This web page shows feedback from the Borgue Community relating to the proposal for a solar photovoltaic farm at High Nunton. It also includes responses to this feedback from the High Nunton project group. If you would like your comments to be included, please email them to This email address is being protected from spambots. You need JavaScript enabled to view it. or via the Contact page on this web site.

Index

Letter from Russell Malloch and other residents of Borgue to Robert Maitland - 4th August 2021

Letter from Linda Mallett, Kirkandrews, Borgue - 17th August 2021

Russell Malloch's Notes from BCC Meeting on 17th August 2021 - Received and posted on 23rd August 2021

Questions from Nancy Hill after the 20th August Public Session and Answers from High Nunton Solar

High Nunton Solar FAQ

Email from High Nunton Solar to Russell Malloch - 26th August 2021

Response from Russell Malloch to High Nunton Solar - 27th August 2021

Feedback from Nancy Hill following a visit to the proposed site

Combined feedback from site visits

Letter from Nancy Hill to Prospus Consulting - 2nd September 2021

Email from Russell Malloch on 22 Nov 2021 about the High Nunton discussions at the 19th October Community Council meeting

Update from Nancy Hill about her letter of 2nd September and response from High Nunton Solar (added on 6th December 2021)

Proposed Changes to Core Path 195 through High Nunton Solar site (received 6th December 2021)

High Nunton Solar Farm Update - 6th December 2021

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Letter from Russell Malloch and other residents of Borgue to Robert Maitland - 4th August 2021

Dear Mr Maitland

High Nunton Solar Farm

1.       I am writing to you about your letter of 31 July 2021, and your proposal to construct a solar farm and battery storage facility at High Nunton.

2.       I wish to raise several issues in connection with your proposal, including (a) the timing and extent of the consultation process, and (b) the provision of the information that is needed to allow me to consider the matter properly.

Timing

3.       You will appreciate that the community does not have any of the data on which your proposal rests, or even access to the current draft of your planning application and supporting documentation.

4.       I appreciate that some of this information may have been disclosed in 2019 in connection with what was then described as the Culraven Solar PV Plant, including the Scoping Report of 15 June 2019 that was prepared for you by the Wood Group (planning authority case reference 19/1259/SCO).

5.       It is clear, in any event, that your 2019 proposal did not proceed beyond the scoping stage, and so the community have no evidence on which to base an opinion, or even to be able to frame questions that may be relevant as regards your current proposal.

6.       In these circumstances I believe that the time for commenting about the scheme should be extended, as your stated response deadline of 1 September 2021 is less than 30 working days away, and it is not practical to consider matters properly, or to respond constructively in that very limited period.

7.       Your restricted timing, combined with the non-disclosure of information about the project, may even be construed as a deliberate attempt to impede a proper consideration of the proposal in advance of your application being submitted.

8.       I would therefore suggest that the response date should be extended to, say, 90 days after you give the community access to the complete data, including (a) the draft planning application and supporting documentation, and (b) your response to the issues referred to at 11. below.

9.       I would be grateful if you could confirm that you can accept my proposal, or explain why you are unwilling to do so.

Request for Information

10.   I have examined the particulars that have just appeared on the High Nunton Solar website referred to in your letter of 31 July 2021, and note that you make several assertions, as well as pointing to authorities and sources that you believe to be relevant for this purpose.

11.   I have been unable to identify some of your sources, or to confirm the figures and assertions you have made, and would be grateful if you help me by answering the questions set out in the following appendix to this email.

12.   One other matter arises, but falls outside the scope of your current High Nunton website, and that is to ask for your response to the issue of the apparent offence of deliberately damaging and/or destroying habitats used by protected species on land at the project site (Culraven Farm), which was reported to Dumfries and Galloway Council on 14 October 2019.

Communication

13.   I would be grateful if you could acknowledge receipt of this communication, and would ask for any response to be in writing, and to be sent to me at this email address.

14.   It might also help if your answers to the questions set out below were shared through the medium of the High Nunton website, as it is likely that other parties would welcome being able to access this sort of information.

Yours sincerely

R. J. MALLOCH

Resident of Borgue

 

HIGH NUNTON SOLAR FARM

APPENDIX

Note:    The questions set out below relate to statements made on the High Nunton Solar Farm website as of 3 August 2021.

Will you please provide:

1.       a copy of the draft planning application and related documents;

2.       the reports and supporting data for the “wide range of surveys [that] have been completed to establish how the land is currently being used by local wildlife including breeding birds, over wintering and migratory birds, badgers, bats and others”;

3.       a copy of the “bespoke landscape, planting and management plan” that is intended to “enhance biodiversity” at the project site;

4.       information about, and the contact details for, any of the low carbon energy projects that Prospus Group have successfully worked with local communities and stakeholders, but only if they were similar in scale and nature to the High Nunton proposal;

5.       the evidence of the extent to which the electricity generated by the project will “help to reduce the carbon dioxide emissions produced in providing electricity to the area”, and

6.       the evidence that the project will save an estimated 40,000 tonnes of carbon emissions over its lifetime.

