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BRIEFING PAPER

Number 07434, 16 December 2015

Solar Farms: Funding, planning and impacts

By Madeline Burke

Inside: 1. Overview of solar farms in

the UK 2. European Union renewables

target 3. Planning 4. Financial support 5. Solar farms and agriculture 6. Environmental impact

Number 07434, 16 December 2015 2

Contents Summary 3

1. Overview of solar farms in the UK 5 1.1 How do solar farms work? 6

What is a solar farm? 6 1.2 UK trends 6

Chart showing renewable energy fuel use in 2014 7

2. European Union renewables target 8 2.1 UK shortfall in meeting the renewables target 8 2.2 Reactions to potentially missing the renewables target 10

3. Planning 11 3.1 National planning policy for solar farms 11 3.2 Planning on agricultural land 14 3.3 Local planning policy for solar farms 14 3.4 Building solar farms on brownfield land 15 3.5 Decommissioning solar farms 16 3.6 News and reactions to planning policy for solar farms 17

4. Financial support 19 4.1 Changes to the renewables obligation 19 4.2 Feed-in tariffs 20 4.3 Review on pre-accreditation of feed-in tariffs 21 4.4 Review on feed-in tariffs consultation 23 4.5 Contracts for difference 24 4.6 Reactions to the proposals 26 4.7 Impact on jobs 28 4.8 Interaction with other policies 29

5. Solar farms and agriculture 31 5.1 CAP subsidies restructure for solar farms 32 5.2 Practical Impacts 34 5.3 Reactions to limited CAP claims for solar farms 34

6. Environmental impact 36 6.1 Wildlife impacts 37

Contributing Authors: Elena Ares (renewable energy), Emma Downing (agriculture) and Louise Smith (planning), Science and Environment Section

Cover page image copyright: CRI-1564 by UK Parliament/Mark Crick image. Licensed under CC BY 2.0 / image cropped.

3 Solar Farms

Summary This Commons Library Briefing paper sets out recent policy updates and issues related to funding, the planning process and agricultural issues for solar farm developments. The majority of Government policies relating to solar farms are devolved. Following a large number of recent and proposed changes to polices which apply to England, England is the main focus of this paper, unless stated otherwise. Members are welcome to contact the library for information about policy in all the devolved administrations. The National Assembly for Wales Research Service has produced a paper which sets out the position in Wales.

Solar farms are arrays of solar photovoltaic (PV) panels to generate electricity at a large scale, which usually feed into the national grid. They are a renewable source of energy, range in size from 1 acre to 100 acres and are normally situated in rural areas. There are 426 solar farms currently up and running in the UK in addition to 70 that are currently being built and 123 that have been proposed.

The UK is required to meet an EU renewable energy target of sourcing 15% of its energy from renewables by 2020. One way of reaching this target would be to use electricity generated from solar farms, including solar PV. However in November 2015 there was some uncertainty raised surrounding the ability of the UK to meet this target, following a leaked letter from Government and referred to in an evidence session with the Secretary of State at the Energy and Climate Change Select Committee.

The Government has increasingly reduced the financial support and subsidy for solar farms. It has removed pre-accreditation from Feed-in Tariffs (FITs) from 1 October 2015 meaning that developers will no longer be guaranteed a price for the electricity they generate from a project before it is built. The Government is currently consulting on significantly reducing support available for stand-alone projects through feed-in tariffs. The main reason the consultation gives for reviewing FITs is overspend against the Levy Control Framework (LCF).

The UK Government has also removed subsidy support through the Renewables Obligation (RO) for solar farms larger than 5MW (megawatts). It is currently consulting on the early closure of the RO to new solar PV projects of 5MW and below on 1 April 2016. Contracts for Difference (CfDs) replaced the Renewable Obligation (RO) scheme for solar developments above 5MW from the start of April 2015 and has a planned transition under Energy Market Reform. The UK Government has also limited the Common Agricultural Policy (CAP) funding to solar farms on agricultural land to bring down spending and to reduce energy bills for consumers, as well as freeing up agricultural land for farming.

The proposals for changes to funding for solar energy, have been meet with great concern by the renewable energy sector. The solar PV sector would suffer the most severe cuts under the proposed changes. Many solar energy providers are of the view that with the right support the sector could become subsidy free by 2020, but that the proposed cuts could make this unachievable.

In England, planning for solar farms is the responsibility of local planning authorities. The planning regime in England includes safeguards aimed to ensure that developments, including solar farms, are properly sited and individuals and communities are protected against any unacceptable impacts. This means that issues such as visual amenity and other environmental impacts are an important consideration within the planning process.

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Some specific issues applying to solar farms are set out at the end of the briefing paper, including impact on the environment and wildlife and the overall impact of solar farms on emissions.

5 Solar Farms

1. Overview of solar farms in the UK

Solar farms (sometimes known as solar parks or solar fields) are the large-scale application of solar photovoltaic (PV) panels to generate green electricity at a large scale, usually to feed into the grid. They can cover anything between 1 acre and 100 acres, and are usually developed in rural areas. They are differentiated from most building-mounted and other decentralised solar power applications because they supply power at the utility level, rather than to a local user or users. In the UK solar farms are ground mounted on either agricultural or brownfield land.1

The solar power source uses photovoltaic technology that converts light directly to electricity. However, this differs from, and should not be confused with concentrated solar power (CSP), the other large-scale solar generation technology, which uses heat to drive a variety of conventional generator systems. Both approaches have their own advantages and disadvantages, but for a variety of reasons, including CSP’s need for high insulation and the low insulation of the UK, photovoltaic technology has seen much wider use in the field. At present there are no CSP stations in the UK.2

The UK needs renewable electricity, including solar power, to meet its 15% renewable energy target by 2020, part of the EU’s renewable energy target.3 Growth in renewables also creates investment and local green jobs, whilst reducing the reliance on overseas fossil fuel imports.

The Government has increasingly reduced the support for solar farms. They have removed subsidy support through the renewables obligation for solar farms larger than 5MW (megawatts)4 and have significantly reduced the support available for sub-5MW stand-alone projects through feed-in tariffs. 5 They have also closed the Common Agricultural Policy (CAP) funding to solar farms on agricultural land.

Solar farms are currently eligible for financial incentives under the Feed-in Tariff (FITs) scheme, the Renewables Obligation (RO) scheme (both below 5MW) and the Contracts for Difference (CfDs) for solar farms above 5MW. However The Department of Energy and Climate Change (DECC) is consulting on plans that would see subsidies for some small solar farms (below 5MW) close by 2016.6

1 Solar Trade Association, Explainer: Solar Farms, accessed 3 November 2015 2 Gov.uk, Carbon Trust, Small-scale Concentrated Solar Power A review of current

activity and potential to accelerate deployment, March 2013 3 DECC, UK Renewable Energy Roadmap, July 2011 4 DEFRA press release, Subsidies for solar farms to be cut to help safeguard farmland,

19 October 2014 5 Ofgem.gov, Feed-in Tariff Payment Rate Table for Photovoltaic Eligible Installations

for FIT (1 April 2015 – 30 September 2015), 30 April 2015 6 DECC, Changes to financial support for solar PV, 22 July 2015

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1.1 How do solar farms work?

Box 1: How is energy generated using solar PV

Electricity from the sun’s energy is generated by converting solar radiation directly into electricity using photovoltaic (PV) panels. A Parliamentary Office of Science and Technology (POST) note on Solar Photovoltaics, (2012), describes the different types of solar power.7 Solar Photovoltaics (PV) is a technology for conversion of solar energy to electricity via the use of semiconducting materials. The photovoltaic effect is an electrochemical process that takes place when solar light comes into contact with a semiconductor; this results in atoms being ionised and generating direct current electricity. PV systems have no moving parts and consist of a panel that made up of solar cells, a ground or roof-mounting frame and electric cables, and an inverter to convert Direct Current (DC) electricity to Alternating Current (AC) that can be used on-site or exported to the electricity grid. In bigger projects, PV systems can include isolator switches to protect the system, trackers (moving frameworks for PV panels) that can track the sun as it moves in the sky, and metering equipment. PV systems can be standalone, installed on rooftops, or integrated into buildings. PV panels are used at a range of scales – from small scale systems such as street signs, through to large scale solar farms covering many acres and generating electricity for hundreds of homes. Solar PV is used to generate electricity both “on-grid”, where it is connected to national electricity infrastructure and “off-grid” (such as in oil rigs and lighthouses). On-grid PV is more expensive than both conventional generation and some forms of low carbon generation such as wind. Governments worldwide have therefore introduced schemes to support PV and to foster domestic solar industries.

What is a solar farm? A solar farm is an installation of multiple solar panels, generally on small towers covering an area of ground. Unlike the solar panels on roofs, these panels can be placed away from shade and moved so they are at the optimum angle to harvest solar rays throughout the day and throughout the seasons.

If a solar farm system is producing more power than is being consumed, the surplus is fed into the mains power grid. Electricity is not generally stored in batteries, as this is not currently cost effective, so it is sold back to the grid or electricity company to be used by other consumers. When the solar cells are not producing power, for example at night, power is supplied by the mains power grid as usual. Generally businesses and consumers use the power during the day and householders use the power during the evening and night.

