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BRIEFING PAPER

Number 07434, 16 December 2015

Solar Farms: Funding, By Madeline Burke

planning and impacts


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

www.parliament.uk/commons-library | intranet.parliament.uk/commons-library | papers@parliament.uk | @commonslibrary


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.
Number 07434, 16 December 2015 4

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
Number 07434, 16 December 2015 6

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
7 Solar Farms

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. London receives 0.11
While the sunniest parts of the UK receive much less solar radiation than kilowatts of sunshine per
the sunniest parts of Europe, the UK's insolation in the south is square metre (kW/m2) on
comparable with that of central European countries. 10 average, compared with
0.19kW/m2 for Athens,
The chart below shows that the largest contribution to renewables and which is nearer the
waste energy in input terms (around 72 per cent in the UK) is from equator, and 0.24kW/m2
bioenergy (excluding non-biodegradable wastes), with wind generation for Cairo, which is nearer
and hydro electricity production contributing the majority of the still. On average the UK
remainder. Just 3.8 per cent of renewable energy comes from receives 0.11 kW,
renewable sources other than biomass, wind and hydro. These include equivalent to 3.42 GJ a
solar, heat pumps, and deep geothermal. 11 Based on the average year, of solar radiation per
annual consumption of a household, for every 5MW installed, a solar square metre.
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
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
Number 07434, 16 December 2015 10

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
11 Solar Farms

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 Framework 21, 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
Number 07434, 16 December 2015 12

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
13 Solar Farms

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 2013 30 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
Number 07434, 16 December 2015 14

• 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
15 Solar Farms

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
Number 07434, 16 December 2015 16

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

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.

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
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
Number 07434, 16 December 2015 30

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 Wales 95. 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 panels 101. 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 Assessment 119
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
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