Will you also please let me know:

7.       what survey work will be conducted between now (August 2021) and 2025 to determine the fact pattern on the project site in advance of the start of construction;

8.       the risks associated with the installation of solar panels and battery storage facilities on the project site, and the measures you intend to take to mitigate those risks;

9.       the financial and funding structure of the project;

10.   the evidence that leads you to state that the project will not receive “any government subsidy or tax breaks” and the assumptions you have made for this purpose, given that High Nunton is not planned to feed into the grid before 2025;

11.   what you mean by “government subsidy” and “tax breaks” in this context;

12.   the nature of any avoidance schemes you intend to implement in connection with the project, including arrangements of the kind that led to litigation in connection with the energy project at Brighouse Bay;

13.   who will be responsible for funding and managing the “non-solar” site facilities during the lifetime of the project, and in the post-decommissioning phase, for example on matters such as maintaining the physical screening, field boundaries, plant and animal habitats, and footpaths and picnic area;

14.   what financial arrangements and/or guarantees will be put in place to protect the community and the environment in the event that you default, or are otherwise unable to complete and manage the High Nunton project, or perform any of the statutory or other obligations that arise during its operation, or during or after the decommissioning phase;

15.   what net business rates are expected to be paid to Dumfries and Galloway, and what assumptions you have made in determining that figure, given that the project is not planned to generate income before 2025;

16.   who will be responsible for the grid connection, and for managing and mitigating the expected environmental impact of installing and maintaining that connection;

17.   what will happen if the grid connection is not available by 2025;

18.   what is meant by the statement that “all local electrical consumers will benefit from the sun’s low carbon energy” because of the High Nunton project;

19.   what assessment you have made of the increased carbon emissions that result from the use of energy generated at High Nunton (for example in manufacturing cars, white goods and other plant and equipment that uses project electricity);

20.   what plans exist to remove the battery storage facilities and, if appropriate, to protect the environment from any degradation of those assets;

21.   what noise will be produced by the project;

22.   what lighting will be used for the project site;

23.   the source of the data you use about solar PV projects, as the Wave 21 public attitude tracker survey that was undertaken by the Department for Business, Energy and Industrial Strategy appears to be from May 2017, while your statement is dated September 2019;

24.   the source of the maps in your information sheet “Solar irradiance in the local area”, as I have been unable to locate the data on the website referred to in the text (globalsolaratlas) , and

25.   what sites you examined to inform your statement that the local area receives the same amount of solar energy “as sites hundreds of miles further south”.

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Letter from Linda Mallett, Kirkandrews, Borgue - 17th August 2021

Dear Robert Maitland

Proposed solar farm at High Nunton

In view of the climate crisis and the need to generate ‘clean’ sustainable energy and also to cut down on rearing and eating animals, I am broadly in favour of repurposing stock-rearing land to create a solar farm and battery storage facility.

However, I am aware that the local community is going to have to bear some of the ‘costs’ of the project, particularly in the initial construction phase, and I feel strongly that the local community should also receive some of the benefits directly.

Green energy projects in countries such as Denmark have on the whole had a much more favourable public response because the local communities are directly involved in the inception, development and ownership of the projects, and are in receipt of ongoing dividends from the proceeds, whether in the form of low-cost energy or community development funds.

So it would seem that this is a wonderful opportunity to spearhead more co-operative ways of developing green energy projects with community co-operation. I would be very interested to see detailed studies of the ecologic impact of the proposed project, and how to undo some of the damage done by past agricultural practices such as removing hedges, filling in ponds and changing water courses.

Yours sincerely

Linda Mallett

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Russell Malloch's Notes from BCC Meeting on 17th August 2021 - Received and posted on 23rd August 2021

Russell Malloch made his own notes at the Borgue Community Council meeting on 17th August. You can see his document here.

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Questions from Nancy Hill after the 20th August Public Session and Answers from High Nunton Solar

From: Nancy Hill
Sent: 23 August 2021 11:06
Subject: FW: solar farm consultation meeting

Dear Prospus team

It was good to have the chance to talk with you at the Friday meeting.  I am writing to you to confirm the following points which we agreed then with you and Mr Maitland. 

  • You agreed  to make available now copies of the  Preliminary Plant and Animal environmental  studies that you have undertaken for me and  everyone to access, and  before your submission deadline so there is time so see them before commenting.
  • You agreed you  would  put on line the questions and answers you did not have time to deal with in in the webinar,   as you indicated would happen in the webinar. (Presumably this will be done next week also.   I am unsure if all the questions asked and answered were  to be put on line but this seems good idea)
  • I have one further question.  Will the present pheasant rearing nursery and feeding stations in copses around this area , and shoots in winter, continue while or after the building of the solar farm.?
  • I requested that you extend the deadline for your comments until after the next Community Council meeting so that there would more time to appraise the scheme in view of the information just received this week or to be received,  and also a chance to discuss the matter at that meeting. However you were unhappy to agree to this.

Best regards

Nancy Hill

---------------------------------------- Response from High Nunton Solar --------------------------------------------------

Dear Nancy Hill,

Thank you for your time at the drop-in-session and for your follow up email.

Responding to your points below in order.

