The Voice for Devon’s Countryside

www.cpredevon.org.uk

PO Box 26, Beaworthy, EX21 5XN Registered Charity No: 1175228

Tel: 01392 966737

North Devon District Council Reference: 80402

Torridge District Council Reference: 1/0470/2025/FULM

Proposed installation of ground mounted solar farm (49.9MW) & battery

energy storage system (BESS) & associated ancillary works

Bulworthy Farm Alverdiscott Bideford EX39 4PY

Devon CPRE

3rd September 2025

Devon CPRE objects to planning applications 80402 and 1/0470/2025/FULM.

The planning application contains many misleading, incorrect and unsupported

statements. It does not provide any references to the information used to provide any

claims made.

Electrical Energy Produced

The Design, Accessibility & Planning Appraisal (DAPA) provides details concerning the

proposal. Section 6.0 of the DAPA states that the purpose of the solar farm is to

“generate essential clean energy”. However, the DAPA does not state what the purpose

of the Battery Energy Storage System (BESS) is.

The DAPA does not provide the most important information concerning the BESS, namely

its storage capacity and how and when it would be used. Section 12.0 states that the

storage capacity is up to 49.99MW. This statement is wrong. 49.99MW is the BESS

power capacity - hence the units of MW. The storage capacity would be the maximum

amount of energy stored and would be given in units of MWh. BESS are very expensive

facilities and, depending on their usage, would need replacing several times during the 40

year life of the development. The BESS would add considerably to the cost of the

electricity produced by the solar farm.

The Executive Summary and Sections 11.0 and 12.0 of the DAPA state that the proposed

development would power the equivalent of up to approximately 24,000 UK households,

whereas Section 13.0 states that the proposed development would power the equivalent

of up to approximately 18,000 UK households. Which is supposed to be the claimed

number? This should be clarified. No information is given as to how the number is

calculated. Presumably it is dependent on the installed capacity, the claimed load or

capacity factor and the average UK household power consumption. The proposed

installed capacity is up to 49.9MW. Ofgem gives an average annual UK household

consumption of 2,700kWh. Statista gives an average solar load factor in the UK of

10.2%. This would result in the development producing enough electricity to power (49.9

x 0.102 x 24 x 365) / 2.7 = 16,500 households. The applicant would seem to be using

incorrect data and this should be clarified. Furthermore, as the solar panels age, their

performance is degraded (by up to 1% per year) so that the load factor would fall and the

number of households powered would also be reduced. The BESS would be a net

2consumer of the electricity produced by the solar panels due to round-trip losses incurred

during charging and discharging the batteries. This would further reduce the average

number of UK households powered by the proposed development.

The poor performance of the proposed solar farm is not surprising given that the World

Bank has shown that in terms of solar energy potential, the UK is the second worst

country in the world.

The average number of households powered by the proposed development is in fact a

meaningless statistic, because at night the proposed solar farm would power no

households and during winter, when demand is highest, it would power very few

households. Quite clearly the information provided in the application is incorrect as is the

description of the benefit in terms of the electricity produced by the proposed

development. The applicant should provide a report giving the details of how much

electrical energy the proposed development would supply to the grid and when it would be

provided so that the backup needed to provide grid balance can be determined.

The recent blackouts in Spain, Portugal and part of France have highlighted the danger to

the distribution and transmission networks of too much reliance on intermittent and

asynchronous generation, such as solar and BESS. The proposed development,

producing DC electricity, converted via inverters to AC for export to the grid, would

decrease the inertia of the grid when operating and would therefore increase the risk of

blackouts, which would be catastrophic. There have been several near-misses to local or

nationwide blackouts and this proposal could only make the situation worse, particularly

as there are many similar local facilities exporting to the 132kV grid.

Delivery of Electrical Energy

The developer has provided no evidence that the local 132kV grid and the 400kV

Alverdiscott substation have the capacity to accept electricity from the proposed

development. Has the developer obtained a connection offer from the National Grid?

Furthermore, it is evident that the eastern parcel of the proposed solar farm has no

connection to the western parcel and therefore cannot deliver electricity generated from

the solar panels to the proposed substation in the western parcel. The eastern parcel

should be removed from the planning application as it serves no purpose.

BESS Risk

The risk from a BESS is the probability of an initiating fault occurring combined with the

consequences of the fault. The major concern with a BESS is a fire and/or explosion.

The risk from BESS comes from faults leading to thermal runaway with the possibility of a

fire/explosion, the consequence being the release of toxic and explosive vapour clouds.

The probability of a fire is proportional to the number of individual battery cells and a

thermal runaway can be caused by many initiating events. The consequences could be a

fire or an explosion with the emission of toxic fumes and heavy metals affecting both local

residents and the local environment. Attempts to extinguish the fire or prevent its

spreading to adjacent modules could lead to fire water run-off and consequential

groundwater pollution.

