Low Carbon says its South Kent Energy Park could power the equivalent of 140,000 homes. Its own scoping report also shows a much bigger scheme, on arable Marsh land, much of it potentially best and most versatile farmland, in a defended floodplain where KCC says long-term water and climate risks are still “poorly understood”.
South Kent Energy Park has just become a much bigger story. What began in public-facing material as a roughly 600-hectare proposal near Old Romney is now presented in the June 2026 scoping report as an 859-hectare Development Consent Order boundary — about 2,122 acres — across arable Romney Marsh land north and south of Old Romney and the A259. That is not a tidying-up exercise. On the numbers now in the documents, the boundary has grown by about 259 hectares, or roughly 640 acres, compared with the 600 hectares still described on Folkestone & Hythe District Council’s page.
Low Carbon says South Kent Energy Park is a proposed 500MW solar and energy-storage project on Romney Marsh, capable of powering the equivalent of 140,000 homes — roughly 20% of Kent households — every year. That is the polished version. The planning version is more revealing: this would be a Nationally Significant Infrastructure Project, with solar photovoltaic panels, Battery Energy Storage System infrastructure, underground interconnecting cables, substations, fencing, tracks, drainage, landscape planting and biodiversity measures, ultimately decided not by district councillors in Folkestone & Hythe but by the Secretary of State after a Planning Inspectorate examination.
The applicant’s scoping report describes the site as land parcels north and south of Old Romney and the A259, with the Main Site encompassing land required for generation and storage of electricity, battery infrastructure, solar arrays, a National Grid substation, the South Kent Energy Park main on-site substation, additional substations and areas for landscape and biodiversity mitigation. So let’s not pretend this is simply a few panels leaning politely in a corner of a field, humming quietly while sheep provide the pastoral soundtrack. This is industrial energy infrastructure across a very large part of the Marsh.
The grid connection is still a moving target. The scoping report says the existing offer is to connect to the proposed East Kent Connection Node A substation, but the precise location of that substation has not been confirmed and remains subject to National Grid’s optioneering. For scoping, the applicant assumes the substation could be inside the DCO boundary, while admitting that if National Grid later confirms a different location, further consideration and, where necessary, further environmental assessment would be required. In ordinary English: the public is being asked to comment on a scheme whose grid furniture is not yet nailed down.
The applicant also stresses that the DCO site boundary may be refined as the design progresses. That sounds harmless enough until you remember the present boundary is already approximately 859 hectares. “Refinement” can mean less land. It can also mean different land, different impacts, different access routes, different drainage assumptions and another round of residents discovering that the map has quietly changed while the brochure language stayed soothing.
The land itself matters. The scoping report says the landscape around the DCO boundary consists predominantly of agricultural fields and that land within the boundary consists of arable farmland. In a district where planning arguments often become foggy with words such as “sustainable”, “green”, “enhancement” and “balance”, this should be kept brutally simple: South Kent Energy Park is proposed on a very large area of working agricultural land.
The agricultural-quality evidence is awkward for the applicant. The scoping report and it appendices predictive Agricultural Land Classification data says the DCO boundary is predominantly Best and Most Versatile agricultural land. Its own figures identify 498.32 hectares as Grade 1, 3.58 hectares as Grade 2 and 116.73 hectares as Grade 3a. That means roughly 618.63 hectares — about 71.8% of the 861.89 hectares shown in the agricultural table — is predicted to be Best and Most Versatile land. This is not poor scrub, spare verge or brownfield dressed up with a skylark logo.
The scoping report says an Agricultural Land Classification and Soil Resources survey will be undertaken and that consultation with Natural England will be carried out because the Main Site is over 20 hectares and agricultural land may be classified as BMV. That survey now needs to be more than a technical appendix. It needs to answer the public question plainly: how much Grade 1, Grade 2 and Grade 3a land is actually being taken into a 40-year solar-and-battery scheme, and what is the realistic route back to productive farming after decommissioning?
The lifetime matters too. The mitigation register says construction is anticipated to take 24 to 36 months, operation is expected to last 40 years, commencing in 2033, and decommissioning is anticipated to take 24 months. The main scoping report says the design life is expected to be 40 years, with panels and components replaced during normal maintenance, and that at the end of that period the equipment will be reviewed to determine whether it remains viable to continue operating. So the Marsh is not being asked to host a short-term experiment. It is being asked to host infrastructure whose effects may run across most of the working lives of today’s young residents.