  • Having taken advice from my planning colleague Tom Woof (who was unable to attend the drop in session due to the requirement to self-isolate), I am advised not to publish the survey data without publishing the full chapter of the environmental statement, and all the supporting documents relating to it, including the non-technical summary of the Environmental Statement. The planning guidance requires that during the pre-planning phase we make information available that is easy to understand and jargon free. The publication of the surveys on their own, and in advance of the completion of the full Ecology chapter of the Environmental Statement risks putting partial technical information into the public domain.  You will of course have the opportunity to review and comment on these surveys and the Ecology chapter of the Environmental Statement, the final design and proposed mitigation during the statutory consultation period, once the planning application has been submitted. You will also be able to address any concerns that you have with the planning authority directly. I appreciate that this is not what you were hoping for, but hope that you can understand our position.
  • The questions and answers from the Webinar and other general questions raised at the dop-in-session are now published on the project website.
  • It is difficult to anticipate what may happen in future and particularly as far out as 2025. The solar farm will not impact on this practice, and whilst Robert is considering this matter he has not yet reached a conclusion on it.
  • We acknowledge that some people would like more time to consider the proposal, however, it is also true that people want more information on the project. As we cannot start the work on the final design until we have comments back from the pre-application consultation, we cannot provide the additional information requested. The timelines for this pre application community consultation process are in line with current Scottish Government guidelines, and so we do feel that they are fair and reasonable.  We also note that the next Borgue Community Council meeting is not until the 19th October and so a delay to accommodate this would result in a significant delay.

Yours sincerely

Derek

Derek Mitchell

For and on behalf of High Nunton Solar

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 High Nunton Solar FAQ

After the public information event on 20th August 2021, High Nunton Solar have published a list of 'Frequently Asked Questions' (FAQ) on their web site. You can view the list by clicking here.

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 Email from High Nunton Solar to Russell Malloch - 26th August 2021

Dear Mr Malloch,

In response to recent correspondence relating to the proposed solar project and battery storage scheme at High Nunton Farm on questions that we have not yet responded to, including the questions raised in the letter and annex of your letter of the 4th of August.

The pre-application consultation has attracted significant interest, and preparations for the webinar and the additional drop-in-session that we were able to organise last week (following the change in Covid guidance), have unfortunately delayed our response to you. However, I’m pleased that we can now respond to all your questions from the annex of the 4th August. These are set out below.  

I note that you didn’t attend either the webinar or the drop-in-session that were held last week, which is unfortunate. The events generated a wide range of considered questions regarding the proposal from the community, with some members of the community finding it helpful to attend both, in order to ask additional questions where required. 

With regards to your email of the 6th August, I will refer back to the response from my colleague Tom Woof in his email of the 6th August. We are in the process of undertaking our statutory requirement to consult with the local community in advance of developing the final design for the project, on which the Environmental Statement and planning submission will be based.  We consider that the timescales that we have proposed for receipt of comments on the pre application community consultation are both reasonable and in line with current guidance.

With regards to your email of the 4th August. It is difficult to comment objectively to point 12 based on the level of information provided. As Robert Maitland has not been approached by Dumfries and Galloway Council with regards to any investigation into such matters, we can only assume that if a complaint was made to Dumfries and Galloway Council, that the relevant authorities concluded that it didn’t merit further investigation.  

It is not clear to us what you are seeking or suggesting in point 12 of your annex to your email of the 4th August? However, as your published comments could be interpreted as suggesting that Robert Maitland has been sued as a result of an avoidance scheme at Brighouse Bay, please set out clearly and precisely the connection that you are inferring between Robert Maitland, an avoidance scheme and the litigation that you refer?

Yours sincerely

Derek

Derek Mitchell

For and on behalf of High Nunton solar

In response to the remaining points raised in the annex, of your letter of the 4th August

Points 1 – 3. As previously stated, these will be provided when completed, as part of the planning submission in due course.

Point 4. The planning team for this project is being led by Tom Woof (BEM MRTPI), a Town and Country Planner with over 30 years of experience. The team at Prospus has consented over 100MW of renewable, energy storage, and low carbon generation in recent years, including a 39MW solar scheme at North Angle Farm in Cambridgeshire. This has included working with local authorities, statutory consultees, stakeholders and communities as part of the planning process. Beyond this, we do not consider your request for us to publish our clients’ personal data to be relevant or reasonable. 

Point 5. The need for, and benefits of renewable generation in reducing carbon emissions for energy consumers locally and nationally has been accepted by the UK and Scottish Governments and adopted as policy. This is not a point that we consider requires further evidencing during this pre application consultation.

Point 6. In estimating the likely carbon savings from the project we have relied on forecast data published by BEIS that sets out the carbon savings per unit of renewable generation, per year of operation of the project. Our assessment is based on the forecast generation of 29,736MWh in year one of the project, an annual degradation of output from the solar modules of 0.4% (in line with the industry average), and the BEIS forward emissions forecast from 2019.  However, as set out it is an estimate that reflects the current design and the BEIS forecast data from 2019, both of which may change before the final planning submission.

Point 7. Further surveys will be required pre-construction, though the nature and full extent of future surveys are not known at this stage as they will be impacted by the design which has not yet been finalised, and an Environmental Statement and Planning Submission that has not yet been developed.

Point 8. Solar PV and battery storage projects are now commonplace in the UK. It is reported in the press that some 14GW of solar PV and 1.4GW of battery storage capacity are now installed. There are now well-established UK and European safety standards and operating & safety management systems for these technologies. Prior to the site becoming operational, the site operator will be required to ensure the system is fully risk assessed and fully compliant with the law and the required safety standards covering the engineering design that is constructed.

Point 9.  It is not practical to put in place project finance for a project that is still in design development, does not have planning consent and for which the planning conditions are not known. Furthermore, the funding of any project subject to a planning application is not relevant to, or required as part of the planning application, and will in most instances remain a private and confidential matter between the funder and the developer.