1.2 UK trends According to industry body Renewable Energy UK, as of November 2015, there were 426 solar farms currently up and running in the UK in addition to 70 that are currently being built and 123 that have been proposed. Renewable UK’s website has an interactive map which shows where the solar farms are in the UK.8

7 POST note, Solar Photovoltaics, 25 January 2012 8 Renewables Energy UK, Interactive Map of Renewable and Alternative Energy

Projects in the UK, Accessed on 25 November 2015

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Solar photovoltaic generation more than doubled in 2014 to 4.1 TWh due to an increase in capacity, particularly from the Renewable Obligation scheme. Installed capacity was 5.4 GW in 2014, up from 2.9 GW in 2013, an increase of 89 per cent. 9

The solar resource of the UK is limited by its distance from the equator. While the sunniest parts of the UK receive much less solar radiation than the sunniest parts of Europe, the UK's insolation in the south is comparable with that of central European countries.10

The chart below shows that the largest contribution to renewables and waste energy in input terms (around 72 per cent in the UK) is from bioenergy (excluding non-biodegradable wastes), with wind generation and hydro electricity production contributing the majority of the remainder. Just 3.8 per cent of renewable energy comes from renewable sources other than biomass, wind and hydro. These include solar, heat pumps, and deep geothermal.11 Based on the average annual consumption of a household, for every 5MW installed, a solar farm will power approximately 1,500 homes for a year. Approximately 25 acres of land is required for every 5 megawatts (MW) of installation.

Chart showing renewable energy fuel use in 2014

9 DECC, National Statistics, Renewable sources of energy: Chapter 6, Digest of United

Kingdom Energy Statistics (DUKES), July 30th 2015 10 IEA International Energy Agency, Snapshot of Global PV Markets, 2014 11 DECC, National Statistics, Renewable sources of energy: Chapter 6, Digest of United

Kingdom Energy Statistics (DUKES), 30 July 2015

London receives 0.11 kilowatts of sunshine per square metre (kW/m2) on average, compared with 0.19kW/m2 for Athens, which is nearer the equator, and 0.24kW/m2 for Cairo, which is nearer still. On average the UK receives 0.11 kW, equivalent to 3.42 GJ a year, of solar radiation per square metre.

Number 07434, 16 December 2015 8

2. European Union renewables target

The Renewables Directive, 2009/28/EC, is a European Union directive which mandates levels of renewable energy use within the European Union. The directive was published on 23 April 2009 and amends and repeals the Directive 2001/77/EC on Electricity Production from Renewable Energy Sources. The 2009 Directive requires that 20 percent of the energy consumed within the European Union is renewable.12 As part of this target the UK has been asked to procure 15% of its energy consumption from renewable sources in 2020.

Progress has been made against this 15% target. Using the methodology set out in the Directive, provisional calculations show that 7.0 per cent of energy consumption in 2014 came from renewable sources; this is up from 5.6 per cent in 2013.13 However the 2015 EU report on progress towards the 2020 renewable energy goals stated that The UK, France and Netherlands were set to miss the 20 per cent target and should review their policies to get back on track.14

2.1 UK shortfall in meeting the renewables target

On 9th November 2015 the Ecologist magazine published a leaked letter from the Secretary of State for the Department of Energy and Climate Change (DECC), Amber Rudd, to Cabinet colleagues. The letter sets out what the UK has left to achieve:

"Beyond a flat rate of renewables for each member state, the effort share for meeting the EU-wide 20% target was based on GDP. As a result of this, and the fact that the UK started from a very low base of renewables deployment, our target requires amongst the most significant annual growth in renewables deployment (16% average annual growth from 2011 to 2020) of any member state."15

The letter stated that the UK is on track to miss its legally binding obligation to achieve strict EU targets on renewable energy by an estimated 50TWh (terawatt hours), or 3.5% of its 15% obligation. Although the letter states “Publically we are clear that the UK continues to make progress to meet the target."16

This is different to the public position of DECC and the Secretary of State (SoS). On the 22 June 2015 the Secretary of State made a

12 EUROPA, EU law and regulations, Document 32009L0028, Directive 2009/28/EC, 23

April 2009 13 DECC, National Statistics, Renewable sources of energy: Chapter 6, Digest of United

Kingdom Energy Statistics (DUKES), 30 July 2015 14 European Commission, Renewable energy progress report, 15 The Ecologist, Leaked letter: Rudd admits 25% green energy undershoot, misled

Parliament, 9 November 2015 16 The Ecologist, Leaked letter: Rudd admits 25% green energy undershoot, misled

Parliament, 9 November 2015

9 Solar Farms

statement to parliament where she stated that 30% of the UK’s electricity will come from renewable sources by 2020:

"The renewable electricity programme aims to deliver at least 30% of the UK's electricity demand from renewables by 2020. We are on course to achieve this objective. Renewables already make up almost 20% of our electricity generation and there is a strong pipeline to deliver the rest."17

On 10 November 2015, the Energy and Climate Change select committee took evidence from the Secretary of State and asked whether Parliament had been misled:

We have looked at the leaked material and your previous statements to the House, and our assessment is that whether or not it was your intention to mislead there has indeed been some misleading use of language and confusion where you talk on different occasions about renewable energy targets and renewable electricity targets.18

The chair asked for clarification of the figures that have been quoted in the press:

The figure of 30% that I am quoted as referring to in the House of Commons is what we expect to have from electricity by 2020, which is a great result. We are now at 20% and we expect to reach 30%. It is something that the UK can be very proud of.

I am concerned about the work that is being done on transport and on heat to make the additional targets. That is why I have been writing to other Ministers in other departments, particularly in transport, to urge them to work across Government to make sure that we do make these targets.

We have made our interim target—in fact, we have just exceeded it—but it is going to be challenging to make the rest of the target. I remain committed to making good progress towards that target and it is because I am so committed to that that I am encouraging other Secretaries of State to take action. This is, after all, a cross-Government target; it is not just for my Department. I am going to be working with Transport and internally I am going to be putting together policies on heat to try to address the shortfall that we currently have in order to achieve that 2020 target.

The SoS gave evidence to the committee stating that the shortfall in meeting the renewable energy targets should be filled by renewable heat, and by more biofuels in petrol and diesel. When questioned regarding reversal of the cuts to renewable electricity from solar and onshore wind she stated:

“I think it would be a mistake to abandon heat and transport, they need to make their contribution on the renewable targets."

17 Oral statement to Parliament, Statement on ending subsidies for onshore wind, 22

June 2015 18 Energy and Climate Change Select Committee, Oral evidence: DECC Annual Report

and Accounts 2014-15, HC 544, 10 November 2015

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2.2 Reactions to potentially missing the renewables target

Reactions to the leaked letter written by the Secretary of State were negative. Greenpeace Head of Energy, Daisy Sands commented that the Governemnt was:

“wilfully hiding this from public scrutiny. The government is planning on cutting support for the solar and wind subsidies in the name of affordability. But perversely, we see that the government believes investing in renewable energy projects involving buying power from abroad is more desirable than supporting home grown renewable energy industries.

Even more worryingly, it seems the government is seeking to haggle with the EU to revise down our legal commitments. This policy makes no environmental or economic sense as the UK is losing jobs and affordable clean, renewable energy sources."19

Green MEP Molly Scott Cato told the Guardian that Amber Rudd had

“serious questions to answer about why she has reported something to parliament which appears inconsistent with what she has been telling other ministers.”20

19 Solar Power Portal, DECC silent over claims Rudd misled parliament, 10 November

2015 20 The Guardian, Energy minister expects UK to miss renewables target, leaked letter

shows, 9 November 2015

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3. Planning In England solar farms go through a rigorous planning procedure before they are approved. This takes into account the suitability of the specific site, any potential impact on the area and relevant renewable energy targets.

Planning for solar farms is the responsibility of local planning authorities. The planning regime in England includes safeguards aimed to ensure that developments, including solar farms, are properly sited and individuals and communities are protected against any unacceptable impacts. This means that issues such as visual amenity and other environmental impacts are an important consideration within the planning process.

Planning policy for solar farms is contained in a number of documents, principally the Government’s National Planning Policy Framework21, the National Policy Statement for Renewable Energy Infrastructure22 and online Planning practice guidance for renewable and low carbon energy. 23 These documents detail the particular factors a local planning authority will need to consider in relation to proposals for large scale ground-mounted solar photovoltaic farms.

The Building Research Establishment (BRE) has some useful planning guides on their website library: Large Scale Solar which is aimed at developers.24

3.1 National planning policy for solar farms

In March 2012 the Government published the National Planning Policy Framework (NPPF) which is a material consideration for local planning authorities (LPAs) considering planning applications. The NPPF directs that when determining planning applications for renewable energy development, LPAs should:

• not require applicants for energy development to demonstrate the overall need for renewable or low carbon energy and also recognise that even small-scale projects provide a valuable contribution to cutting greenhouse gas emissions; and

• approve the application if its impacts are (or can be made) acceptable. Once suitable areas for renewable and low carbon energy have been identified in plans, local planning authorities should also expect subsequent applications for commercial scale projects outside these areas to

21 DCLG, (2012) National Planning Policy Framework. 22 DECC, (2011) National Policy Statement for Renewable Energy Infrastructure. 23 Planning practice guidance for renewable and low carbon energy. 24 BRE, Our Library, Large Scale Solar, Planning Guidance for the development of large-

scale ground mounted solar PV systems (free), 2013

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demonstrate that the proposed location meets the criteria used in identifying suitable areas.25

The NPPF makes clear that renewable energy development is not normally considered appropriate development for green belt land:

91. When located in the Green Belt, elements of many renewable energy projects will comprise inappropriate development. In such cases developers will need to demonstrate very special circumstances if projects are to proceed. Such very special circumstances may include the wider environmental benefits associated with increased production of energy from renewable sources.26

The NPPF also encourages LPAs to develop a strategy to promote renewable energy developments and identify suitable sites for them:

97. To help increase the use and supply of renewable and low carbon energy, local planning authorities should recognise the responsibility on all communities to contribute to energy generation from renewable or low carbon sources. They should:

• have a positive strategy to promote energy from renewable and low carbon sources;