And this is where the flood-risk issue stops being an “add-on” and becomes central to the South Kent solar farm story. The applicant’s own report says the majority of the DCO site boundary is situated within Flood Zones 2 and 3, associated with flooding from the sea. It also says the Environment Agency flood zones do not take account of flood defences, while the long-term flood-risk map, which does account for defences, shows the proposed development in areas considered to have a very low chance of flooding. That distinction is everything: defended risk is not no risk.
The same table says there is residual tidal risk if flood defences are breached, and that the Environment Agency will be contacted for modelled breach results as part of the site-specific Flood Risk Assessment. It also says the White Kemp Sewer Main River flows west to east through the south of the DCO boundary, the New Sewer Main River flows west to east through the north, and a number of land drains across the boundary are regulated by the Romney Marsh Area Internal Drainage Board. In short, water is not around this scheme. Water is through it, beside it, under it and built into its whole setting.
The scoping report admits the fluvial picture is not yet settled. It says the Flood Map for Planning does not specify whether risk arises from tidal or fluvial sources, that the flood zones appear to be associated with tidal sources, and that “the fluvial flood risk to the Proposed Development is currently unknown.” Data will therefore be requested from the Environment Agency, Kent County Council and the Romney Marsh Area Internal Drainage Board, with hydraulic modelling undertaken where required. That is an extraordinary sentence to sit beside a 2,100-acre solar-and-battery proposal.
Because the scheme is classed as “Essential Infrastructure” and the majority of the DCO boundary lies in Flood Zones 2 and 3, the scoping report says an Exception Test will be required. For that test to be passed in Flood Zone 3, the Flood Risk Assessment must show the development would be safe for its lifetime, taking climate change into account. The report says this will influence the positioning of infrastructure, particularly BESS and substations, and the heights of panels. That is not a detail. That is a warning label.
The proposed drainage answer is, at this stage, conventional. The report says surface water discharge rates will be restricted to greenfield rates, with on-site attenuation provided primarily through sustainable drainage systems, including Rural SuDS or other appropriate solutions. That is the right paragraph for a consultant to write. The question is whether it is the right answer for a defended, low-lying, pump-dependent Marsh where flood volume, groundwater, tide-locking and residual breach risk may matter more than a neat greenfield-runoff sentence.
Kent County Council’s own flood presentation makes that concern impossible to brush aside. Under agenda item 5, “Romney Marshes Flood and Climate Change Assessment”, KCC described Romney Marsh as a flat and low-lying reclaimed wetland of about 250 square kilometres, much of it below mean high-water springs, protected by a long frontage of tidal defence and dependent on a network of watercourses, main rivers, sewers, ditches, drains, pumps and gravity outfalls.
Then came the line that should now sit at the top of every response to South Kent Energy Park: “Currently, the long-term risks for water level management, surface water flooding, and climate change are poorly understood.” KCC also said water-level management on Romney Marsh is complicated, predominantly based on local knowledge and historical management, that interaction between catchments and networks is poorly understood, and that there is currently a lack of modelling to support evidence-based decision making.
That is the contradiction at the heart of the South Kent solar farm. A 2,100-acre nationally significant solar-and-battery scheme is being scoped across Romney Marsh while KCC says the Marsh’s long-term water-level, surface-water and climate risks are still poorly understood. It is not anti-renewable energy to say that. It is basic due diligence. You do not put vast energy infrastructure into a complex floodplain and then discover the floodplain is more complex than the brochure allowed.
KCC’s presentation said increased rainfall, sea-level rise and more frequent tide-locking of outfalls as a result of climate change are expected to increase flood risk to communities, businesses and key infrastructure, including rail and highways, but that “the level of this risk is unknown.” That unknown sits directly against South Kent Energy Park’s need to prove it will remain safe for its lifetime. If the flood-risk baseline is still being built, then the solar farm assessment must not pretend the foundation is already firm.
The next phase of KCC’s Romney Marsh work is supposed to model hydraulic interactions between watercourses, pumps and gravity outfalls across the area. KCC said the study area will be divided into discrete catchments, with modelling to determine floodplain storage and flood risk to receptor locations, and that because of the low-lying pumped catchments, “flood volume is more likely to be the key driver of flooding, instead of peak flows.” That sentence is fatal to any lazy assessment that treats runoff as a standard spreadsheet box.
This means the South Kent Energy Park Environmental Statement must not simply tell residents that runoff will be limited to greenfield rates and then move briskly on to the photomontages. It must show how 859 hectares of panels, tracks, compounds, fencing, underground cables, BESS containers and substations interact with flood volume, pump capacity, outfalls, ditches, drains and future sea levels. On Romney Marsh, the water may not care that the drainage chapter looked tidy.