Points 10 & 11. Since the removal of the Feed-in Tariff and Renewable Obligation for new build solar PV projects, solar PV projects have been constructed without UK government subsidy. It is reported in the press that some 1GW of solar PV projects have now been constructed without subsidy. With regards to your point on tax breaks, we acknowledge that this is a complex and technical area, and so we have updated the respective document on the website to remove reference to tax breaks. This update was completed on the 5th August.

Point 13, 14 & 20. Planning consents are commonly granted subject to conditions which are imposed by the local planning authority to secure additional information or compliance during the period of construction or operation.  We would expect this to be the case for this proposal too.

Point 15.  Solar PV schemes attract business rates, the extent of which are determined by the Local Authority post consent and prior to the operation of the scheme.

Point 16. The district network operator for the area will be responsible for installing and managing the grid connection, in line with their statutory obligations.

Point 17. The scheme will not be constructed until the grid is in place. Therefore, any delay to the grid will delay the construction of the scheme.

Point 18. When it starts operating the scheme is forecast to generate and export 29Million kWh of low carbon electricity into the local grid network per year, reducing the total proportion of electricity that needs to be generated from non-renewable sources to meet the needs of consumers on that network.   

Point 19.  As the project does not include for the manufacture of cars, white goods, or other plant and equipment, we have not included an assessment for the manufacture of such plant or equipment in our assessment.  

Point 20. It is normal for renewable energy planning applications to include a planning condition that requires the removal of the scheme if it does not generate electricity for a prescribed period of time. We would anticipate that this will be the case in this instance.

Pont 21. Whilst the solar panels do not produce noise, some of the electrical components will produce some noise. A noise assessment will be undertaken on the final design once the pre application community consultation process has been completed. The noise assessment will be submitted as part of the planning application and will need to demonstrate that the project complies with the required noise limits at the nearest properties. 

Point 22. We do not anticipate that any external lighting will be required.

Pont 23. The refence by the leaflet is to Wave 31 and the date of Sept2019 is correct as stated. You appear to be referring to Wave 21. However, we also note that solar PV consistently enjoys a high level of support by the general public. In latest release, Wave 37 (March 21), solar PV was supported by more than 8 out of 10 members of the public.

Point 24. The data is available at: https://globalsolaratlas.info/map The website has been updated to make it easier to find this website. 

Point 25. Using the PVGIS-CMSAF database, published by the European Commission, the yearly in-plane irradiation for the site is forecast to be 1,357 (kWh/m2). This compares to a figure of 1,195 (KWh/m2) for the Hereford or 1,215.36 (KWh/m2) for Banbury.

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 Response from Russell Malloch to High Nunton Solar - 27th August 2021

Dear Mr Mitchell

Thank you for your email of 26 August 2021.

I regret that we seem to be far apart in terms of engaging in a meaningful pre-consultation process, as your client has provided generic responses, rather than precise answers, to most of my questions about this large and complex proposal.

I am sure you will appreciate that such generic responses, about what we know to be classified for planning purposes as a major development, provides no more information than I could have obtained from “the man on the Clapham Omnibus”.

I am also surprised, given the content of my emails of 4, 6 and 14 August, that you thought I would have benefitted from attending your client’s webinar or drop-in session, without access to any of the information I had previously requested.

You have referred me to your colleague’s email of 6 August, but you must know from our earlier correspondence that the evidence leads firmly in the opposite direction of the destination you suggest, in terms of your client's compliance with the PAC.

You then raise two specific points.

The first relates to a letter of 14 October 2019 which, as I explained in my email of 4 August 2021, dealt with a matter that fell outside the scope of your current High Nunton website. I take from what you have written that your client currently knows nothing about that letter.

As for point 12 of my email of 4 August 2021, this was a simple request (linked to questions 9 to 11, and 13 to 15) for information about the financial viability of the proposal, which is always likely to be a material consideration in the context of a major development.

It is therefore impossible to interpret point 12, viewed from even the most oblique angle, as suggesting that your client “was sued as a result of an avoidance scheme at Brighouse Bay”.

Brighouse involved an appeal about tax matters to the House of Lords, whose decision would show quite clearly that Robert Maitland had no interest in that scheme. A Google search under “Brighouse Bay avoidance” (for example) would have quickly led you to the relevant decision.

A more helpful, and perhaps less dramatic, response to point 12 would have been for your client to have replied “None”.

As for his responses to my other questions I have analysed them in the table below, except for (a) points 11 and 12, which I dealt with above, and (b) those matters (points 11, 18, and 23 to 25) where your client has done no more than (i) define terms, or (ii) clarified his sources (for example, at point 23, where you have perhaps overlooked that Wave 21 rather than 31 appeared on the High Nunton website).

This analysis shows that, in relation to the substantive questions about this major development, the overwhelming balance rests with (a) generic statements, rather than (b) precise answers.

It is plain that this outcome would reinforce the view of any impartial observer that Robert Maitland is unwilling to properly enter into the PAC process, where the threshold for community engagement is much more demanding of your client, for the simple reason that we are dealing with a major development, rather than a few solar panels on a farm building.