• design their policies to maximise renewable and low carbon energy development while ensuring that adverse impacts are addressed satisfactorily, including cumulative landscape and visual impacts;

• consider identifying suitable areas for renewable and low carbon energy sources, and supporting infrastructure, where this would help secure the development of such sources;

• support community-led initiatives for renewable and low carbon energy, including developments outside such areas being taken forward through neighbourhood planning; and

• identify opportunities where development can draw its energy supply from decentralised, renewable or low carbon energy supply systems and for co-locating potential heat customers and suppliers.27

The Government has published online Planning Practice Guidance to accompany the NPPF, which should also be taken into account when planning decisions are made. 28 This guidance includes particular provisions local authorities should consider in relation to large-scale ground mounted solar photovoltaic farms. 29 One of the aims of the guidance is to make clear that the need for renewable energy does not automatically override the need for planners to properly scrutinise the effects of renewables deployment. It directs planners to ensure that the

25 Department for Communities and Local Government, National Planning Policy

Framework, 27 March 2012 26 Department for Communities and Local Government, National Planning Policy

Framework, 27 March 2012 27 Department for Communities and Local Government, National Planning Policy

Framework, 27 March 2012 28 Planning Portal Gov, Planning Practice Guidance, Renewable and low carbon energy,

6 March 2014 29 Planning Portal Gov, Planning Practice Guidance, What are the particular planning

considerations that relate to large scale ground-mounted solar photovoltaic Farms?, 27 March 2015

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impacts of proposed renewable energy deployments are acceptable, including impact on visual amenity and effects on cultural and heritage landscapes:

What are the particular planning considerations that relate to large scale ground-mounted solar photovoltaic Farms?

The deployment of large-scale solar farms can have a negative impact on the rural environment, particularly in undulating landscapes. However, the visual impact of a well-planned and well-screened solar farm can be properly addressed within the landscape if planned sensitively.

Particular factors a local planning authority will need to consider include:

• encouraging the effective use of land by focussing large scale solar farms on previously developed and non-agricultural land, provided that it is not of high environmental value;

• where a proposal involves greenfield land, whether (i) the proposed use of any agricultural land has been shown to be necessary and poorer quality land has been used in preference to higher quality land; and (ii) the proposal allows for continued agricultural use where applicable and/or encourages biodiversity improvements around arrays. See also a speech by the Minister for Energy and Climate Change, the Rt Hon Gregory Barker MP, to the solar PV industry on 25 April 201330 and Written Ministerial Statement – Solar energy: protecting the local and global environment – made on 25 March 2015. 31

• that solar farms are normally temporary structures and planning conditions can be used to ensure that the installations are removed when no longer in use and the land is restored to its previous use;

• the proposal’s visual impact, the effect on landscape of glint and glare (see guidance on landscape assessment) and on neighbouring uses and aircraft safety;

• the extent to which there may be additional impacts if solar arrays follow the daily movement of the sun;

• the need for, and impact of, security measures such as lights and fencing;

• great care should be taken to ensure heritage assets are conserved in a manner appropriate to their significance, including the impact of proposals on views important to their setting. As the significance of a heritage asset derives not only from its physical presence, but also from its setting, careful consideration should be given to the impact of large scale solar farms on such assets. Depending on their scale, design and prominence, a large scale solar farm within the setting of a heritage asset may cause substantial harm to the significance of the asset;

30 DECC, Gregory Barker speech to the Large Scale Solar Conference, 25 April 2013 31 Parliamentary Business, Publications and Records, Planning Update: Written

statement - HCWS488, Solar energy: protecting the local and global environment, 25 March 2015

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• the potential to mitigate landscape and visual impacts through, for example, screening with native hedges;

• the energy generating potential, which can vary for a number of reasons including, latitude and aspect.

The approach to assessing cumulative landscape and visual impact of large scale solar farms is likely to be the same as assessing the impact of wind turbines. However, in the case of ground-mounted solar panels it should be noted that with effective screening and appropriate land topography the area of a zone of visual influence could be zero.32

3.2 Planning on agricultural land The NPPF also makes clear that local planning authorities should take into account the quality of agricultural land when taking decisions about any development (not just renewable energy projects):

111. Planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land), provided that it is not of high environmental value. Local planning authorities may continue to consider the case for setting a locally appropriate target for the use of brownfield land.

112. Local planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality.33

The Agricultural Land Classification: protecting the best and most versatile agricultural land (TIN049)34 system grades land into five categories according to versiltility and suitability for growing crops. The top three grades, grades 1, 2 and 3a are referred to as “the best and most versatile agricultural land”.

3.3 Local planning policy for solar farms When taking a decision on a planning application local planning authorities (LPAs) are entitled to take into account all “material considerations” when deciding a planning application. The courts have held that “in principle...any consideration which relates to the use and development of land is capable of being a planning consideration (Stringer v MHLG [1971] 1 All ER 65).

The Government’s Planning Portal website makes clear, however, that “issues such as loss of view, or negative effect on the value of properties are not material considerations.” Representations for and against a planning application, at any stage, may be particularly

32 Planning Portal Gov, Planning Practice Guidance, What are the particular planning

considerations that relate to large scale ground-mounted solar photovoltaic Farms?, 27 March 2015

33 Department for Communities and Local Government, National Planning Policy Framework, 27 March 2012

34 Natural England, Agricultural Land Classification: protecting the best and most versatile agricultural land (TIN049), 13 January 2009

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persuasive if they relate to policies set out in any Local Plan that the area might have and any relevant Government guidance.

Local councils may have their own planning guidance regarding renewable energy and solar farms on their websites. Cornwall, which receives some of the highest levels of solar insulation in the UK, has a Cornwall Renewable Energy Supplementary Planning Document available on the council’s website and contains guidance on planning for solar PV. This planning guidance is currently under consultation. The document highlights issues such as views and screening, layout and scale and land management.35

3.4 Building solar farms on brownfield land

“Brownfield” land is now known in planning terms as “previously developed land”. Previously developed land is defined in the Government’s National Planning Policy Framework as follows:

Previously developed land: Land which is or was occupied by a permanent structure, including the curtilage of the developed land (although it should not be assumed that the whole of the curtilage should be developed) and any associated fixed surface infrastructure. This excludes: land that is or has been occupied by agricultural or forestry buildings; land that has been developed for minerals extraction or waste disposal by landfill purposes where provision for restoration has been made through development control procedures; land in built-up areas such as private residential gardens, parks, recreation grounds and allotments; and land that was previously-developed but where the remains of the permanent structure or fixed surface structure have blended into the landscape in the process of time.36

The definition includes a number of exceptions as to when land will be classed a “previously developed”.

There are several examples of solar farm developments on brownfield land. These include:

• Wheal Jane site in Cornwall, a 1.42MW (megawatt) solar farm on a brownfield area of the site using 5,680 solar panels built on the site of a former tin mine.

• Near Lymington in Hampshire, a 2.4MW solar project on the site of a 12.6 acre field, recently restored after a decade of gravel extraction.

• 5MW solar farm at Tavells Farm in Hampshire on the site of a former quarry/ landfill site.

An article from the specialist publication, Planning, quoted research from a solar farm developer which had found many brownfield sites in the UK would be unsuitable for a solar farm either because of their size,

35 Cornwall Council, Cornwall Renewable Energy Supplementary Planning Document,

2015 36 Department for Communities and Local Government, National Planning Policy

Framework, 27 March 2012

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their liability to flooding or that they had already been designated for other uses, such as housing.37

3.5 Decommissioning solar farms What will happen to the land after a solar farm is closed will depend on the facts of each specific case, such as what status the land had before the erection of the solar farm, whether the solar farm is intended to be a permanent structure and whether any other activities take place on the land. However, decommissioning bonds can be put in place by the developer and the landowner to make sure that there is enough money at the end of the project to allow the land to be restored appropriately.

Decommissioning bonds are also sometimes called reinstatement bonds. There are two main ways that they operate. The first is where money is put aside into an account at the beginning of the development, to cover the costs of removing the equipment and restoring the land to its original condition at the end of the project. The money stays in the account throughout the lifetime of the project and is only accessed at the end when it is needed. Alternatively it can be where income throughout the life of the project is put aside to cover the decommissioning costs. Because decommissioning costs are often expensive, both ways aim to provide greater certainty that the decommissioning will happen properly and will be funded at the end of the project.

A 2014 article on LexisNexis news, titled “Harvesting the sun—closing down a solar farm” explains the legal considerations when decommissioning a solar farm site. This includes consideration of issues such as who own the equipment, who will arrange for the resoration of the land etc.38

The local authority would not always be involved with setting these bonds up – they would often be agreed between the developer and the land owner. Suncredit, an international solar PV development group of companies, has an FAQ on their website which details when the tenant (the developer) will supply a reinstatement bond and what the bond guarantees:

13. What happens if the owner goes bankrupt and what would happen to the equipment is on site?

50% of the income is guaranteed by the Government for up to 20 years and the other 50% is sold on the energy market. With energy prices increasing every year, therefore, the chance of it going bankrupt is extremely low. Added to this the value of the equipment installed is worth circa £150,000 per acre and lasts for up to 25 years, so in the unlikely event that the company goes bankrupt the equipment would revert to the land owner who could either continue to receive the income or sell the equipment to cover the cost of reinstatement and any other losses. In the later years the tenant will supply a reinstatement bond to cover the cost of the removal of the equipment.

37 “Not enough brownfield land for solar farms, developer claims” Planning, 19

August 2013 38 LexisNexis News, Harvesting the sun—closing down a solar farm, 3 October 2014

17 Solar Farms

16. At lease end what happens?

This lease is normally fixed for a period of 25 to 30 years with an option to extend if this is agreeable with the land owner. Once the lease ends the tenant is required to remove all the equipment and reinstate the land back to its original condition which is guaranteed by a bond which the tenant enters into in the 15th year of the lease.