Cllr Tony Hills (pictured) put the Marsh reality into plain English during the same agenda item. He called the Romney Marsh work the “first step” for Kent in understanding places at risk from rising sea levels, more extreme weather and flash flooding, and described the Marsh as the “canary in the coal mine” because the work could show how Kent protects communities into the next century. He also warned that if the worst extreme weather forecast arrives, “our sea defences aren’t designed for that.”
Hills then gave the committee the topographical lesson every solar promoter should have to read aloud before using the word “resilience”. Dungeness, he said, is a shingle island at about six metres Ordnance Datum; across the Marsh, moving inland towards the canal, the land gets lower, with an average of around three metres OD and some places as low as zero metres OD. The average spring tide, he said, is about 4.4 metres OD, so if the sea gets in, “it will fill inside out.”
“Fill inside out” is the Marsh in three words. It means the issue is not simply whether the sea comes over a wall in a dramatic television-friendly wave. It is whether water enters, sits, moves through dykes, backs up through drains, meets tide-locked outfalls, overwhelms pumps, mixes with groundwater, affects access, threatens substations and makes a nonsense of neat planning diagrams.
The Environment Agency’s Romney Marsh material gives the wider public-risk frame. It says much of Romney Marsh is around one to two metres below high spring tide levels and that, without protection, 14,500 homes, 700 businesses, nationally important critical infrastructure, military sites and environmental designations would be at risk. It also says existing coastal defences are reaching the end of their design life, with many in place since the early 20th century.
Peer-reviewed climate evidence reinforces why this cannot be brushed away as local nervousness. Kulp and Strauss’s CoastalDEM paper in Nature Communications found that, under high emissions, up to 340 million people could live on land below projected annual flood levels by mid-century, and up to 630 million by 2100, compared with roughly 250 million at present. That does not prove every defended Romney Marsh field will flood annually, but it does show why low-lying defended coastal land must be tested against future annual flood exposure, not treated as safe because it usually looks dry today.
Climate Central’s own press material on the same study says that by 2050 sea-level rise will push average annual coastal floods higher than land now home to 300 million people, and adds the critical caveat: without existing, augmented or new coastal defences, populations in these areas may face regular flooding or permanent inundation within 30 years. The correct use of this evidence is not hysteria. It is scrutiny: South Kent Energy Park’s Flood Risk Assessment must show how this defended Marsh landscape behaves over the lifetime of the scheme, with climate change, residual breach risk and drainage dependency fully in the equation.
Ecology is another hard constraint, not a garnish. The scoping report says there are no international, national, regional or locally designated nature-conservation sites within the DCO boundary itself, but the closest environmental constraint is Dungeness, Romney Marsh and Rye Bay SSSI, Ramsar site and SPA, approximately 660 metres east of the DCO boundary. Dungeness SAC is 2.7km south, while Romney Warren Local Nature Reserve, Dungeness National Nature Reserve and Romney Sands SPA are also within 5km.
The water environment chapter adds that both the SPA and Ramsar site are hydrologically connected to the DCO boundary by various drains and ditches. That matters because hydrological connection is not a theoretical inconvenience. It is how impacts can move through the Marsh. If a scheme changes drainage, runoff, sediment, pollution pathways, groundwater interaction or water quality, the ditch network is not just scenery; it is the transport system.
The bathing-water detail should also make people sit up. The scoping report identifies three designated bathing waters downstream of the proposed development: Littlestone-on-Sea, St Mary’s Bay and Dymchurch. It says Littlestone and Dymchurch have “poor” water quality with bathing not recommended according to 2025 classifications, and that their bathing-water profiles list pollution from nearby drains as a possible issue. The report proposes not to assess bathing waters further because of dilution. Given the district’s recent sewage and storm-overflow history, “the sea will dilute it” may not be the reassurance consultants imagine.
Landscape impacts are also not trivial. The scoping report says construction could result in temporary significant adverse landscape effects because of physical alterations to landform, removal of vegetation, construction machinery and activity on a greater scale and duration than general farming. During operation, it says the development would change landscape character through renewable-energy equipment and structures. This is the applicant’s own language, not a protest poster tied to a gate with baler twine.
The operational kit is large. Solar mounting structures could be 4.5 metres high, BESS containers 4.5 metres high within a maximum compound area of 8 hectares, substations up to 9 metres, the South Kent main on-site substation up to 13 metres and the National Grid substation up to 25 metres. CCTV posts could be five metres high, with 3.4 metre security fencing around substation compounds and electrical infrastructure. That is an energy park, not an agricultural footnote.