Yours sincerely

Russell Malloch

Question

Subject

Answer

1

Draft application

No

2

Data

No

3

Biodiversity

No

4

Other projects

No

5

Emissions

No

6

Project emissions

No

7

Survey work

No

8

Risks

No

9

Finance

No

12

Avoidance

No

13

Non solar facilities

No

14

Default

No

15

Rates

No

16

Grid

No

17

Connectivity

Yes

19

Emission increase

No

20

Plant removal

No

21

Noise

No

22

Lighting

Yes

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 Feedback from Nancy Hill following a visit to the proposed site

Suggestions for High Nunton Solar farm

Essential for ecology gain

1.Buffer strip of wide mixed hedges with berries around panel fields as essential part of screening and wherever else possible. Using one variety of sycamore trees only for screening and no hedges as suggested by Mr Maitland gives hardly any ecological gain.

2. Mixed deciduous, berried e.g. rowan, and some evergreen species of tree as essential part of screening.. Scots Pine, Holly .. any good ecologist or Woodland Trust can advise.  This should be implemented by the project  rather than volunteers.

3. Beetle banks and scrub are advised by ecologists

4. Wetland bog area is very minimal and could be larger.  There is an adjacent small wet area east over the next rise.. could this be included to make a slightly larger sized reserve?  It should be hedge fenced rather than just cattle fenced

5.Undertaking not to use herbicides , pesticides on fungicides or chemical glass cleaners to maintain the undergrowth around panels, in solar farm area and nearby in order to protect plants,insects, animals and water quality… in Millhall Burn and Doune.  Can the sites be managed organically.?  Bees and insects like to nest underneath  panels.

6. Pheasant rearing and shooting on adjacent parts of the farm are incompatible with ecological gain.  (Pheasants eat all available caterpillars and could not be kept out of the sites.)  Can this cease once solar farm build begins.?

7. Wildlife corridors Woodland and wide mixed hedges to create wildlife corridors.

possibly

a.  alongside existing Doune to High Nunton path and linking to ecologically sound screening  around panels.

b.  Along north field side of Millhall Burn which flows through Cooper  Croft.  This could link directly to ecological screening around panels by planting along the burn field edge below Lower Nunton.  (around 100 metres )

c. Planting in fields across road from the marsh are below the south side of Senwick wood , leading to a path or corridor in the field nearer to Brighouse turn off.

All these options link into Senwick wood.

Other issues

8.Footpath.  If all panel fields are to be separately fenced as Mr Maitland confirmed,  a  path could go between them taking several routes as access tracks will be needed to maintain panels.

These could link with the Doune path ….. either to Glentruil, or near Culraven, or  via the field opposite Brighouse Bay turn off, or preferably Borgue if this can be arranged ..with another farmer.?  Wide mixed hedges along the path screening the panels close up  would  be important for the view and excellent for nature.  See photos below of close up impact. 

solar_photo_1.jpgsolar photo 2solar photo 3solat photo 5

9. Clearly minimising of ugly signage is important. (see photo below).

solar photo 4

10. Drainage.  There is an recent issue at the moment with the poor water quality at Dhoon beach. There is an investigation  by SEPA of the poor water quality from run off from Mill Hall burn and Corrafore burn from farming and human waste.  The drainage from the solar farm feeds directly into Mill Hall burn. Can the project ensure that any concentrated run off from the sloping panels will be contained not by drainage measures but by good positioning and (scrub?) planting in front of panel fields and along the stream banks.  This is to prevent sudden run offs into Millhall or other burns. Sudden run off can damage water quality with mud, chemicals etc and cause  potential damage. ((This  affects Cooper Croft  also as the lower watergate was broken down by flooding last winter).

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Combined feedback from site visits

After the public information sessions that were held in the Borgue Hotel marquee on 20th August 2021, people that had attended the session were invited to tour the proposed site with Robert Maitland to ask further questions and make suggestions about the provision of visitor facilities. Here is the summary of questions and suggestions that were generated after the visit:

Footpaths and Visitor Amenities

  • Footpath.  If all panel fields are to be separately fenced as Mr Maitland confirmed,  a  path could go between them taking several routes as access tracks will be needed to maintain panels. These could link with the Doune path ….. either to Glentruil, or near Culraven, or  via the field opposite Brighouse Bay turn off, or preferably Borgue if this can be arranged ..with another farmer.?  Wide mixed hedges along the path screening the panels close up  would  be important for the view and excellent for nature.  See photos below of close up impact. 

solar photo 1

solar photo 2

solar photo 3

solat photo 5

  • Have a footpath that could connect with further development across to Borgue village, enabling access between Borgue and Dhoon Bay without having to walk along the roads.
  • Have a loop footpath rather than a single in/out route.
  • Have benches along the footpath route rather than or in addition to the proposed picnic area.
  • Provide off-lead dog walking by growing a hedge corridor between the animals and the walkers to provide shelter for wild life and a safe area for dog walkers? Trees could be sourced from the Woodland Trust to plant in areas that are available for community woods.
  • Provide access to historical sites within the solar farm area (Old Castle/Witches Thorn)
  • Part of the area of the proposed solar farm falls within the Solway Coast Regional Scenic Area (shown in green below). Are the aims of a large-scale renewable energy project compatible with this designation?

https://www.dumgal.gov.uk/media/19851/Regional-Scenic-Areas-technical-paper/pdf/Regional_Scenic_Areas_Technical_Paper.pdf

ScenicArea

  • The site is generally well screened due to the local topography and some existing woodland, with the most prominent views of the area being from the Cairniehill area, and of course from Blackcraig.
  • Provide information panels so people understand how the site works and why it is important – it would be great to have a live power output display
  • Electric car charging point at the car park for the walk or other local locations around Borgue.