The local authority may want to make it planning condition that such a bond exists, in order to give certainty that the decommissioning will be funded, but the bond/fund itself may well be a private contractual agreement between developer and land owner. Therefore it is difficult to say whether there is a trend or not for use of these across the country as the details of these agreements won’t be published. It is not always possible to track the extent of the use of private legal agreements.39

Cornwall Council, in planning policy documents, sets out that solar farms will need to be decommissioned after their lifetime and may need a decommissioning bond, however it is not a requirement:

5.14 Site restoration/duration of planning permission

• The planning application should clearly set out the length of time that the development will be in place. All ground mounted solar PV permissions will have a condition imposing a time limit and require restoration of the site. In addition, a restoration or performance bond may be required to ensure that site is appropriately restored post decommissioning.

• Restoration means that all development, including ancillary infrastructure, footings and access tracks should be removed from the site and any soils and vegetation restored to ensure the land is returned to its original pre-development condition.40

3.6 News and reactions to planning policy for solar farms

Some recent news stories have highlighted some of the reasons given for refusal of solar farm applications, including harming the visual amenity of the area and the impact on the landscape. Some examples are included below: • In Charlbury (Oxfordshire) a proposed 5MW solar farm in an Area

of Outstanding Natural Beauty (AONB) was refused because of “harm to the visual amenity of the area”. Other objections included loss of wildlife and that it would “urbanise the landscape”.41

• In Horsham and South Downs three solar farm applications were refused by the committee “under the same reasons, including the

39 Suncredit, FAQs, accessed 24 November 2015 40 Cornwall Council, Cornwall renewable energy supplementary planning document,

2015 41 BBC News, “Charlbury solar farm plans refused by Oxfordshire council”, 7 May

2014

Number 07434, 16 December 2015 18

scale of each development, the impact on the landscape, and the issues outweighing the benefits.”42

• In Eastbourne proposals for a 69 acre solar farm were rejected because there was a need to “avoid using the best agricultural land for large-scale solar farms” and because the development would have had “a slight adverse impact on the ‘special landscape’ of the site and would harm the visual amenity of the area”.43

• In East Sussex a solar farm was refused because “the proposal with associated access, structures, fencing and CCTV cameras, would represent a significant intrusion into the countryside”.44

There are other examples of solar farms being granted planning permission, including a news story on how a solar farm overcame landscape objections and agricultural land objections to be given planning permission.45 In Somerset a solar farm was granted permission on the basis of the benefits renewable energy development, the absence of significant harm to the landscape character or appearance and lack of impact on best and most versatile agricultural land.46

There have been some negative reactions to how the Planning Practice Guidance require local planning authorities (LPAs) to consider the ype of land that a solar farm application is located on. For example, an article on the website Solar Power Portal, titled “Will common sense prevail for solar planning in 2015?” states:

Requiring solar farm developers to discount alternative sites not only shifts the burden of proof and has no support in law, but also puts solar farms on an unequal footing with land uses that take more land out of agricultural production, and for longer time periods. Golf courses are the obvious culprits, because of their large land take, but it remains that developers of ground-mounted solar farms have been singled out in needing to justify their selected site against other, unknown sites. This is despite solar farms being temporary uses of 25-30 years.

Further, it is a test not required of other energy plants, the location of which are similarly driven by supply side economics, such as shale gas drilling rigs and using farmland to grow biofuel crops. The latter may not require planning permission, but biofuel power plants do and the government has previously given generous subsidies to enable the construction of advanced biofuel plants in the UK. The fuel for those plants is grown each year on thousands of acres of prime British farmland.47

42 West Sussex County Times, “Council refuse three solar farm plans in Horsham and

South Downs”, 17 April 2014 43 Eastbourne Herald, “Inspector upholds solar farm refusal”, 26 March 2015 44 Rye and Battle Observer, “Planners say no to Catsfield solar farm”, 16 April 2015 45 Planning Resource, “Solar farm overcomes landscape and agricultural land impact

objections”, 1 September 2015 46 Planning Resource, “Solar farm overcomes landscape and agricultural land impact

objections”, 1 September 2015 47 Solar Planning Portal, Will common sense prevail for solar planning in 2015?, 13

January 2015

19 Solar Farms

4. Financial support The Government has increasingly reduced the support for solar farms, where solar arrays are ground mounted on either agricultural or brownfield land. They have removed subsidy support through the renewables obligation (RO) for solar farms larger than 5MW and have significantly reduced the support available for stand-alone projects through the removal of feed-in tariffs (FITs) pre-accreditation. They have also limited the Common Agricultural Policy (CAP) funding to solar farms on agricultural land.

The Government is currently consulting on plans to close the renewables obligation for solar farms at or below 5MW and reducing the range of FIT financial support available for stand-along projects.

4.1 Changes to the renewables obligation

The Renewables Obligation (RO) was introduced in 2002 to provide incentives for the deployment of large-scale renewable electricity in the UK. The RO requires licensed UK electricity suppliers to source a specified proportion of the electricity they provide to customers from eligible renewable sources. This proportion (known as the ‘obligation’) is set each year and has increased annually.

On 13 May 2014, DECC published a consultation paper setting out measures to control spending on new solar PV capacity above 5MW within the RO, and to promote the deployment of mid–scale building-mounted solar PV in the small–scale FIT scheme. This was specifically aimed at reducing support for solar farms. On 2 October 2014, DECC published a response to that consultation, confirming the decision to close the RO to new solar PV generating stations above 5MW in scale from 1 April 2015, and to additional capacity added to existing accredited stations from that date, where the station is, or would become, above 5MW.

The Government response also confirmed the decision to keep the RO open to new solar PV projects at or below 5MW. However, DECC stated that:

Consistent with our responsibility for managing RO expenditure under the LCF and mindful of how quickly the solar sector has adapted to past policy changes we will continue to monitor the deployment pipeline. As indicated in our consultation document, if this monitoring indicates deployment is growing more rapidly than can be afforded we will consider taking measures to protect the LCF.48

On 22 July 2015, the now Conservative Government published a further consultation paper on changes to financial support for solar PV including proposals to bring forward the closure of the Renewables Obligation to new solar PV projects of 5MW and below to 1 April 2016. The consultation also proposed the removal of the guaranteed level of 48 DECC, Consultation on changes to financial support for solar PV, 13 May 2014

Number 07434, 16 December 2015 20

subsidy for the duration of solar PV projects – known as grandfathering - of 5MW and below and a banding review for these solar PV projects. This was to test whether the costs to developers associated with the deployment of solar PV had fallen further and faster than previously anticipated. This also applies to Wales. Specifically on grandfathering:

• Removing grandfathering for new solar PV projects on 5MW and below, and additional capacity up to a total of 5MW total installed capacity, that are not accredited under the RO as of 22 July 2015. We also propose an exception to the removal of grandfathering for projects that satisfy the criteria for the significant financial commitment grace period.49

The Scottish Government has announced it will retain a grandfathering guarantee for key policies supporting investment in solar farms. Scottish Energy Minister Fergus Ewing expressed disappointment the Scottish Government was not consulted on the decision by the UK Government, despite it applying to Scotland.50

DECC stated it will publish a decision as soon as possible following the closure of the consultation on the Renewables Obligation on 2 September 2015 and:

• Subject to Parliamentary approval, intends to implement any decision to close the Renewables Obligation early to solar PV projects of 5MW and below through legislation to come into force before 1 April 2016.

• Subject to this consultation intends that the effective date for the removal of grandfathering will be 22 July 2015.

• Subject to this consultation, will publish proposed bandings for new solar PV projects of 5MW and below for further consultation.51

4.2 Feed-in tariffs The FITs scheme was introduced in 2010, with a comprehensive review of the scheme in 2011-12 introducing several changes. Alongside the Renewables Obligation and the Contract for Difference (CfD) regime, FITs is part of a set of initiatives to encourage the deployment of renewable energy across the UK.

The aim of FITs is to provide a simple system to incentivise small domestic and business renewables (up to 5MWs for solar PV). The scheme was introduced by the previous Labour Government in the Energy Act 2008 and has been running since April 2010. The Scheme pays a tariff, which varies according to the technology and the size of the installation, for every kWh generated. It also pays a smaller additional tariff for each kWh exported into the grid. Generators are paid the tariff for the lifetime of the scheme, which is index linked to the Retail Price Index. 52 Details of Feed in Tariffs are available in Library

49 DECC, Consultation on changes to financial support for solar PV, 22 July 2015 50 BusinessGreen, Scottish Government to keep 'grandfathering' solar guarantee, 23

September 2015 51 DECC, Consultation on changes to financial support for solar PV, 13 May 2014 52 DECC, Consultation on a review of the Feed-in Tariffs scheme, 27 August 2015

21 Solar Farms

Note SN06200. 53 A summary of the changes in Solar Feed in Tariffs since October 2011 are set out in a separate note SN06112. 54

The objectives of the scheme on its introduction were:

• Encourage deployment of small scale (up to and including 5 MW) low-carbon electricity generation;

• Empower people and give them a direct stake in the transition to a low-carbon economy;

• Assist the public take-up of carbon reduction measures;

• Foster behavioural change; and

Help develop local supply chains and drive down energy costs.55

4.3 Review on pre-accreditation of feed-in tariffs

The Secretary of State for Energy and Climate Change, Amber Rudd, set out the Government’s intention to carry out a review of Feed-in Tariffs (FITs) in a Written Statement on 18 June 2015, at the same time it announced the closure of the Renewables Obligation to onshore wind generators a year early in April 2016:

I will also shortly be considering options for continued support for community onshore wind projects through the feed-in tariff (FITs) as part of the review that my Department is conducting this year.56

On 22 July 2015 the Government also announced, in a press release titled “controlling the cost of renewable energy”, 57 a consultation on pre-accreditation of Feed-in Tariffs in July 2015. At the same time it announced changes reducing support for biomass and smaller solar photovoltaic projects through the Renewables Obligation. 58

The Government consulted on removing pre-accreditation because both deployment and spend under the FIT scheme had outstripped expectations. The consultation document explained the Government’s decision to look at the role of pre-accreditation in deployment of renewable energy technology. The overall aim being to reduce costs falling within the LCF:

In the context of current pressure on the LCF we consider there is a strong rationale for taking action in the short term to rebalance the risks between consumers and industry, prior to consulting on a wider review of the scheme.

