I’m taking a close interest in two major developments on public or former public land, threatening newly designated Sites of Special Scientific Interest: Lodge Hill, and Rampisham Down.
In the case of Lodge Hill, the local Council officers recommended the Council approve proposals by the Ministry of Defence to sell over 300ha of public land to build a new town, garden city, or whatever the latest phrase is, of 5000 houses, schools, shops etc. The Council duly approved the application – and opened a Pandora’s box, as I described yesterday.
In the case of Rampisham Down, the Government sold off this piece of public land, which was a former strategic radio transmitting station, and has ultimately fallen into the hands of Solar Farm developers. The Council officers in this case have recommended the Council refuse planning permission. The Council will decide whether to approve it or not in January.
A couple of weeks ago I wrote about the latest twist in the Rampisham Down story, when the developers revealed “new” evidence they had gathered to support their case, but only revealed it to the Councillors, naughty naughty. Had the Councillors gone ahead and decided on the application, based on this new evidence, they would have breached the requirements of the 1985 Environmental Impact Assessment Directive. I can see UKIP supporters sighing and shaking their heads even at the mention of such a thing.
Anyway, the developers provided those reports (the top three on the list here) to the Council and the Council duly published them, asking for comments. The evidence they provide is very poor, and they make all sorts of unsupported claims based on this poor evidence. It is a bit of a shocker really.
If you would like to comment back to the council please email firstname.lastname@example.org
I have produced this response, from which you are welcome to copy:
Dear Mr Martin,
further to our previous correspondence, I am submitting these comments in response to the applicant’s belated submission for public view, of reports entitled “Rampisham Shade Report” “Environmental Data Report: Autumn 2014” and “Rampisham Down Shading Experiments Layman’s summary of the latest scientific information”.
The report on the effects of shading under the experimental panels is called the “Environmental Data Report”. This report confirms what the applicant had previously found, which was that under the solar panels, there is an increase in soil moisture, a reduction in soil temperature and light levels are reduced. There are a number of graphs which are difficult to interpret due to poor presentation. What is clear from figure 13 is that even the “semi-open” plots receive only 80% of the light levels of the open areas. This is a significant drop in the amount of light reaching the ground and I would suggest, based on my knowledge of plant communities in Britain, that this is sufficient to cause a change in the vegetation below the panels.
Given the presence of shade tolerant mosses such as Rhytidiadelphus squarrosus in the U4 communities on Rampisham Down, it would be logical to assume that these shade tolerant species would increase in the shaded, moister conditions under the panels, while flowers such as Heath bedstraw would decline.
Given that there are these evident physical changes under the panels, the experiment should be asking these questions:
1. Will the physical changes affect competition between more shade tolerant and less shade tolerant species?
2. Will the physical changes affect the capacity of different species of plant to flower and set seed?
3. Will the physical changes affect the opportunities for seeds to germinate and seedlings to establish – bearing in mind seed germination depends on light levels, but this requirement varies from one species of plant to another.
None of these important questions will be answered to any extent with the current experimental design.
Other important factors have not been incorporated into the experimental design. Grazing is critical to the management of a grassland such as Rampisham Downs. within the experiement, there is no grazing or any attempt to mimic the effects of grazing by cutting and removing vegetation. What are the impacts of extreme heat or cold; what happens if deep snow is blown under the panels? None of these are considered in the experiment.
In the report’s conclusions, the author notes that 2014 was sunnier than usual, therefore the variation in shading between open areas and areas shaded by panels may be larger than “normal”, since “normal” weather conditions are cloudier. While this is self evidently true, it tells us nothing about the impact of the panels on the vegetation. That vegetation has existed under weather conditions that have been sunnier, cloudier, warmer and cooler, over a period of millennia. The important point to note is that, as the report states, whatever the weather, the conditions under the panels have substantially changed – they have become cooler, damper and darker.
The second report is entitled “Rampisham Shade Report”. The report header states that this is a preliminary note to client – is there a final version? The report summarises data collected from botanical monitoring carried out under the experimental panels during 2014.
The report is intended to convey an impression that this is a scientific experiment and therefore the results should be given due weight as scientific evidence. But in truth there are no results within this report that have any bearing on the planning case in question.
The authors attempt to suggest that it is possible to monitor change in vegetation within a single year. This is not possible. Plants adapt to change over a variety of different timescales. If a grassland is ploughed and converted to an arable field, for example, it is possible to assess the changes in the plant community of the grassland over a period of two days, one on the day before the ploughing, and then again the next day. Using this approach a surveyor might conclude that there had been a 100% reduction in the number of species occurring at that site. If the surveyor returned a month after ploughing, they would find a completely different plant community, perhaps comprising a number of “arable weeds” and a crop, perhaps of wheat. If the surveyor returned a year later, they might find a different crop and a different set of arable weeds. And in ten years time a surveyor might return to the field and find it had returned to grassland, but with a different set of plants occupying the sward, compared with the original community.
The important point is that it is vital to choose the right timescale over which monitoring is carried out, and this depends on the type of plant community being monitored, and the type of change that is predicted to take place.
While a debate could be had over whether a 5 or 10 or even 20 year monitoring programme was long enough to find the signal of vegetation change in response to the introduction of the solar panels, there is no debate that the change will only be found over a period of several years. This is in the nature of vegetation, with individuals of different plant species responding to changing environmental factors in different ways. Long lived individuals may persist for many years before succumbing to a change in their circumstances (such as an increase in their shading.) But if these are species for which the site is deemed special, their disappearance is highly significant.
This report is based entirely on data collected from within one year, therefore it is scientifically invalid to make any statements about the change (or lack of) in the presence of plant species at Rampisham as a result of solar panels being introduced. It is therefre equalliy invalid to infer from these date any change in the type of plant community present, whether under a solar panel or not.
The other serious defect in the experimental design is the lack of replicates. For this experiment to yield scientifically valid results, a minimum number of replicates are needed, to enable the necessary statistical analysis of the results. At present, one small area of the site is being monitored using 16 1 metre squared plots, in four 4m long transects. For statistical analysis to be performed, I would suggest there should be at least 5 and preferably 10 replicates for each variable, so 10 transects of 4 1m squared quadrats. And in order to provide evidence that is applicable to the entire site, each experimental plot would need to be replicated across the site – at least 10 different locations on the Down would be needed to sample what is a site that varies considerably in its topography and vegetation.
The only scientific value that can be ascribed to the data in the report is as a baseline against which to assess change in subsequent years. But the only change it would be valid to conclude, was the change in vegetation under that particular panel; it would not be scientific to extrapolate those results to the entire site.
As these two reports contain no meaningful data, it is evident that the conclusions that are drawn in the “Layman’s summary” have no validity. It is simply not possible to claim, on the basis of no evidence, that “the experiments show that solar panels have virtually no effect on vegetation.” This is a well known fallacy called The Argument from Ignorance Argumentum ad ignorantium.
There is no evidence that the solar panels have, or do not have, an effect on the vegetation; we will have to wait for the evidence before coming to any conclusions. This is a basic element of the scientific method.
In conclusion, these three reports, provided by the applicant shed no additional light on the issue of whether the proposed solar farm will have a deleterious impact on the features for which the sites was notified as a Site of Special Scientific Interest, namely the unimproved lowland acid grassland, lowland heathland and chalk heath habitats.
The Council are in possession of all the evidence they need to determine this application. The site is nationally important for wildlife, and the Government’s statutory experts on wildlife, Natural England, have concluded that the development of a Solar Farm at Rampisham Down would damage the wildlife there. There is an alternative location immediately across the A356 from Rampisham, which would have no impact on the special wildlife at Rampisham Down.