Ecological Gain

  • The site is typical Borgue landscape with rocky knowes and hollows. Its current ecological value on the main pastures is pretty low with a rotation of beet, reseeded pasture and heavy grazing so this project could represent an opportunity to improve the ecological value of the site.
  • Mossmaul should be protected from any aspect of the development, it has complex acid hummocks and nutrient rich channels between.  The proposed footpath past this wet area should avoid it and the proposed wetland area in the Mossmaul field should not interfere with the water regime of Mossmaul itself.  Perhaps the new wetland area could be modelled along the lines of the Wee Drum, which is also an interesting site in itself,  just around High Nunton.
  • Create a new wetland area in the Moss Maul field to improve species habitat and biodiversity, preferably with an area of open water.
  • Create a woodland connection from the Millhall/Senwick Woods area towards Borgue with the aim of eventually connecting together more woodlands through the Borgue area. Could be part of a ‘community woodland’ scheme for Borgue
  • Buffer strip of wide mixed hedges with berries around panel fields as essential part of screening and wherever else possible. Using one variety of sycamore trees only for screening and no hedges as suggested by Mr Maitland gives hardly any ecological gain.
  • Mixed deciduous, berried e.g. rowan, and some evergreen species of tree as essential part of screening.. Scots Pine, Holly .. any good ecologist or Woodland Trust can advise.  This should be implemented by the project  rather than volunteers.
  • Beetle banks and scrub are advised by ecologists
  • Wetland bog area is very minimal and could be larger.  There is an adjacent small wet area east over the next rise.. could this be included to make a slightly larger sized reserve?  It should be hedge fenced rather than just cattle fenced
  • Undertaking not to use herbicides , pesticides on fungicides or chemical glass cleaners to maintain the undergrowth around panels, in solar farm area and nearby in order to protect plants,insects, animals and water quality… in Millhall Burn and Doune.  Can the sites be managed organically.?  Bees and insects like to nest underneath  panels.
  • Pheasant rearing and shooting on adjacent parts of the farm are incompatible with ecological gain.  (Pheasants eat all available caterpillars and could not be kept out of the sites.)  Can this cease once solar farm build begins.?
  • Wildlife corridors Woodland and wide mixed hedges to create wildlife corridors.
    • Alongside existing Doune to High Nunton path and linking to ecologically sound screening  around panels.
    • Along north field side of Millhall Burn which flows through Cooper  Croft.  This could link directly to ecological screening around panels by planting along the burn field edge below Lower Nunton.  (around 100 metres )
    • Planting in fields across road from the marsh are below the south side of Senwick wood , leading to a path or corridor in the field nearer to Brighouse turn off.
    • All these options link into Senwick Wood.

Other Questions and Concerns:

  • What will be used to clean the panels? Hopefully some environmentally-friendly solution.
  • Drainage.  There is an issue at the moment with the poor water quality at Dhoon beach. There is an investigation  by SEPA of the poor water quality from run off from Mill Hall burn and Corraford burn from farming and human waste.  The drainage from the solar farm feeds directly into Mill Hall burn. Can the project ensure that any concentrated run off from the sloping panels will be contained not by drainage measures but by good positioning and (scrub?) planting in front of panel fields and along the stream banks.  This is to prevent sudden run offs into Millhall or other burns. Sudden run off can damage water quality with mud, chemicals etc and cause potential damage.
  • Minimising of ugly signage is important. See example below from an existing solar farm

 solar photo 4

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 Letter from Nancy Hill to Prospus Consulting - 2nd September 2021

To Prospus Group

From Nancy Hill, Cooper Croft, Borgue DG6 4 TN

Thank you for the help and information you have provided so far. Now that I have been formally included as a residential adjacent neighbour with possible visual and other effects, I would like to contribute the following points with regard to my house and garden at Cooper Croft.

1.Noise.  The timetable given indicates that construction of the solar  farm will with take place for 9 months up to 2025. Can I have an assurance that there will be not extra noise from working in the area in the interim period, except for tree and hedge planting?  I ask this because there has been considerable noise in the area over this summer with tractors  and diggers.

2. Screening. I am happy that Mr Maitland has offered to provide any screening I request and I will discuss this with him and whether it is needed once winter views are present.

3. Access for me behind my house.   If planting all along the burn course takes place it would be good if I could still retain pedestrian access through the burn into the fields below Lower Nunton to complete a round walk there.

4. Hydrology.    I note the question and answer in your webinar on rainwater run off from the panels, and the need for assessment and mitigation.   I have not been able to see the hydrology report or establish when it was written but clearly this is of prime interest to me downstream of the site.   The  Millhall Burn taking the drainage from the area of the site runs through my property for over 100 metres with a watergate at either end.  Any changes to the drainage systems such as increased water flow may affect me.  Can I have an assurance that any significant changes and any resulting damage are your responsibility.  Instances might be increased flow damaging watergates, fencing or trees , silting or herbicide pollution from the site works and operation.