It is our assessment that developers across all sectors are better placed now than in 2012 to handle the risks inherent in the degression mechanism. Removing pre-accreditation will enable

53 Commons Briefing papers SN06200, Feed-in Tariffs, 9 August 2012 54 Commons Briefing papers SN06112, Feed-in Tariffs: Solar PV Review, 5 April 2012 55 DECC, Consultation on a review of the Feed-in Tariffs scheme, 27 August 2015 56 Written Statements, Energy and climate change, 18 June 2015 57 DECC, Press Release, Controlling the cost of renewable energy, 22 July 2015 58 DECC, Policy Paper, 2010 to 2015 government policy: low carbon technologies

Appendix 5: the Renewables Obligation (RO), 8 May 2015

Number 07434, 16 December 2015 22

deployment under the FIT scheme to continue but with lower risk to consumer bills.59

The Government proposal to remove pre-accreditation and pre-registration, would mean that projects would only receive the tariff available when they submit their accreditation to Ofgem.

This has an impact in two ways. Firstly, as tariffs degress regularly, pre-accreditation allows a scheme to receive a higher rate than it otherwise would have. More importantly to developers, pre-accreditation provides certainty as to what rate of support a project will receive and reduces risk to investors, therefore providing some security for developers.

DECC’s view, expressed in the consultation on pre-accreditation of Feed-in Tariffs, was that was that the proposals would adversely impact deployment levels:

In our assessment of the impact of these measures, the decrease in certainty would therefore be represented by an increase in the rate of return required for a project to go ahead. In turn this is likely to lead to a decrease in deployment levels, as some projects which would have previously gone ahead will now be considered marginal – or not economically viable – at these revised hurdle rates. 60

The majority of respondents to the consultation were opposed to the proposed changes, with a significant number unhappy about the short (4 week) consultation and the lack of any accompanying Impact Assessment. The responses were detailed in the Government response to the consultation on changes to Feed-in Tariff accreditation, and included DECC responses to the criticism:

A significant number of respondents stated that the length of the consultation period (4 weeks) had adversely affected their ability to respond in full to the consultation questions. While we appreciate that the length of this consultation period was a subject of contention amongst stakeholders, we also note that it contained only four questions on an established and well-understood policy. Taking into account the fact that the proposals will need to be implemented urgently in order to protect bill-payers from rising policy costs in a demand-led scheme without effective cost control, we judged that four weeks was adequate for stakeholders to provide a considered response. We consider that the high number of substantive considered responses received shows that sufficient time was provided.61

Following consultation, the Government announced in the response to the consultation that it would remove pre-accreditation from 1 October 2015. However, according to the consultation this could be a temporary measure, which could be reversed depending on the outcome of the Review of Feed-in Tariffs.

However, subject to the outcome of the FIT Review, if generation tariffs for new applicants remain available under the FIT scheme, we will consider reintroducing pre-accreditation either for all groups or on a more limited basis. This is because we consider

59 DECC, Consultation on a review of the Feed-in Tariffs scheme, 27 August 2015 60 DECC, Consultation of pre-accreditation of feed-in tariffs, 21 July 2015 61 DECC, Government response to the consultation on changes to Feed-in Tariff

accreditation, 9 September 2015

23 Solar Farms

that the proposals set out in the FIT Review consultation, in particular the introduction of deployment caps, would enable control of the overall costs of the scheme. In this context, pre-accreditation would be an appropriate means of enabling deployment under an effectively cost-controlled scheme.62

4.4 Review on feed-in tariffs consultation The Consultation on a review of the Feed-in Tariff scheme, published in August 2015 by DECC, includes a raft of proposal to change the FIT’s scheme for solar PV, wind and hydro power.63

The main reason the consultation gives for reviewing FITs is overspend against the overall Levy Control Framework (LCF):

In order to limit the impact on consumer bills, Government set a limit on the annual low-carbon energy subsidy expenditure which could be collected from consumers, known as the LCF. The LCF is designed to control impacts of support for low-carbon generation on consumer bills. There are annual caps but the current final LCF year of 2020/21 sets an expenditure limit of £7.6bn (2011/12 prices). In July 2015, the Office for Budgetary Responsibility (OBR) published new projections of LCF expenditure which revealed forecast expenditure equivalent to £9.1bn (2011/12 prices) in 2020/21 resulting in a forecasted overspend of around 20%.

Greater technological efficiency, higher uptake of schemes, and changes to wholesale prices account for the reasons why we are likely to overspend against the LCF restrictions without taking any action.

In light of these financial pressures, the Government is taking or proposing measures to control renewables subsidy expenditure, such as changes to grandfathering of subsidies for coal plants converted to burn biomass, or a mixture of biomass and coal, early closure of the RO to solar projects of 5MW and below, and a separate consultation on the removal of pre-accreditation from FITs.64

Currently the cost of subsidies for renwable electricity generation are passed on by suppliers to consumer through their electricity bills. This includes FITs and the Renewables Obligation. The LCF is designed to limit the impact on consumer bills.

The consultation states that FITs has largely met, or is likely to meet, its objectives ahead of schedule and the costs of buying and installing renewable energy have fallen for most technologies, particularly for solar PV. The consultation also highlights government concerns about the scheme’s overall value for money and affordability within the context of carbon reduction and the LCF, particularly when compared to other low-carbon schemes.

Included in the proposals is the option of removing the generation tariff completely, if there is a surge of applications before the changes come into force in January 2016, and retaining the export tariff only. If this is

62 DECC, Consultation on a review of the Feed-in Tariffs scheme, 27 August 2015 63 DECC, Consultation on a review of the Feed-in Tariffs scheme, 27 August 2015 64 DECC, Consultation on a review of the Feed-in Tariffs scheme, 27 August 2015

Number 07434, 16 December 2015 24

not implemented the following tariff changes for solar power are proposed.

For Solar PV the range of support available would be reduced from of 4.28 -12.47 p/Kwh to 1.03 to 3.69 p/kWh. Smaller installations of 4kW or less would see the biggest cut, with a reduction of 87%. Standalone installations would receive a cut of 76%, with medium sized and larger fixed installations falling somewhere in between. The 87% cut to solar FITs is one that was widely quoted in the press when the consultation was published.65

The Government also proposed a raft of other measures including:

• Quarterly degression of either 10%, 5% or 0% for all technologies, meaning FIT rates will decrease as technologies get cheaper.

• New installations to be CPI index-linked rather than RPI index-linked

• Scheme not extended to any new technologies

• New expenditure under FITs is limited to an overall budget of £75-100m to 2018/19.

Proposals that may be considered in the future include an obligation for all new FIT generators to inform their Distribution Network Operator (DNO) of their installation and increasing energy efficiency criteria of buildings for new FIT applications to qualify for support.

The consultation also includes a table of proposed default degression quarterly until 2019, together with tables setting out the total generation and number of installations projected to 2108/19 per quarter.

The Government also published an Impact Assessment and a report titled Performance and Impact of the Feed-in Tariff Scheme: Review of Evidence as part of the consultation. The Impact Assessment looked into the impact three different policy options would have, ranging from doing nothing, making some changes, to completely closing down the scheme. 66 DECC commissioned the Performance and Impact of the Feed-in Tariff Scheme: Review of Evidence to assess the success of the FIT in achieving its objectives. It summarises evidence gathered on the performance of the Feed-in Tariff (FIT) scheme over the 5 years of operation. 67 This consultation was closed on 23 October 2015 and the Government response has not yet been published.

4.5 Contracts for difference Contracts for Difference (CfDs) replaces the Renewable Obligation Certificates (ROC) scheme for commercial solar developments above 5MW from the start of April 2016 with the RO set to end entirely in 65 The Guardian, Slashing household solar subsides will kill off industry, government

told, 27 August 2015 66 DECC, Impact Assessment: Periodic Review of FITs 2015, 27 August 2015 67 DECC, Performance and Impact of the Feed-in Tariff Scheme: Review of Evidence,

27 August 2015

25 Solar Farms

2016. There is a planned transition from the Renewables Obligation (RO) Certificate scheme to the Contract for Difference scheme (CfD) under Energy Market Reform. DECC published its proposals in relation to the transition in the document Energy Act: Renewables Obligation Transitional Arrangements. The RO scheme will potentially close to new entrants in 2016 but will run for existing entrants until 2037. In the period between the introduction of CfDs in 2014 and the closure of the RO to new capacity potentially on 1 April 2016, new capacity will be able to choose between support under the RO or under CfD.

The first CfD auction took place in February 2015, with 27 projects receiving more than £315m. Five of these projects were solar projects totalling 72MW. However, two of the projects – Wick Farm Solar Park in Somerset and Royston Solar Farm in Hertfordshire – are not going ahead, with industry experts saying their agreed CfD strike price of £50 per megawatt hour of electricity generated was not commercially feasible:

James Rowe, director of Hadstone Energy, today confirmed that Wyke had been scrapped. "We could never deliver at that price," he told BusinessGreen.