The technology of Li-ion batteries has steadily improved over the past few years, so that

the probability of a fire at a BESS has fallen. However, so far in 2025 two BESS fires

have occurred in the UK (See EPRI ‘BESS Failure Incident Database’). The potential

consequences of a fire remain severe and the risk thus remains high.

In the UK there are no regulations and no standards for a BESS. This is confirmed in the

Outline Battery Safety Management Plan (OBSMP). Regulations are statutory, i.e.

enforceable by law. Standards change over time and are not enforceable. The Health &

Safety Executive does not regulate BESS. The Department for Energy Security and Net

Zero (DESNZ) provides guidance in ‘Health and Safety Guidance for Grid Scale Electrical

Energy Storage Systems’. March 2024. This guidance states that “Planning applications

and decisions should always be taken with a complete assessment of risks and impacts.”

The appellant has performed no risk or impact assessment. Guidance is also

provided by the National Fire Chiefs Council (NFCC). It has stated that it ‘recognises that

BESS pose specific hazards in the event of fire that are still not fully understood or

researched’. The Devon and Somerset Fire & Rescue Service can only give guidance to

developers and local planning authorities, and cannot enforce recommendations given in

the guidance. The OBSMP shows that the applicant has not performed a risk

assessment.

The location of the BESS is such that it poses an unacceptably high risk to local

residents and the environment.

Emissions saved

The DAPA makes numerous references to the need to reduce greenhouse gas (GHG)

emissions to meet various government targets, but completely fails to provide any

information as to by how much, if any, the proposed development would reduce such

emissions.

With regard to the GHG emissions savings, it is noted that the government has major

concerns in this area. It states in the Overarching National Policy Statement for Energy

(EN-1) dated April 2025 that:

All proposals for energy infrastructure projects should include a GHG assessment

as part of their ES. This should include:

• A whole life GHG assessment showing construction, operational and decommissioning GHG impacts, including impacts from change of land use.
• Measurement of embodied GHG impact from the construction stage.

A GHG assessment has not been undertaken. It is likely that, taking into account the

mining and refining of materials used in the manufacture of the solar panels, batteries and

other infrastructure, the transport, assembly, maintenance, decommissioning and back-up

of the proposed development, that there will be little, if any GHG emissions savings.

There may thus be no benefits from the proposal.

Farmland & Loss of Best & Most Versatile Land

The proposed 111.5ha (279acres) site is massive and is typical Devon farmland which,

together with the local climate, produces the finest quality beef and dairy products in the

world.

Section 12.0 of the DAPA shows that 25.5% of the site is grade 3a, 48% is grade 3b and

24.3% is grade 4. This land is ideal for growing grass and other feed crops for sheep,

beef and dairy production. The proposal affects 27.7ha of Grade 3a Best and Most

Versatile (BMV) land. Natural England states: “The development would result in the

temporary loss of BMV land and may not be in line with planning guidance which

encourages solar farms to be located on previously developed or non-agricultural land.”

There is therefore conflict with Policy ST01 and Policy ST03 of the North Devon Local

Plan (2018), which promote the safeguarding of productive land and prioritises

development on previously developed sites.

The North Devon Local Plan, the National Planning Policy Framework (NPPF) 2024, and

National Policy Statements EN-1 and EN-3 all support the preferential use of Previously

Developed Land (PDL) for solar development, especially over agricultural land. The

Environmental Statement references analysis of previously developed land. So, in line

with EN-3 which encourages justification for agricultural land use, are the LPA going to

require evidence of a site search for PDL alternatives, if not already provided?

The applicant makes many claims that agricultural activities would include sheep grazing.

However, observation of numerous solar farms in Devon has shown that sheep grazing is

impractical and is little used. In fact the use of herbicides is the preferred method of

vegetation control under solar panels.

The applicant also makes the claim that following 40 years and decommissioning of the

solar farm, the quality of the land would be improved. This is not correct. The strips of

land between the strings of solar panels would have been compacted due to use of

vehicles for solar panel cleaning and maintenance. Furthermore, water runoff from the

panels and pollution from the panels would damage the soil.

The proposed site is valuable farmland for food production and should not be used

for very inefficient electricity production.

The proposed development would lead to a considerable loss of food production and

would therefore have a considerable negative impact on food security. The loss of food

production would considerably outweigh the small gain in energy production.

Landscape

Devon CPRE are concerned that key landscape related issues raised in the

Pre-Application Response ENQ/0583/2023 (North Devon) and 1/0870/2023/SCRHID

EIA Screening Opinion (Torridge) have been missed or insufficiently addressed in the

submitted Landscape and Visual Impact Assessment (LVIA) for this proposal.