Early this year I had a large bill to install a new watergate at the lower end of the stream after winter flooding brought down the wall and fencing. The burn area has been reasonably stable for 30 years until now.  It is unclear how much of the flooding was due to weather and how much was aided by the clearing in autumn 2020 of the deciduous trees on the stream bank in the nearby conifer wood,  and the digging deeper of the burn there and just above my property with a mini digger.  But clearly it is of concern to me that severe flooding is not in any way increased by further operations.  As I have been told current site operations this summer are to do with drainage, I trust this work will not have increased the run off.  Of course I hope the planned extra planting and mitigation measures will indeed reduce the flow and I trust you will be confident enough I will not be affected to offer me redress should any damage unfortunately occur.

Thank you for your time

Nancy Hill

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 Email from Russell Malloch about the High Nunton discussions at the 19th October Community Council meeting

I have read the draft minutes from the Borgue Community Council [BCC] meeting that was held on 16 October 2021, and regret that they do not provide an accurate record of the discussion that took place in connection with the High Nunton planning application.

It was disappointing that some members of the BCC referred to an alleged misunderstanding about what was agreed on 17 August. That is especially so, given my email to you on 11 September 2021, when I wrote “I would be grateful if you could take this matter up with the High Nunton team on my behalf, in line with the commitment that was given at the public meeting on 17 August … Please do not hesitate to contact me if you require any clarification in terms of the outstanding information, or if you think that I can help in any other way.”

You replied on 19 September, when you said that you had “received several communications this week regarding the High Nunton development and the Community Council is working to collate that information in order to take it forward.” Our emails were then entirely disregarded by certain members of BCC, and neither you or Carol Ryall (who was good enough to make the original offer to help) spoke on 16 October to explain what had actually happened.

I have seen the email Syd Davison sent you on 20 November about the draft minutes, and agree that he has provided an accurate account of what was discussed. 

My views on this matter are shared by many of the members of the community who contacted Robert Maitland and/or were present at the BCC meetings on 17 August and/or 16 October, including Colin Clarkson, Dave Hitchcocks, Heidi Hitchcocks, Jo Clarkson, Martin Thomson and Michelle Thomson.

Our concern is that certain members of the BCC are not trying to ascertain the views of the community, and are not laying aside their personal opinions or preferences, which has the effect of reducing the community’s trust and confidence in the integrity of the BCC in representing the views of the local area.

This conclusion is supported by the content of the draft minutes, including the chair’s statement that there was “ample opportunity after last Borgue CC council to find out more about the proposal” and “lots of information put out on the Borgue Community Council Website, lots of opportunity for Borgue Community to access this information.” These were no more than the chair’s personal opinions, rather than the views of the community as expressed at the last two public meetings.

I would therefore ask that the BCC puts mechanisms in place to ascertain the views of the whole of the Borgue community, rather than conveying the personal opinions of the chair, which are likely to align with those of the property developer.

Yours sincerely

Russell

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Update from Nancy Hill about her letter of 2nd September and response from High Nunton Solar 

From Nancy Hill to High Nunton Solar:

After receiving no reply to my letter of 2nd September (see Community Website) I resent my letter  to Prospus and received this reply  from Prospus on 12 th November when they asked for a site visit.

As well as asking for higher ecological commitments, hedgerows etc ,  I asked the project to take responsibility for any increased flooding or damage arising from  run off  into the Milhall Burn which runs through my property. I also again requested they send me any  initial hydrology reports undertaken at the start of the project  before the drainage work on the burn and fields above my house was done last October and this year.  Their reply below is to say I will see hydrology reports when the assessment is published later.  I enclose the letter.

I was told by the landscape architect that a local forestry expert is being employed to advise on ecology and planting.

From High Nunton Solar to Nancy Hill:

Dear Nancy,

Many thanks for your very constructive comments. I’ll ensure that these are passed onto the ecology team developing the aspects of the project relating to habitat and biodiversity enhancement.

I certainly hope that the project will be able to accommodate many of these, though must caution that grazing land within the array will need to be managed as agricultural land. However, as you will recall from our previous discussions, the project will enable Robert to take a significant area land out of agricultural management. This will include the development of both planting corridors and areas of wetland enhancement, which will offer benefits to wildflowers and insects.

(The hydrology assessment is currently being undertaken and will form part of the Environmental Statement, which will be submitted as part of the planning submission. )

Yours sincerely

Derek Mitchell

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 Proposed Changes to Core Path 195 through High Nunton Solar site

As part of the community consultation for High Nunton Solar and the subsequent site visit organised by John Shields, the solar project agreed to review the location and start point of the proposed solar farm walk. As part of those discussions it was agreed a loop that could be accessed from the existing core path and its parking would be preferable to the route proposed in the pre application consultation for the proposed solar farm.  The process and subsequent discussions also opened up the opportunity to improve the existing core path (Path 195), by amending its route slightly to the east of where it currently runs.

Subsequent discussions with Richard Masters (Countryside Access Officer at Dumfries & Galloway Council) have indicated that the Council would be open to this change, subject to consultation.

I am emailing you today to let you know that Richard Masters will be in contact with the Community Council shortly to consult with the Community Council.

I have attached a plan of the existing and proposed routes for your reference. Unfortunately the OS map has not been updated to reflect historic changes to field boundaries.

CorePath195

The new route will reduce the impact of the existing path route on livestock as it largely follows the field boundaries and for the same reasons will be easier for members of the public to follow.  The maps also suggests that the proposed route crosses an area that could be water logged, but this is no longer the case.

Please let me know if you would like any more information from us with regards to this proposed route change?