Rowe has previously described the CfD regime as a "policy failure", telling Solar Power Portal that £50/MWh was roughly the same price the company could secure on the open market.

"We got the stick without the carrot, the hook without the bait," he said. "For solar, this CfD round doesn't look much like 'world-leading competitive auction', it looks a lot like policy failure."

Rowe would not comment on why the company submitted such a low bid. However, the fact two companies bid at a price they could not meet will fuel complaints that the auction process is overly complex.70

BusinessGreen reported that solar energy companies were not supporting CfDs:

Solar developers are turning their backs on a new government green energy support scheme as they do not feel it will work for them, according to the results of a new industry survey.

The poll of 29 developers and investors responsible for adding over 1GW of solar energy generation to the grid in the past six months finds most will not be looking to secure support for larger

68 DECC, Electricity Market Reform: Contracts for Difference, 26 May 2015 69 DECC, Energy Act: Renewables Obligation Transitional Arrangements, 2013 70 Business Green, Solar farms shelved following government contract controversy, 7

April 2015

Box 2: Contract for Difference (CfD)

A Contract for Difference (CfD) is a private law contract between a low carbon electricity generator and the Low Carbon Contracts Company (LCCC), a government-owned company.68 The contracts require developers to bid to supply electricity at a certain "strike price", which is then guaranteed by the government, as part of efforts to drive down the cost of clean energy.69 Renewable energy developers compete with each other in reverse auctions to win subsidy contracts, this guarantees a payment to renewable energy developers in case of a market shortfall.

Number 07434, 16 December 2015 26

projects through Contracts for Difference (CfD) in the year ahead.71

In response a spokeswoman from DECC stated that CfDs were a viable option:

We've already allocated 25 CfD contracts, including two solar projects – demonstrating that the CfD is an investable proposition for a wide range of renewable technologies, including solar, and one that can drive real cost reductions through competition.72

4.6 Reactions to the proposals The proposals for changes to FITs and the Renewables Obligation, have been meet with great concern by the renewable energy sector. The solar PV sector would suffer the most severe cuts under the proposed changes. Many are of the view that with the right support the sector could become subsidy free by 2020, but that the proposed cuts could make this unachievable. The Solar Trade Association reaction, in an article titled ‘Solar Industry welcomes growing call for Government to reconsider ‘extreme’ Feed-In Tariff proposals’, reflected this:

The Government’s own Impact Analysis shows their proposals will reduce the UK solar industry to a shadow of its former self, with insufficient business to sustain solar installers and the wider UK supply chain. STA modelling, which has been verified by experts from Imperial College, shows that it will add only £1.70 to household bills in 2020 to deliver well over a million more solar homes. The modelling showed that it is growth and political stability which will drive the sector off subsidy through economies of scale. DECC’s proposals are the complete opposite. 73

And:

It is quite wrong to suggest we cannot afford to go solar. The truth is we cannot afford not to. It’s hard to think of a greater waste of public money than building up a strong British solar industry, hailed by the Prime Minister as a success, and then pushing it over a cliff before it is ready to fly.74

Michael Dall, lead economist at Barbour ABI, outlined some of the risks of cutting subsidies, including job losses and stopping growth of the solar industry:

"The government's stance on solar is that falling costs have made it easier for the industry to survive without subsidies, particularly with the drop in prices for wholesale electricity prices."

"However, the risk here is that diminishing subsidies could falter a growing industry, potentially putting it under major jeopardy. Up to 27,000 jobs are at risk over the coming years in solar alone, not

71 Business Green, Solar farms shelved following government contract controversy, 7

April 2015 72 Business Green, Solar farms shelved following government contract controversy, 7

April 2015 73 Solar Trade Association, Solar Industry welcomes growing call for Government to

reconsider ‘extreme’ Feed-In Tariff proposals, 17 September 2015 74 Solar Trade Association, Solar Industry welcomes growing call for Government to

reconsider ‘extreme’ Feed-In Tariff proposals, 17 September 2015

27 Solar Farms

mentioning other renewable technologies, if more subsidy cuts are on the way."75

Many companies within the renewables industry suggested that the proposed cuts would result in the collapse of the UK solar industry. Frans van den Heuvel, CEO at Solarcentury, said:

"In little more than three months, the Conservative Government has literally turned upside down the certainties which had characterised the UK renewables market and the cross-party consensus that underpinned it. If the consultation is enacted, we can expect to see a wholesale collapse in solar take up by homeowners and businesses - just at a point in time when most other countries are escalating their solar deployment having seen the dramatic impact the technology can make in tackling climate change. So much for Amber Rudd's promised "solar revolution" and the former Conservative energy Minister's pledge to put "rocket-boosters" under the non-domestic roof sector. 76

It is also thought that the cuts will severely affect sub-5MW standalone projects such as small scale solar farms:

DECC is currently consulting on plans to close Renewables Obligation support for sub-5MW solar farms a year earlier than planned in March 2016, while the removal of grandfathering effectively shut off the planning application deadline on 22 July.

The small-scale feed-in tariff would be the only means of support for ground-mount solar farms up to 5MW in size, however the government has also sought to cap their deployment by consulting on the cancelling of pre-accreditation. This means projects would not be guaranteed a FiT until they connect to the grid and start generating, rather than being able to obtain a conditional rate prior to the start of development. 77

There is also some criticism of the Government for justifying the closure of the Renewables Obligation in terms of the LCF. In October 2014, just after the closure of the RO to >5MW solar, Seb Berry, head of public affairs, Solarcentury stated:

Earlier this week, on the Conservative Party conference fringe, ministers were busy talking up the contribution from solar and promising "long-term certainty" for investors in all renewables. Today's announcements however, do little to undo the disruption and uncertainty of the last five months, providing at best a very marginal boost to roof-top solar to 2020 while confirming a premature end to the solar Renewables Obligation for large-scale projects.

It's baffling that the government continues to justify these decisions in "value for money" terms, when everyone knows that they are being driven by the coalition's preference for ring-fencing spend on the much more expensive option of off-shore wind, at a

75 Business Green, Solar power industry braces for 98 per cent feed-in tariff spending

cut, 22 July 2015 76 SolarCentury, Solarcentury responds to FiT consultation announcement, 27 August

2015 77 Solar Power Portal, Upcoming standalone FiT degression a ‘significant concern’ for

sub-5MW projects, 24 August 2015

Number 07434, 16 December 2015 28

time when by contrast spending on the solar RO amounts to just over 1% of the total Levy Control Framework budget.78

The Solar Trade association has launched a ‘£1’ solar rescue plan which aims to ‘save’ the solar industry:

The UK’s most popular energy source is fighting for its survival and it needs your help. High profile solar companies are folding or planning to leave the UK. If Government is to secure the British industry it must act quickly. Our emergency plan, if enacted next January, would add just £1 to household bills by 2019, demonstrating how affordable it is to adopt sensible reductions in support for solar power. The alternative – decimating the British industry – will waste huge public support to date, cost an estimated 27,000 jobs and set the UK apart from an international tide of technology change, consumer empowerment and economic opportunity. 79

A round up of reactions to the Feed-in Tariff cuts can be found on the Business Green website, under their Policy section, titled Feed-in Tariff cuts: the reaction. 80 Industry reactions to both FIT cuts and the closure of the RO can be found in a Utility Week articles titled further subsidy cuts for renewables: the industry reacts. 81

4.7 Impact on jobs The Guardian reported that many hundreds of jobs at small solar businesses will be further at risk, in addition to 1,000 jobs that have already been lost after four solar power companies announced they were going into liquidation, blaming the government cuts to support for solar. 82

The impact assessment in the consultation on a review of the Feed-in Tariff scheme referred to the impact on jobs, which was not quantified, and which the Government was seeking information on through the consultation. However the impact assessment acknowledged there would be a negative impact:

The scheme has certainly seen a significant amount of jobs transfer from other parts of the economy to support renewables installation. The proposed changes will see the current high rate of deployment decrease, likely leading to a rebalancing of jobs in this sector. There is therefore likely to be a negative impact on existing jobs in the renewable electricity generation sector, though DECC has not been able to quantify it.83

There were reports in the press of leaked conversations with Ministers that suggested the impacts on jobs in the renewables sector was not a consideration of the Review:

78 Solar Power Portal, Industry reacts to RO closure for >5MW solar in 2015 and CfD

budget, 2 October 2014 79 Solar Trade Association, Back our emergency ‘£1’ solar rescue plan, 23 October

2015 80 Business Green, Feed-in Tariff cuts: the reaction,27 August 2015 81 Utility Week, Further subsidy cuts for renewables: the industry reacts, 24 July 2015 82 The Guardian, Revealed: Many more solar firms face closure if government cuts go

ahead, 19 October 2015 83 DECC, Consultation on changes to financial support for solar PV, 22 July 2015

29 Solar Farms

In a highly unusual move, British Photovoltaic Association chair Reza Shaybani has published an account of the meeting in which he says Rudd told him the impact on jobs was not part of the consultation on the solar subsidy cuts. An analysis, based on government data, by Friends of the Earth estimates that 22,000 jobs could be lost by the proposed 87% cut in support for domestic solar electricity.

A spokesman for the Department of Energy and Climate Change said: “This was a private meeting, of which no verbatim minutes or transcripts were taken. We do not recognise this document or the quotes it contains.”84

The 22,000 job losses figure was echoed in open letter from a large group of organisations including trade associations, NGOs, the NFU, and manufacturers such as DuPont and Panasonic, calling on the Government to reconsider the proposals and emphasising the widespread public support for renewables:

If the current proposals are implemented, analysis based on your Department’s figures shows more than 20,000 people could lose their jobs in pioneering renewable energy companies. Your own analysis shows nearly a million fewer homeowners, social housing providers, businesses, community groups, local authorities and farmers will be able to join the “solar revolution” you called for just four months ago.