The LVIA partially responds but falls short of fully addressing the scope and depth of the

issues identified, especially around cumulative impact, elevated landform, and public

receptor visibility. For example:

The LVIA does not appear to meet the council’s expectation for a robust cumulative

landscape analysis, especially given the proximity to other large-scale solar schemes. The

LVIA acknowledges cumulative impact (Section 2.6.21), but fails to map or quantify

cumulative visibility.

The LVIA does not reflect the council’s clear recommendation to avoid visually prominent

elevated parcels, nor does it convincingly show how mitigation would reduce skyline

intrusion.

The LVIA does not fully respond to the council’s advice to assess all significant public

receptors, especially elevated viewpoints with wide visibility. It includes 13 representative

viewpoints but omits several key locations (e.g. Codden Hill, Webbery Cross). Some

areas are mentioned in passing but lack detailed visual analysis.

The LVIA understates the sensitivity of LCT 3A and does not fully justify how a 100+

hectare scheme aligns with the strategy to protect tranquillity and rural identity.

The response from Natural England supports our concerns that the LVIA lacks quantitative

or visual evidence to support claims that mitigation will reduce adverse effects, especially

from sensitive viewpoints. Stating: “The LVIA does not provide sufficient information to

assess the potential impacts on the special qualities of the National Landscape.”

This highlights conflict with Policy ST09 and Policy DM08A, which require that

development respects the character and setting of designated landscapes and avoids

adverse visual impacts.

Insufficient information

Both Natural England and the Historic Environment Team have highlighted inadequacies

in the assessments provided.

Natural England highlighting, amongst other things:

“The presence of ancient woodland and a veteran tree on or adjacent to the site requires

careful consideration and appropriate buffer zones.”.

“There is no assessment of the potential impacts on protected species, and the proposed

fencing and lighting may affect wildlife movement and habitat connectivity.”

“The application does not clearly demonstrate how biodiversity net gain will be achieved or

monitored.”

This is inconsistent with Policy DM08 and Policy ST14, of the North Devon and Torridge

Local Plan (2018) both of which require that development avoids harm to protected

species and maintains ecological networks. Section 15 of the National Planning Policy

Framework (2024) is also applicable.

The Historic Environment Team state:

The Heritage Statement submitted “is not sufficient to enable an understanding of the

significance of the heritage assets… or of the impact of the proposed development.”

Due to “known potential for survival and unknown significance of any below ground

archaeological deposits,” the Historic Environment Team objects to the application.

Without further information, they “recommend the refusal of the application,”.

The proposal conflicts with Policy DM07 of the North Devon and Torridge Local Plan

(2018) and paragraphs 207 and 208 of the National Planning Policy Framework (2024).

Benefits do not outweigh harms under the terms of the NPPF

NPPF paragraph 11 states that permission should be granted unless

any adverse impacts of doing so would significantly and demonstrably outweigh the

benefits, when assessed against the policies in this Framework taken as a whole

NPPF paragraph 168 states that:

When determining planning applications for all forms of renewable and low carbon energy

developments and their associated infrastructure, local planning authorities should:

not require applicants to demonstrate the overall need for renewable or low carbon

energy, and give significant weight to the benefits associated with renewable and low

carbon energy generation and the proposal’s contribution to a net zero future;

According to the Renewable Energy Planning Database (Jan 2025) and NSIPs registered

up to March 2025, more than 55GW of ground-mounted solar capacity has been applied

for (and the applications accepted), has been consented, is under construction or is

already operational in England. This represents 117% of the Net Zero target capacity for

2030 – not including any existing or planned rooftop solar or any further applications

accepted in the last six months.

If more than 117% of the Net Zero target has been obtained or is in the process of being

obtained, the ‘need’ for this application cannot be said to demonstrably outweigh the

cumulative harms to the landscape, amenity and economy of the parish that a 7% total

solar land-take would represent.

Solar Panel Manufacturer

The government has made its position clear on the use of slave and forced labour in the

solar panel supply train (see: Great British Energy to lead the field in ethical supply chains

- GOV.UK). If the council is minded to approve the planning application, then a condition

must be imposed which states that before installation of the solar panels commences,

information must be provided to the councils, and approved by the councils,

demonstrating that the solar panel supply chain is free of forced and slave labour

Conclusions

The benefits of the proposed solar farm have been exaggerated and many of the harms

ignored. In reality, there may be no benefits to outweigh the many harms outlined above.

Given the scale of the proposal, the sensitivity of the landscape, and the outstanding

concerns/responses from statutory consultees, the application should be refused.