Yours sincerely

Derek Mitchell

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 High Nunton Solar Farm Update - 6th December 2021

The following document has been received from the High Nunton Solar project and requested that it be shared with the Borgue Community:

6th December 2021

Dear Members of the Borgue Community,

Re: High Nunton Solar project update, December 2021

We would like to take this opportunity to provide a brief update on the proposed solar farm at High Nunton.

Our original plans of submitting the planning application in November have been delayed in order to allow the landscape architect to collect winter views of the site as part of their assessment, following the request for winter views to be accounted for during the community consultation.  Following a mild autumn, the landscape architect has now managed to undertake the winter view assessment and we are finalising the application ready for submission shortly.

We would like to take this opportunity ahead of submitting the planning application to thank you for all your responses during the community consultation process. Your questions and challenges have focused effort within the team to deliver a better proposal.  As a result of the community consultation, the design team have made significant amendments to the proposed design. These changes include: reducing the number of panels by over 6,000; reducing the footprint of the area covered by solar panels by over 3 hectares; removing panels from some of the most prominent locations within the site, and replacing those panels with enhanced screen planting to further break up the site.

Following the site visits and the suggested ecological enhancements, the design team have introduced a number of additional measures including: additional wildlife corridors across the site; beetle banks; and the introduction of an expanded selection of native woodland tree and scrub species. In partnership with the local community we will also develop a management plan for the wetland area of Mossmaul, to conserve and enhance this wetland area.

In line with feedback received on the footpath, we have moved the footpath to create a loop that is accessed from the existing core path and parking area. The footpath will include a seating area and will avoid the ecologically sensitive area of Mossmaul.

In response to recent community council meetings where additions to the minutes and other correspondence indicate that the team has not answered all the questions put to them as part of the community consultation, we would assert that we have responded to the questions put to us, and our responses are set out on the Community Council website. Whilst we recognise that some may not feel that these responses are sufficient, we have sought to address those questions that we can, and to provide reasons where we can’t or haven’t.  For the benefit of the broader community who may not have had the opportunity to read all the correspondence relating to the project on the Community Council website, we have summarised our position below.

As required under planning legislation relating to pre-application consultations, a project design should not be fixed at the pre application consultation stage, but instead should be open to change to accommodate feedback received during the consultation phase. Any change to the design will therefore have implications on all assessments relating to that design, which is one reason why planning legislation doesn’t require the presentation of the full planning application and all supporting information at the pre application consultation stage. The appropriate place to do this is as part of the planning submission itself.

We would also highlight that a number of the questions that we have been asked to respond to stray beyond what is required within the planning submission. To provide further context of this, we have set out below examples of some of the questions we would place in this category.  

  • We have been asked to provide the evidence of the extent to which the electricity generated by the project will help to reduce the carbon dioxide emissions produced in providing electricity to the area. However, the NetZero target, the legislative renewable generation targets that underpin NetZero, and national planning policy already recognise the benefits of renewable generation in reducing carbon dioxide emissions. This is so that each proposal for renewable energy does not have to justify itself in terms of carbon dioxide emissions. 
  • We have been asked to set out what assessment we’ve made of the increased carbon emissions that will result from the use of energy generated at High Nunton being used to manufacture cars, white goods and other plant and equipment that use electricity generated by the project. However, the project does not propose to manufacture cars, white goods or other plant and equipment. This proposal seeks consent only for the generation of renewable energy, it does not seek to explain how that energy will be used.
  • We have been asked to state what business rates will be paid as a result of the project. Whilst it is a matter of law that solar farms pay business rates, which will benefit the local authority and therefore support the provision of council services in Dumfries and Galloway, it is for the local authority to determine what those rates are according to legislation at the time the project starts operating. That figure will be subject to the legislation in force at the time.
  • We have been asked to set out the financial and funding structure of the project. However, the funding of any project subject to a planning application is not relevant to, or required as part of the considerations of the planning application. Planning applications should be considered only on their planning merits.

Therefore, we believe we have answered all reasonable questions adequately.  We are happy to answer any further reasonable questions, although our priority is to complete the submission documents so that the full proposal is available for all to comment upon.

We would also like to question a couple of other recent statements that have been recorded on the Community Council website that could be misleading.

  • The community drop-in-session held at the Borgue Hotel on the 20th August was open to all people to drop-in and find out more about the project at a time that suited them, and during the course of the afternoon people attended individually and in groups, at their choice. The one-to-one events that were offered on the website were entirely separate to drop-in session and were available for people to request if they wanted to.
  • It has also been suggested that the project ‘was a development of the size of Kirkcudbright’. However, the footprint of the developed area of Kirkcudbright, accounting for the settlements both sides of the river, equates to approximately 130ha, whereas the area within the security fences of the proposed solar farm equates to approximately 45ha. We would also note that the 45ha includes significant grassland within and around the panels themselves, ensuring that the majority of this 45ha will remain grassland and will continue to be grazed by sheep.

We continue to believe that the planning benefits offered by this project and the mitigation proposed, including the low carbon electricity generated, the significant biodiversity enhancement supported through woodland and scrubland planting, the preservation and enhancement of the wetland area of Mossmaul, and the employment supported, will represent a positive outcome in combatting the climate emergency and provide significant benefits directly to the local environment. 

Yours faithfully

Derek Mitchell

For and on behalf of High Nunton Solar Ltd