In response to the planning application MO/2024/1544 proposing the installation of a Battery Energy Storage System (BESS) facility, underground cabling, access track, landscaping, biodiversity enhancement and ancillary infrastructure and equipment, security fence and gates at Land North West of Barnett Wood Lane, Ashtead, Surrey, KT21 2BU, the City of London Corporation as Trustees of Ashtead Common (a National Nature Reserve and part of the Epsom and Ashtead Commons Site of Special Scientific Interest) have lodged the objection below with Mole valley District Council.
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Mr Aidan Gardner
Planning Officer
Mole Valley District Council
Pippbrook
Dorking
Surrey
RH4 1SJ
Dear Aidan,
Application number MO/2024/1544 – INSTALLATION OF A BATTERY ENERGY STORAGE SYSTEM.
I am writing on behalf of the City of London Corporation to OBJECT to the above mentioned application.
The proposed development is located next to the Epsom and Ashtead Commons Site of Special Scientific Interest (SSSI). Although not immediately adjacent to Ashtead Common National Nature Reserve (owned and managed by the City of London Corporation), our organisation has a clear interest in matters affecting the whole SSSI. A detrimental impact on any part of the SSSI will inevitably adversely affect the area under the City Corporation’s careful stewardship.
I wrote to Mole Valley District Council (MVDC) in February 2023 to express concern that the pre application screening decision not to require an Environmental Impact Assessment in relation to this development was incorrect (see application document PA05 2226-R003). MVDC had correctly identified that the proposed development would constitute a Schedule 2 development under the Town and Country Planning Regulations 2017, but in failing to consider the impact of the development on areas beyond its immediate footprint, MVDC had ignored government guidelines that state:
‘In practice, the likely environmental effects of Schedule 2 development will often be such as to require an Environmental Impact Assessment if development is to be located in or close to sensitive sites.’
Part 1(b) of Section 3 of the 2017 Regulations calls for consideration of the ‘cumulation with other existing development.’ MVDC’s reference to another electricity sub-station a considerable distance away is erroneous, since this criterion does not restrict itself solely to similar development. The proximity of the existing mobile phone installation, A243 and M25 all cumulatively contribute to the potential harm the proposed development could cause, specifically in relation to light, air and noise pollution, as well as the considerable fragmentation of wildlife habitat already found in this area. Indeed, the letter even goes on to acknowledge the issue of noise pollution emanating from the A243 in relation to criteria 1(e), offered almost in mitigation of the development.
Of more concern is the consideration given in relation to part 2 of Schedule 3 ‘Location of development.’ The Regulations state:
‘The environmental sensitivity of geographical areas likely to be affected by development must be considered…’
The land in question is not in active agricultural use (see letter PA05 2226-R003), it has effectively transitioned from farmland to wildlife habitat and is an established and effective buffer for the SSSI. This area is now an important feeding and foraging ground for species resident in the Epsom and Ashtead Commons SSSI and is of particular significance for the numerous bat species known to be present.
Bats
Ashtead Common is of high importance for bats with at least 10 species, including species red listed as Vulnerable or Near Threatened on IUCN database, such as Myotis bechsteinii and Barbastella barbastellus.
It is well documented that anthropogenic influence has a harmful impact on bat activity. Light pollution displaces bats from their foraging areas and alters bats activity pattern. On a landscape scale it has a negative impact on all bat activity. However, it has a significantly negative impact on “clutter species”. A clutter species is described as low flying and foraging in dense vegetation (Pouwels et al., 2021). Those species (such as Myotis nattereri, Myotis daubentonii, Myotis mystacinus) are more specialist and therefore less common and have been recorded in abundance on Ashtead Common.
Noise pollution demonstrated a significant negative impact on bats (Myotis ssp) and additionally for Pipistrellus pipistrellus and Pipistrellus pygmaeus feeding behaviour was negatively impacted as well as overall activity (Finch et al., 2020). Both Pipistrellus species are widely present on Ashtead Common.
Modification of the landscape by adding artificial structures, habitat changes, fragmentation and alteration have harmful impacts on biodiversity (Trombulak and Frissell, 2000). Moreover, the harmful impacts of the changes and traffic depends highly on surrounding habitats with more open habitats such as agricultural fields and meadows being impacted >500 m from the source and woodlands being impacted approx. 300m (Medinas et al., 2019).