While we accept that subsidies for technologies cannot go on indefinitely, it is absolutely essential that changes to Government policy are taken with appropriate consultation with stakeholders in order to retain investor confidence and to allow for a smooth, stable transition towards grid-parity.

78% of the British public want Government to enable investment in local renewables. The published proposals do the opposite.85

4.8 Interaction with other policies The FIT Review followed a raft of changes with impact on the low carbon and renewables sector. These included early closure of the Renewables Obligation to onshore wind, changes to planning guidance on onshore wind, removal of grandfathering of support rates for biomass conversion under the RO, closure of the Green Deal scheme aimed at improving energy efficiency, the proposed sale of the Green Investment Bank and the abandonment of the 2016 zero carbon homes target.86

All these changes have had an impact on investor confidence which was reflected in the UK dropping out of the top ten most attractive countries to invest in renewables (from eighth to eleventh) for the first time since the Ernst and Young Renewable Energy Country Attractiveness Index was introduced in 2002:

After experiencing what seems to be death by a thousand cuts, the UK renewables sector is trying to make sense of the Government’s latest inconsistent actions.

84 Solar Power Portal, Rudd defends Tory solar record, claims ‘any new government’

would have reviewed subsidies, 7 September 2015 85 Friends of the Earth, Open Letter to the Secretary of State, 17 September 2015 86 DECC, Policy: Low carbon technologies, Accessed 5 November 2015

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At best this may be misguided short-term politics obstructing long-term policy. At worst, however, it’s policy-making in a vacuum, with no rationale or clear intent.

Though the latter is more worrying, both could sour the UK’s general attractiveness as an investment destination if the can pull the rug from under the feet of investors backing low cost, sustainable energy when it is most needed, is any sector safe?

The question is, should the UK renewables sector continue to fight policy tinkering by a Government with unclear motives, or is this an opportunity for it to establish itself at the forefront of unsubsidized renewables in Europe? This won’t be easy, but it may well be worth taking the risk.87

The changes have also led the Government’s commitment to reducing emissions and tackling climate change being called into question. Amber Rudd, the Minister for DECC, has consistently reiterated that this is not the case, stating that unchecked climate change is one of the greatest long-term economic risks this country faces. 88, 89

87 Ernst & Young (EY), Renewable energy country attractiveness index, September

2015 88 Gov.uk, Secretary of State speech on Climate Change, 24 July 2015 89 Gov.uk, Secretary of State speech on Climate Change, 24 July 2015

31 Solar Farms

5. Solar farms and agriculture Many solar farm developers actively encourage multi-purpose land use, through continued agricultural activity. It is commonly proposed in planning applications for solar farms that the land between and underneath the rows of PV modules should be available for grazing of small livestock. Larger farm animals such as horses and cattle are unsuitable since they have the strength to dislodge standard mounting systems, while pigs or goats may cause damage to cabling, but sheep and free-ranging poultry have already been successfully employed to manage grassland in solar farms while demonstrating dual-purpose land use.

Other productive options such as bee-keeping have already been demonstrated. According to the Bumblebee Conservation Trust (BBCT) ground-mounted solar farms help in producing microhabitats (small specialised insect homes) for bees with a variety of wet, shaded and sunny areas, making attractive homes for wildlife.90 In some cases, solar farms may actually enhance the agricultural value of land, where marginal or previously-developed land (e.g. an old airfield site) has been brought back into more productive grazing management.

The National Farmers Union (NFU) provides guidance to farmers on solar power in agriculture, for example Solar photovoltaic electricity in agriculture – on your roofs and in your fields, (Dec 2013) sets out the benefits to farmers, the potential for continuing to use the land, and bringing it back into use after the end of a project.91 The Building Research Establishment (BRE) has also published guidance for farmers wanting to install solar panels Agricultural Good Practice Guidance for solar farms.92 This gives information about design and layout of solar farms, conservation, grazing, construction and long term management. The BRE particularly highlight management of small livestock in solar farms.

Farmer unions across the UK are very supportive of renewables and in June 2015 made a co-ordinated call for more action from government to realise their potential:

Following a meeting in Birmingham, the UK farming unions are calling on government and the devolved administrations to do all they can to unlock the huge potential of land-based renewables.

Solar, wind, mini-hydro, anaerobic digestion and other forms of sustainable bioenergy all have a role in UK energy security and provide substantial diversification incomes in support of profitable agricultural production.

Moreover, in the run up to November’s international climate talks in Paris, the unions (NFU, NFUS, UFU and NFU Cymru) say it is vital

90 Solar Power Portal, Solar farms to provide lifeline to British bumblebees, 4 July 2013 91 NFU Briefing, Solar photovoltaic electricity in agriculture – on your roofs and in your

fields, December 2013 92 BRE, Agricultural Good Practice Guidance for Solar Farms, 2013

Number 07434, 16 December 2015 32

that governments acknowledge the unique capacity within the agricultural sector for tackling climate change.93

5.1 CAP subsidies restructure for solar farms

The Common Agricultural Policy (CAP) is a system of EU agricultural subsidies and programmes covering farming, environmental measures and rural development. Direct subsidy payments from 2015 are being made via the Basic Payment Scheme. This was previously the Single Payment Scheme (SPS).

Under the SPS, Farmers could claim CAP direct payments on land being used for solar farms if the primary purpose of the land parcel was for agriculture and the land under the panel was capable of being grazed.

In October 2014 The Department for Environment, Food and Rural Affairs (DEFRA) announced that farmers who chose to use fields for solar farms would not be eligible for any farm subsidy payments from the Common Agricultural Policy (CAP) from January 2015.94 A similar decision was made in Wales95. The rationale for this change was given as follows:

In our view solar farms by their very nature do significantly hamper agricultural activity, even if that activity is just grazing, as there will be limitations on how the animals may graze in a field covered by solar panels. We want to make sure CAP is going to those people who primarily use the land for agriculture.96

However, current planning advice for solar panels on agricultural land is already geared to ensuring that high grade agricultural land is not used (see section on the Basic Payments Scheme below) so it was not immediately clear why this move was necessary.

In the announcement, Environment Secretary, Elizabeth Truss indicated that the change was motivated by ensuring that agricultural land was as productive as possible:

English farmland is some of the best in the world and I want to see it dedicated to growing quality food and crops. I do not want to see its productive potential wasted and its appearance blighted by solar farms. Farming is what our farms are for and it is what keeps our landscape beautiful.

I am committed to food production in this country and it makes my heart sink to see row upon row of solar panels where once there was a field of wheat or grassland for livestock to graze. That is why I am scrapping farming subsidies for solar fields. Solar panels are best placed on the 250,000 hectares of south facing

93 NFU Press Release, Unions seek recognition on land-based renewables, 14 July 2015 94 DEFRA Press Release, Subsidies for solar farms to be cut to help safeguard farmland,

19 October 2014 95 GWALD, Solar parks – new rules, accessed 15 December 2015 96 DEFRA Freedom of Information Release, Common Agricultural Policy (CAP) subsidy

on solar arrays, 16 February 2015

33 Solar Farms

commercial rooftops where they will not compromise the success of our agricultural industry.97

The new guidance for the Basic Payment Scheme (BPS), (February 2015), now makes it clear that land parcels which contain solar panels are ineligible. However, if the panels are concentrated in one end of a field, the rest of the land can be eligible if the 2 areas are registered.98 In October 2014 farmers were given guidance on the new CAP schemes in England which explained what had happened over the previous months.99

In February 2015 the government produced more evidence on its decision after a FOI request under the Environment Information Regulations. This included a briefing from Defra’s Direct Payments Policy Team explaining the changes:

What’s changing:

From 2015, farmers will not be able to claim basic payments on land on which solar arrays are sited. Currently farmers can claim agricultural subsidy if they can prove the land is predominantly for agricultural use.

Why it’s important:

• We want to make sure CAP is going to those people who primarily use the land for agriculture.

• Solar photovoltaic (PV) technology plays an important part of England’s diverse energy mix. We want to see this clean energy sector grow in the right way.

• Solar PV needs to be appropriately sited, give proper weight to landscape and visual impact, heritage and local amenity, and provide opportunities for local communities to influence decisions that affect them and gain community benefit – as set out in the Solar PV Roadmap.

• Large scale solar farms should be focused on previously developed and non-agricultural land. Agricultural land should only be used where it is shown to be necessary.

The justification:

• The UK solar PV sector has undergone a huge transformation since the Coalition Government came to office in 2010. From almost zero, PV has now been deployed on over half a million buildings, with total installed capacity in 2014 set to exceed 4GWp.

• Take-up of ground-based solar has been stronger than anticipated, though hard data remains very limited; NFU estimate that c250-300 solar ground based units are up and running in England currently, and expect around 1,000 ground-based solar farms by end of the decade across the UK.

