On the 21st October 2015, Fordmouth Renewables Limited lodged a planning application with South Lanarkshire Council for the installation of a solar farm and associated hydrogen production and storage facility, south of Dippool Farmhouse Carnwath, consisting of 20,000 solar panels across an area of 20 hectares (50 acres).
As a lifelong environmentalist and supporter of renewable energy initiatives, I must admit I was quite excited when I first heard about this proposal. I was aware of some grumblings from neighbours who would be directly affected, and living less than a mile away from the proposed site myself, I wondered whether concerns were more about the potential drop in house prices than anything else.
Solar energy – mmm… yes we all want a bit of that don’t we? Is this a proposal for a community owned, locally generated electricity source? Is there evidence that the developer understands and can manage the project risks involved – and do they have a credible track record? Is it situated in an area which has good roads and infrastructure? Is the hydrogen being produced close to where it will be used? Will it have minimal ecological, landscape and visual impact? Regrettably, the answer is ‘no’ to all of the above and the proposal is problematic for at least four reasons.
1. The lack of community consultation
The proposal concerns ground right at the border of Carnwath and Tarbrax Community Councils and yet the initial planning application was only vaguely described as ‘Hydrogen Plant – Carnwath’, with no attempt made to consult with either Community Council prior to the planning application being lodged. A formal consultation event was only held under council recommendation, who also suggested community benefit should be considered, but no offer of support for the local population has been forthcoming.
2. The project serves no local need and has no community benefit
The installation is not intended for electricity generation for general use but would be used to power a chemical plant producing hydrogen gas through the process of electrolysis. The gas would then be driven out in multiple loads by diesel-fuelled tanker on narrow, un-gritted roads, over a small bridge with poor sightlines, to an unspecified location, possibly as far as Aberdeen - thus negatively offsetting potential carbon savings. Although this is a renewable energy source and has interesting potential, it would not contribute to the Scottish Government’s Renewable Energy Targets for electricity, heat or transport. As well as exacerbating poor road infrastructure locally, it would use an average 13,500 litres of water per day, (nearly double that in summer with longer sunlight hours) putting further pressure on the water supply from Throughburn. For the community, the scheme delivers no tangible local benefit, it will not create any new jobs or bring in any new income (except for the landowner who lives outwith the area).
There is also the nagging question of exactly how much solar energy is needed to run a hydrogen factory to get a commercial return, especially in the location of Dippool - which is not known for its year-long sunny aspect! Surely a solar energy capacity assessment, similar to using wind vanes to assess the viability of wind farm installations, should be undertaken before the people living and working in the area are overwhelmed by the view of 20,000 industrial solar panels, glare (when the sun does shine) and 2.4m high security fencing? Although commercial viability is not a planning consideration, if the forecast yield of 160 tonnes of Hydrogen per annum is not met, will the project just be abandoned leaving further disarray?
3. The potential environmental impact
The proposed site is located within a flood plain, which has flooded 4 times in the last 6 weeks. Again, this should ring alarm bells, especially when SEPA have objected to the proposal on the grounds of ‘flood risk contrary to Scottish Planning Policy and on the grounds of lack of information in respect of disturbance and reuse of excavated peat’.
Westwater reservoir is a designated Special Protection Area (SPA) for Greenland/Iceland Pink-footed Goose (Anser brachyrhynchus), which winters almost exclusively in Britain and has an amber UK status for ‘Birds of Conservation Concern’. There are identified feeding sites east of West Linton and south west of Biggar and it is locally known that the proposed site is common foraging for the geese. Yet, hitherto, the formal feeding field surveys have not covered the Dippool Valley to ascertain its importance, although the RSPB, Scottish Ornithologists Club, Wildfowl and Wetland Trust and Scottish National Heritage (SNH) all suggest that it would be a good idea. Notwithstanding this, SNH have now advised that no significant effect on any qualifying interests pertaining to the SPA, or the designated Moss Sites of Special Scientific Interest (SSSI) located within 2km of the application site, are sustained and that no further ecological surveys beyond a desk study and a single site visit are required. They do, however, advise that mitigation measures are implemented to prevent death or injury to otters and badgers and that - bizarrely for a conservation agency - ‘suitable measures should be put in place to deter the geese from feeding within the site prior to construction’. In contrast, the RSPB have declared that they do think there is a risk of cumulative impact on the roost at Westwater SPA and have recommended off-site habitat management for the geese as part of the planning conditions, if consent were to be granted. This highlights the often confusing and contradictory advice given to Planning Officers who are relying on expert guidance to help them make decisions.
The proposed site flooded this year, courtesy of Kirsten Harris.
4. The risks of an industrial hydrogen production plant
Industrial hydrogen production has tended to be carried out within large refinery and chemical facilities which have built up safety protocols. Early hydrogen projects have tended to be for fuel cell and hydrogen fuelling of vehicles and involve 10s of kilos of hydrogen. The proposed plant seeks to produce 160 tonnes per annum, and store up to 20 tonnes on site. There is little experience either in the UK or Europe of this new technology at the scale proposed, and apparently little or no knowledge amongst developers and planners of the processes and risks involved. Crucially, this proposal is being treated as an electrical solar farm development rather than an integrated plant producing hydrogen gas on an industrial scale, and thus should be treated as a Schedule 1 activity for which an Environmental Impact Assessment is mandatory. If this was the case, at least the correct regulatory bodies would be able to risk assess the proposal appropriately.
So where does this leave the small community surrounding Dippool who are energetically objecting to this proposal? These folk are not your stereotypical NIMBYs, they comprise at least three renewable energy experts and engineers, as well as everyday families and households who care about the place they live in. Indeed, the most positive benefit from this proposal has been the way it has galvanised neighbours to meet together on cold winter nights to form a strong challenge against a substantial environmental and hazardous impact with no community benefit and only private gain. The campaign is well coordinated and different members are contributing their expertise in a number of ways. But, as always, they’re running against the clock - in spite of their knowledge and independent reports, a decision may go against them and then, with no equal rights of appeal, they only have the option of an expensive and prohibitive judicial review, something which the charity Planning Democracy is vigorously trying to address (http://www.planningdemocracy.org.uk/).
Yes we do desperately need speculative entrepreneurship to push the boundaries of current renewable energy options, and we need receptive communities to support them, even if there is some inconvenience on a practical and aesthetic level. However, proposals like this only serve to undermine the potential support for truly innovative proposals that can benefit the local landowner, community, ecology and reduce our greenhouse gas emissions.
South Lanarkshire planning application ref: CL/15/0455, validated on 30th November 2015. http://pbsportal.southlanarkshire.gov.uk/northgate/planningexplorer/generalsearch.aspx
 Phys Org (September 2015). New efficiency record for solar hydrogen production is 14%. http://phys.org/news/2015-09-efficiency-solar-hydrogen-production-percent.html.
 The Scottish Government (2015). Energy in Scotland 2015.
 Turner, J., Sverdrup, G. et al. (2008). Renewable hydrogen production. International Journal of Energy Research 32:379-407.
 Gainford Limited (November 2015). Supplementary Statement, Fordmouth Renewables Limited Solar to Hydrogen Plant.
 SEPA (16 December 2015). SEPA response to CL/15/0455.
 Mitchell, C. (2012). Mapping the distribution of feeding Pink-footed and Iceland Greylag Geese in Scotland. Wildfowl & Wetlands Trust/Scottish National Heritage Report: Slimbridge.
 SNH (10 December 2015). SNH Position re CL/15/0455.