Cumulative impact may become the real story. The South Kent figure pack identifies DCO solar projects within 5km of the proposed development, including South Brooks Solar Farm and Shepway Energy Park. The scoping figure says South Brooks was digitised from its consultation material and Shepway Energy Park from Planning Inspectorate notice and public-domain boundary material. In other words, South Kent Energy Park is not arriving alone; it is joining a cluster of major solar and energy projects on the Marsh.
That cumulative issue must not be allowed to vanish into the paperwork swamp. One big solar farm can say its impacts are managed. Another can say the same. A third can arrive waving a biodiversity net gain calculation and a smiling stock photo of a meadow. But Romney Marsh experiences the total effect: land-use change, construction traffic, visual change, altered drainage, cable routes, substations, battery compounds, fencing, maintenance access and the steady conversion of farmland into energy infrastructure.
KCC councillors understood the solar-flood connection. Cllr John Baker (Reform UK) asked whether proposed solar farms will increase flood risk. Louise Smith responded that solar farms come through KCC’s statutory consultee role within the SuDS team, that they should not release or discharge above greenfield runoff rates, and that sites may need to store water on site. She also said rainwater harvesting could be advised, especially because of concerns that solar farms may use mains water to wash panels.
That answer is useful, but it is not enough. The South Kent scheme must be judged not only on whether each drainage feature ticks a SuDS box, but whether the whole project is compatible with the future Marsh system KCC is only now trying to understand. Greenfield runoff rates are not a magic spell. They do not by themselves answer groundwater, tide-locking, breach risk, flood volume, emergency access, BESS safety, contaminated runoff, or cumulative solar build-out across the same low-lying landscape.
The land-ownership question must also come back in, carefully and properly evidenced. The South Kent scoping report does not name the landowners. Shepway Vox’s earlier work on the St Mary’s solar farm showed why Land Registry evidence matters, because it can reveal who owns the land, who holds options or restrictions, and who may benefit from solar development. The same method now needs applying to South Kent Energy Park: title by title, field by field, option by option.
Shepway Vox’s wider land-ownership work across Folkestone & Hythe has already shown how much local land is tied up in public bodies, institutions, colleges, the Crown, utilities and private companies, and how Land Registry data can turn vague local suspicion into checkable evidence. For South Kent Energy Park, the public-interest test is not gossip about who owns what. It is documentary proof: registered proprietor, title number, tenure, option agreement, restriction, charge, lease and ultimate beneficiary.
That matters because the Marsh is not just a planning location. It is a working landscape, a flood-risk landscape, a food landscape, a habitat landscape and a land-ownership landscape. If more than 2,100 acres are being moved into a nationally significant solar-and-battery scheme, residents deserve to know who owns the land, who has signed what, who gets paid, who carries long-term drainage obligations, and who is responsible if the restoration promise proves thinner than the marketing.
None of this is an argument against renewable energy. Climate change is real. Decarbonisation is necessary. Solar will be part of the answer. But a climate project on Romney Marsh does not get to ignore climate risk because its press release is green. If anything, it should be held to a higher standard, because the very problem it claims to help solve — a warming climate — is also one of the risks bearing down on the land beneath it.
The key question is therefore simple. Can South Kent Energy Park prove, with site-specific modelling and not just consultant confidence, that its panels, BESS, substations, cables, drainage, access routes and decommissioning plan remain safe and workable over the full lifetime of the project, on a defended floodplain where KCC says long-term water-level and climate risks are still “poorly understood”?
The Environmental Statement must answer that question before anyone is asked to accept the scheme. It must show the final land take, the final grid assumptions, the actual agricultural grading, the title and option picture, the flood modelling, the breach scenarios, the groundwater position, the tide-locking risk, the cumulative solar impact, the water-quality pathways, the BESS safety assumptions, the access arrangements in flood conditions, and the restoration plan after 40 years. Anything less is not scrutiny. It is paperwork with a sunny logo.
Romney Marsh has lived with water for centuries. That does not mean it can absorb every scheme that arrives with a net-zero badge and a battery compound. The South Kent solar farm may yet be redesigned, reduced, justified or refused. But the starting point must be honest: this is a huge energy proposal on high-quality arable Marsh land, in a defended and poorly modelled flood-risk landscape, beside internationally important habitats, with other major solar schemes nearby. The Marsh does not need panic. It needs proof.
Seen something the public should know about? Send tips, documents or concerns to TheShepwayVoxTeam(at)proton(dot)me. You can contact us in confidence, speak off the record in the first instance, and help us follow the evidence where it leads.
The Shepway Vox Team
The Velvet Voices Of Voxatiousness
