to increased traffic as do shift changes at AWE Aldermaston. Oliver’s Lane to the south of field 4 will become extremely difficult for motorists, cyclists, pedestrians and horse riders. At certain times this road will be seriously affected by reflections from the south facing panels.
The extra traffic movements estimated for the development period will cause pressure on traffic in Bramley in general, and huge pressure on Minchens Lane. The large and heavy lorries in particular are going to struggle with accessing the site from the single track Minchens Lane, and all this is in close proximity to a number of other junctions onto Minchens Lane, in particular the Doctor’s surgery car park.
The plans indicate alterations to the field access road on Minchens Lane. The splaying of the entrance will result in the removal of ancient hedging and damage to animal/bird habitats.
If this development could be completed in the ambitious time frame of 30 weeks, which based on experience at other sites is unlikely, and only be accessed from Minchens Lane, it would still lead to considerable congestion where the access track meets the Lane. This would still leave field 4 being accessed along very narrow single-track roads or a track between Withy Copse and Holdens Copse. Bramley PC feels it is doubtful if fields 1, 2 and 3 could be accessed in this way as it would entail a track of some 2km crossing 4 ordinary watercourses and traversing very wet land. This may well lead to the alternative access points being used with all the associated transport problems. Over 30 weeks (6 months), there are (with a 10% buffer) expected to be 1029 deliveries, two-way 2058 journey equating to 7 per day (14 two way). This is just for the solar farm aspect – the associated battery installation will generate a further 86 deliveries equating to extra 1 per day. Access to Minchens Lane could only be from the west along the C32 Silchester Road as the level crossing and traffic calming prohibits access from the east. Heading south down Minchens Lane is also not possible due to narrow single-track nature of the Lane.
Bramley NP policy T2states that “Development proposals will not be supported if it is demonstrated that there will be a severe adverse impact on road safety at the known traffic hazards that cannot be satisfactorily mitigated.” In view of the concerns above, Bramley PC believes that the Transport Assessment is not sustainable.
In the Biodiversity EIA no mention is made of the significant herd (approximately 60) of roe deer which range widely over the area. Funnelling them along the paths would be unacceptable both for the deer and walkers with dogs. This proposal would remove their habitat, access to feeding grounds, and restrict their ability to roam freely. There is also a good nesting population of Red Kites and Buzzards in the area, which are likely to be affected by ground mounted solar panels, especially over so large an area. Slow worms, grass snakes, frogs and toads in significant numbers have been seen on the site. The creation of a new footpath will further upset the existing wildlife. All this would be against Local Plan policy EM4, and Bramley NP policy RE3.
Important Views & Vistas
The Bramley Neighbourhood Plan identifies important views and illustrates them on map 6c. Vista 4a and views 1, 7 and 8 would be severely impacted by this development and view 9 would entail standing under panels. The project will be highly visible to a considerable number of residents as evidenced by the applicants ZTV map. Bramley PC appreciate that the glint and glare will be mitigated by tree and hedge cover, but this will only be in the summer months. Minchens House (a grade 2 listed building), the north west corner of St James’s park, Moat Close, and numerous properties along The Street including the Conservation Area will be badly impacted. This is contrary to Bramley NP policy D1, as it will not complement and enhance the historic character and rural setting of Bramley, and Bramley NP policy D2, as it is unlikely to be well integrated with its surroundings. All views besides those listed in the NP support the historical agricultural, rural history of Bramley and have to be protected. There would also be a severe impact on the Silchester Conservation Area around Three Ashes.
Moreover, Local Plan policy EM5 states that development proposals will only be permitted where they do not result in the fragmentation of the green infrastructure network by severing important corridors/links. This application will remove 50% of the green corridor between Bramley and Silchester. Furthermore, the site is very large – more than twice the size of the village centre at Silchester, and approaching the size of the village centre of Bramley. Bramley PC understand that, should it be built, it will be the fifth largest solar panel site in the country. The other four are all on brownfield sites and not on prime agricultural land.
The Bramley Conservation Area including St James Church will be impacted by this intrusion onto the landscape.
The County Archaeologist has identified a villa complex on the site which potentially has national importance. It is understood that a dig is planned for the villa complex in the next couple of years, and Bramley PC believes that it would be prudent to delay any development of the area at least until the full implications of this dig are understood. It would be instructive to identify the area marked E1 in field 6 before it is “put out to glass.”
There are a further 2 archaeological sites, and all of these could be damaged by any pilings installed for the development. In addition to these, Bramley Frith, Little Holden Copse, and Withy Copse are listed as Sites of Importance for Nature Conservation (SINC), and Bramley Frith and Withy Copse are also listed as ancient woodlands.
Around 53% of the site is classified as good agricultural land. Government guidance suggests that brownfield or less good land should be used. This loss of productive land will lead to more foodstuffs being imported potentially impacting the supposed carbon reduction. Fields 5 and 6 have been drained within the last 5 years and an irrigation pond constructed in the last 20. This has enabled a great variety of crops to be grown. It should be noted that, even with land drains heavy equipment still becomes bogged down even in summer.
Local Plan policy EM8 (Commercial renewable/low carbon energy conservation) does not promote the use of greenfield sites for solar farms. It refers to the approach of BDBC to achieve renewable energy in the “Renewable Energy Study” which states ways of achieving this green energy. Whilst this form of renewable energy is important, this site is completely inappropriate for the long-term future of Bramley, whose residents have stated repeatedly that they wish to retain the rural aspect of Bramley, a key aspect of the NP. It will damage the settings of the historic woodlands, farms and walks that reflect the agricultural history of Bramley which the residents of Bramley want to preserve.
A number of these have been offered:
- A new permissive footpath – this will impact on existing wildlife, as has already been mentioned elsewhere in this response.
- Nature Area and proposed Forest School Community Area – the Bramley and Silchester areas are already well served with such facilities, at Bramley Frith and the nearby Pamber Forest.
- Information Boards on public footpaths advising about solar energy and the biodiversity features of the proposals – it is very questionable that filling the countryside with notice boards enhance the rural nature of the area.
- Allotments – the proposed site is well away from any dwellings, and would not be accessible by foot. Almost all users would need to use a vehicle to get to the allotments. Bramley Parish Council do not support the inclusion of allotments, particularly in such a location, to be a community benefit.
There are no discernible local benefits to this project. If successful it would be Bramley village yet again providing benefits to a wider community to the detriment of Bramley’s cultural heritage and well-being. This would further make Bramley unsustainable to meet local needs.
In the last 10 years Bramley will have given over to development (including Upper Cufaude Farm which will happen), over 6% of its surface area, all on sites outside the settlement policy boundary.
This application, if successful, would result in the loss of a further 40 hectares (approx) or 4% of total surface area with another 40 hectares (approx) adjacent to Bramley’s boundary with Silchester.
Bramley Parish Council felt that the location was beneficial to the applicant through its proximity to the Frith sub-station which was a profit led choice. There are alternative brownfield options within Basingstoke & Deane and the wider Hampshire area.
Finally, Bramley Parish Council note that there are a number of inaccuracies and inconsistencies in the application, and therefore question how many others there may be that have not been picked up.
Given all the points stated in this response, Bramley Parish Council restates its objection to this planning application.