Woodland edge and less specialist species like Plecotus auratus, Nyctalus noctule and Eptesicus serotinus often forage along field margins, using natural linear features as routes from roosts to foraging grounds. The distance travelled varies between species, with some travelling up to 10km to foraging grounds. Such species regularly changes roosts, every four days or so, due to mite presence. Therefore, it is crucial that within the landscape a high number of suitable roosting, foraging, and commuting routes is sustained and provided.
In summary, the loss and fragmentation of grassland habitat, and the combination of light, noise and dust pollution associated with the construction and operation of this development immediately adjacent to a nationally important SSSI will have harmful impacts on an important bat population.
Fire
Ashtead Common National Nature Reserve is home to 1,100 ancient oak pollards and has recently been ranked joint fourth in the country on the Index of Ecological Continuity – alongside Richmond Park and in the company of such notable areas as The New Forest, Windsor Great Park and the Blenheim Estate. Places like these are home to a collection of species that evidence undisturbed provision of habitat over centuries, even millennia. Put simply, the ancient oak pollards and associated habitats of Ashtead Common are of at least national significance and knocking on the door of significance at an international level (Richmond Park, for example, has the international designation of Special Area of Conservation).
Fire presents the greatest risk to the ancient trees of Ashtead Common. Past fires which killed or damaged many ancient oak pollards were viewed by such national conservation authorities as George Peterken, Oliver Rackham and Keith Kirby as nationally significant biodiversity incidents.
Battery Energy Storage Systems are known to present a fire risk. Were it to go ahead, this facility would be located at the extreme South-Western corner of the Epsom and Ashtead SSSI; the worst possible location in relation to the prevailing wind.
It is unclear how the provision of a water tank (as proposed) will be sufficient in tackling the thermal runaway associated with lithium-ion battery fires.
Opportunity cost
The Environment Act 2021 introduced a strengthened ‘biodiversity duty’ where public authorities in England must consider what they can do to conserve and enhance biodiversity. Surrey County Council is leading on the production of a Local Nature Recovery Strategy for Surrey which is due for completion in 2025. Underpinning the thinking is the Lawton Report’s (2010) thesis of ‘bigger, better and more joined up’ and the need to confront the environmental threats arising from climate change.
The UK is one of the most nature depleted countries in the world. 15% of species in the UK are now threatened with extinction (UK State of Nature Report 2019). 11.5% of species native to Surrey are now locally extinct (Surrey State of Nature Report 2017). The City of London Corporation invests considerable resource into maintaining the biodiversity of Ashtead Common. The proposed construction of a battery energy storage facility, with its recognised harmful impacts, immediately adject to a SSSI and on land currently in a naturalised and environmental buffering condition will harm existing protected species in that area. It will also prevent any opportunity for future buffering of this nationally
important habitat in that area in perpetuity.
Biodiversity Net Gain (BNG)
Using the BNG metric, this development proffers a 20% enhancement in biodiversity by incorporating the wider field. It must be noted that BNG assessments do not consider individual species, nor do they look beyond the red line of the proposed development area.
As previously mentioned, the field subject to this proposal has not been actively farmed for some time and is naturally transitioning into wildlife habitat. If managed optimally, a conservation mowing or grazing regime would be introduced to encourage species-rich grassland. However, even if left unmanaged, the area will continue its natural transition to become scrub habitat and ultimately woodland.
The proposed introduction of seed to artificially short circuit the natural transition towards greater species diversity is regarded as sub-optimal practice (refer, for example, to ‘Developing with Nature Guidance’ (2022) Nature Scotland) when working adjacent to wildlife sites. It discourages natural colonisation by those species and genomes already present or dormant in the local environment and that are best adapted to be there.
The area proposed both for development and BNG ‘improvements’ is already providing beneficial appropriate habitat and will naturally continue to do so over time.
BNG has great potential benefit to promote biodiversity recovery, however, it must be used appropriately and not, as in this case, appear to being used to make an inappropriate development appear attractive.
Conclusion
In conclusion I consider that this development will have a significantly harmful impact on nationally important species and habitats.
As such there is no overriding argument to allow it to be located at this place within the greenbelt.
Yours sincerely
.
Benjamin Murphy CC
Chairman – Epping Forest and Commons Committee
Copy to:
Councillor Margaret Cooksey – Cabinet Member for Planning
Councillor Claire Malcomson – Cabinet Member for Climate Change and Wellbeing
Mr. Geoff Sinclair, Superintendent of the Commons, City of London Corporation