97 DEFRA Press Release, Subsidies for solar farms to be cut to help safeguard farmland,

19 October 2014 98 DEFRA, Basic Payment Scheme: guidance for 2015, The Basic Payment Scheme in

England 2015, 24 February 2015. 99 DEFRA, The new Common Agricultural Policy schemes in England, October 2014

Number 07434, 16 December 2015 34

• CAP funds are shrinking. We need to allocate funds to support people who primarily use the land for agriculture.100

5.2 Practical Impacts As BPS payments are only now being made, for 2015/2016, the full impact of this decision is not yet clear. It has been estimated that this change would mean a loss of subsidy of around £222/ha of land containing solar panels101. However, this compares to ground rents for large solar farms between £1500/ha and £2500/ha or more, that a farmer may receive from entering an agreement to host a solar project.102 Indeed, previously some farmers did not claim on the area of land used for solar panels because the administrative requirements of only counting the non-grazed areas were too onerous for the limited payments available.103

5.3 Reactions to limited CAP claims for solar farms

The stakeholder reaction to restricting payments under the CAP for land underneath solar farms have been negative. The Solar Trade Association, questioned the Government’s stance that solar farms were reducing agricultural productivity:

“It is damaging and incorrect for Defra to suggest that solar farms are in conflict with food production. The government’s own planning guidance makes clear that farming practices should continue on solar farms on greenfield land. The industry, working with the National Farmers Union, has been very careful to define good practice to ensure continued agricultural production.

“The land is still available for farming – the solar fixings only take up 5% of the land. This means plenty of room for continued agricultural practices such as sheep, geese or chicken farming. As far as farm payments are concerned, solar should really be treated in the same way as orchards or fields with trees, where animals continue to graze the land in between.

“Solar farms have an important role to play in conserving our countryside. Not only can solar power save huge amounts of greenhouse gases, but solar farms can provide protected spaces for boosting biodiversity, such as wildflowers and bees, as well as providing greater income stability for farmers who face increasing weather risk due to climate change. We urge Defra to champion best practice in the solar industry for the benefit of British farmers, our climate and our countryside.”104

Current planning guidance for solar panels on agricultural land is already geared to ensuring that high grade agricultural land is not

100 DEFRA Freedom of Information Release, Common Agricultural Policy (CAP) subsidy

on solar arrays, 16 February 2015 101 Liz Truss accused of trying to woo UKIP voters with ‘minute’ solar subsidy cuts,

Business Green, 21 October 2014 102 NFU Press Release, Unions seek recognition on land-based renewables, 14 July 2015 103 Liz Truss accused of trying to woo UKIP voters with ‘minute’ solar subsidy cuts,

Business Green, 21 October 2014 104 Solar Power Portal, ‘Damaging and incorrect’: Industry reaction to solar farm CAP

scrap, 20 October 2014

35 Solar Farms

used.105 Lower grade agricultural land has tended to be used for solar panels and farmers have actually found benefits to livestock from the shelter provided.106 Hence, farmers’ use of solar panels has not majorly impacted on the food production potential of the land, most of which would have been used for grazing anyway.107 The NFU Briefing, Solar photovoltaic electricity in agriculture, states that solar arrays have a negligible impact on food security:

If 10 GW of solar power were ground-mounted (half the national ambition for 2020 set by DECC), this would occupy at most 25,000 hectares - just 0.14% of total UK agricultural area (18 million ha) with a negligible impact on national food security. Solar farms are a temporary and reversible use of farmland - the modules are typically mounted on screw piles, to be removed at the end of the 25-year planning consent period, enabling land to return to agriculture.108

Other reactions focussed on the small savings in CAP subsidy that this change will deliver and questioned why CAP has been restricted for solar farms rather than other non-food production processes that often take place on farms, such as growing energy crops or hosting camp sites. 109

The Government was criticised for admitting that it had not assessed the impact of its decision about solar and CAP. This was brought out in a written PQ in 2014:

Asked on: 22 October 2014

Julie Elliott: To ask the Secretary of State for Environment, Food and Rural Affairs, with reference to her Department's press release of 19 October 2014, on the reduction of subsidies for solar farms to safeguard farmland, what estimate she has made of the potential annual change in mW of solar-generated energy as a result of that policy.

Answered on: 27 October 2014

George Eustice: The decision to make land covered by solar panels ineligible for the CAP Basic Payment Scheme reflects the fact that agriculture is no longer the predominant use of such land. The Government wants farmers to prioritise making the best use of their land for agriculture and food production. However, we have made no estimate of the potential annual reduction in generating capacity.110

105 Department for Communities and Local Government, National Planning Policy

Framework, 27 March 2012 106 Are solar farms really hitting British food production, The Guardian, 21 October

2014 107 Are solar farms really hitting British food production, The Guardian, 21 October

2014 108 NFU Briefing, Solar photovoltaic electricity in agriculture – on your roofs and in your

fields, December 2013 109 Liz Truss accused of trying to woo UKIP voters with ‘minute’ solar subsidy cuts,

Business Green, 21 October 2014 110 Parliamentary Questions, Solar Power:Written question – 211422, October 2014

Number 07434, 16 December 2015 36

6. Environmental impact DECC published a UK Solar PV Strategy in April 2014 which stated that “DECC and Defra will work with industry to understand better the effects (both positive and negative) of solar farms on biodiversity.”111 The Strategy also highlighted best practice guidance from the Solar Trade Association (STA), which are a series of 10 commitments that solar farm developers, builders or tenants who are members of the STA have committed to complying with. This is a voluntary scheme:

1. We will focus on non-agricultural land or land which is of lower agricultural quality.

2. We will be sensitive to nationally and locally protected landscapes and nature conservation areas, and we welcome opportunities to enhance the ecological value of the land.

5. We will encourage land diversification by proposing continued agricultural use or incorporating biodiversity measures within our projects.

10. At the end of the project life we will return the land to its former use.112

The UK Solar PV Strategy also highlighted the BRE National Solar Centre Biodiversity Guidance for Solar Developments 113 which has been developed in conjunction with The National Trust, The Bumblebee Conservation Society, the RSPB, Plantlife and six other conservation organisations and which is intended as guidance to planners as to the biodiversity issues associated with solar farms. There has been some criticism on the blog “a new nature blog” that the guidance does not completely rule out development on land that has any conservation value.114

The potential environmental impacts of ground based solar panels on agricultural land is a new area of research. A Guardian Online article from July 2014, summarised the current limited understanding of the impacts of solar farms on land, and the potential for designing installations for maximising environmental and agricultural benefits as better evidence emerges:

Work on wind farm sites, for example, has highlighted local effects on temperatures, changed humidity levels through turbulence, higher concentrations of biogenic gas (CO2, methane and nitrous oxide), and changes in patterns of cloud cover and rainfall. It's clear that PV panels will cause shading and changes to wind flow, and in principle is likely to alter temperature, change

111 DECC, UK Solar PV Strategy, para 73, April 2014 112 Solar Trade Association, 10 Commitments for Solar Farms, accessed on 24

November 2015 113 BRE Biodiversity Guidance for Solar Developments. Eds G E Parker and L Greene,

2014 114 Wordpress, A new nature blog, Held to Ransom: Solar Farms – green or greed?, 13

July 2014

37 Solar Farms

the rainfall distribution (which impacts on soil moisture) and the wind flow over the land.115

6.1 Wildlife impacts The impacts on wildlife of any proposed array will very much depend on the characteristics of each site. Natural England has produced advice Solar parks: maximising environmental benefits (Sept 2011) which covers landscape and environmental impacts, in this it makes clear that whilst solar arrays may be inappropriate in some areas they may be used to enhance biodiversity in others:

The location of solar parks should avoid sites of high wildlife value, in particular, designated sites such as Sites of Special Scientific Interest (SSSIs), Special Protection Areas and Special Areas of Conservation. Any development proposed on land within or adjacent to designated sites is likely to have an adverse effect on the environmental features for which they were designated, in particular during the construction phase.116

The advice summarises the opportunities as follows:

Solar park sites, especially on sites of lower existing biodiversity value may offer opportunities to deliver enhancement measures. These should be considered on a site by site basis and are likely to be most effective when they contribute to local biodiversity priorities identified through your local Biodiversity Action Plan. These should be available on the web. Creating grasslands and hedgerows on the areas around the panels is likely to offer most benefits for plant and animal communities.117

All proposals will require some form of impact assessment setting out potential environmental impacts. If the development is over a certain size it will also require an Environmental Impact Assessment as set out by legislation National Planning Policy Framework.118 South Hams council has provided some interim guidance which helpfully summarises the kind of issues considered:

The process is governed by Regulations which prescribe the types of development for which an EIA is required. SolarPV development falls within Schedule 2 of the Regulations, where an EIA must be carried out if the development is likely to have a significant impact on the environment by virtue of its nature. The majority of proposals for solarPV development will not be of sufficient scale or impact to require a formal Environmental Impact Assessment119

Regardless of the need for a formal Environmental Impact Assessment, the Council will still require robust information about the environmental impacts of the proposal and appropriate evidence and information to support a planning application.120

115 The Guardian, Solar is booming but solar parks could have unintended climate

consequences, 18 July 2014 116 Natural England, Solar parks: maximising environmental benefits, 9 September 2011 117 Natural England, Solar parks: maximising environmental benefits, 9 September 2011 118 Department for Communities and Local Government, National Planning Policy

Framework, 27 March 2012 119 South Hams District Council, Solar Arrays in South Hams, Interim Planning Guidance

for Solar Arrays Requiring Planning Permission, April 2013 120 South Hams District Council, Solar Arrays in South Hams, Interim Planning Guidance

for Solar Arrays Requiring Planning Permission, April 2013

Number 07434, 16 December 2015 38

The guidance also sets out the kind of evidence and information that would be required.

The Royal Society for the Protection of Birds (RSPB) has highlighted a range of effects that solar farms could have on wildlife.121 This sets out some of the direct impacts on birds, such as collision risk, as well as indirect impacts on other wildlife such as insects mistaking solar panels for bodies of water. It also highlights that land use change impacts could include direct habitat loss and/or displacement or disturbance of a species.122

121 RSPB Policy Briefing, Solar Energy, December 2014 122 RSPB Policy Briefing, Solar Energy, December 2014

BRIEFING PAPER Number 07434, 16 December 2015

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