30 October 2019
Solar arrays in Hastings Country Park Nature Reserve
I am writing this open letter on behalf of the Friends of Hastings Country Park Nature Reserve in response to your piece in Hastings Independent Press of 18 October about the Council’s proposal to set up about 10 acres of solar arrays in the Nature Reserve for which the Council has the responsibility of stewardship.
We understand your wish to try to draw some red lines on the project as an implicit attempt to mitigate the inevitable tension between the Council’s primary aim of securing income from a solar installation there on the one hand and the environmental damage to a sensitive ecosystem on the other. However, we feel that, in the interests of good decision-making by the Council, some of the arguments behind those red lines need to be challenged. The matters concerned relate to 1) Biodiversity; 2) Concrete foundations and cleaning fluids; and 3) Farming and the protected landscape.
Your article suggests in its headline that solar panels bring biodiversity as a matter of course. This is frankly a tendentious statement and we would be interested to know on what studies you might be drawing to reach such a conclusion. As far as we and our advisers aware, existing independent research only suggests that biodiversity might increase under solar arrays in comparison to fields which are a monoculture in terms of a crop (e.g. barley). With conventional farming practices, these arable fields will have been managed to reduce biodiversity in terms of wild flowers, invertebrates and crop diseases.
This research cannot be interpreted to mean that biodiversity would increase in the fields immediately above and adjoining the Fairlight Glen SSSI and the field at North’s Seat which are being considered by the Council for solar arrays. As permanent pasture these fields are important in terms of carbon sequestration and provide a habitat or food for a range of flora and fauna. We regard it as disingenuous to try to argue that these fields are already “developed”, and are not greenfield sites. It is inevitable that the construction of solar arrays in these fields would result in the disturbance of the soil structure, loss of sequestered carbon, and a loss of biodiversity.
It is also inevitable that solar panels will have a shading effect on the ground beneath them, thus also reducing total photosynthesis, and hence carbon sequestration and biodiversity. In the initial report to the Council’s Cabinet in January, an estimate was made of the carbon supposedly saved by installing solar panels. From the Council’s studies so far we have not seen any attempt to factor in the carbon cost of making, transporting, installing, managing and eventually decommissioning solar arrays, as well as the continuing reduction in carbon sequestration. If the Council were to make this calculation (as it should) the result would indicate a substantial discount from the initial optimistic guess at carbon saved.
You suggested as one of your red lines that the fields might be managed in part with reseeded wildflowers. However, their creation and management also have environmental implications. To achieve any substantial biodiversity improvements, the soil across the whole fields would have to be disturbed. These sites comprise improved pasture, so simply seeding with a wildflower mix without doing anything else is unlikely to be successful. The wildflowers one might want are unlikely to establish well because these fields are nutrient-rich and there would be too much competition. Good soil preparation (with removal of topsoil if nutrient levels are high) is actually regarded as key to re-creation of wildflower meadows, be they real meadows containing only native species of local provenance, or the sort that are called wildflower meadows but where non-local species and non-native species are used.
If wildflower re-seeding with non-local provenance and/or non-native species is what is proposed there may also be issues with doing this close to the SSSI. In addition, the carbon input and loss for establishing and managing wildflower meadows would need to be factored into the Council’s estimate for carbon saved from installation of solar arrays (see above). We are also sceptical about the survival of wildflowers in the face of work required to maintain the panels.
2. Concrete foundations and cleaning fluids
We are pleased that you are now thinking about your red lines in relation to the foundations and cleaning methods, but it is optimistic to think that red lines against the use of concrete foundations and chemical cleaning fluids could be sustained in practice. Concrete is the foundation of choice for contractors installing solar panels because they provide a more stable structure than alternatives. But, of course, the manufacture and transport of concrete comes with a carbon cost. And its installation inevitably causes substantial damage to soil structure and thus to carbon sequestration.
We agree that it is sensible to try to stipulate that no chemical cleaning fluids should be used for any solar arrays, particularly given the risk that they might run off downhill into the SSSI site. But anecdotal evidence from other parts of the country indicates that, irrespective of what a cleaning contract might say, contractors resort to such fluids when faced with a difficult cleaning task, for example removing bird faeces from solar panels. With the strong bird population in the trees surrounding the proposed sites and others perching on the panels this could be a significant issue for cleaning solar panels in the Country Park. It would be difficult to ensure compliance with a contractual condition that would require regular inspection and supervision.
3. Farming and the protected landscape
In the third paragraph of your article, you say that “much of the Country Park is used for farming”. This implies that in those parts of the Nature Reserve where farming does take place biodiversity conservation is secondary. We believe that this sends the wrong message, and is contrary to the Council’s management plan for the area. Farming is carried on there in a manner wholly consistent with the overall purpose of the Nature Reserve.
You state that none of the protected sites comprise protected land. But you fail to mention that they fall within a statutorily protected Local Nature Reserve, within SSSI Impact Risk Zones and an area of Outstanding Natural Beauty. National planning policy affords AONBs the highest status of protection in relation to conserving and enhancing landscape and scenic beauty. These designations imply a considerable degree of environmental protection. The High Weald Coast, of which the Country Park is a substantial part, is in the East Sussex Landscape Assessment characterised as assessed a largely unspoilt and tranquil landscape with few intrusive features. This characterisation and assessment of the landscape beauty are independent and objective, not a matter of perception as you suggested. You also ignore the fact that the solar panels will have to be surrounded by security fencing to ensure public safety and potential damage by intruders, and there will be associated cabling and transformers.
In conclusion, the purpose of management of the Country Park is to conserve and enhance biodiversity, and that farming methods may be used is integral to promoting its biodiversity. The Country Park is not designated ‘Hastings Country Park Nature Reserve’ for nothing, and nature has to come first.