Their conclusion doesn’t formally oppose the scheme. It doesn’t support it either. Unless Blue Planet Solar supplies further evidence, redesigns parts of the project and pins down enforceable mitigation, officers say the council’s response should remain “one of clear reservation rather than support for the specific scheme”. That’s planning-speak for: not so fast, sunshine.
Councillors meeting on 21 July won’t approve or refuse South Brooks. The proposed 500MW solar farm is a Nationally Significant Infrastructure Project, so it’ll be examined by the Planning Inspectorate and ultimately decided by the Energy Secretary. FHDC is being asked to endorse its formal consultation response — a detailed list of what’s wrong, what’s missing and what’ll need sorting before any Development Consent Order application lands in 2027.
And this isn’t a few panels tucked discreetly behind Farmer Giles’s hedge.
The red-line boundary stretches across 1,208 hectares — 2,985 acres — making South Brooks a whisker smaller than Heathrow Airport. It’s spread across five main parcels around Lydd, New Romney, Greatstone and Dungeness, stitched together by cable corridors, access routes and other infrastructure. Around 655 hectares would accommodate above-ground development, while 322 hectares are set aside for landscaping and ecological measures. EDF power solutions UK and PS Renewables say the scheme could generate enough electricity to match the annual consumption of more than 140,000 homes.
Panels could stand 3.5 metres high, rising to 4.5 metres in flood-risk areas. Up to two substations are being considered, with a maximum combined footprint of 60,000 square metres, buildings reaching 15 metres and a lightning mast up to 25 metres high. A main collector compound could cover another 25,000 square metres and stand 7.1 metres high. There’d also be satellite compounds, three primary construction compounds, six secondary compounds, 6.5-metre-wide tracks, deer fencing, palisade fencing, CCTV, lighting, transformers, switchgear and battery storage. The number of battery units still hasn’t been settled.
The scheme has been pared back since last year, and it’d be churlish not to say so. The developable area has fallen by 20%, land for landscaping and ecology has risen by 25%, Parcel F has disappeared, half of Parcel D has been removed and Parcel E would have no above-ground infrastructure. The overhead connection to Dungeness has been dropped, while 9.3 kilometres of permissive walking routes are proposed. A further 43 hectares beside RSPB Dungeness would be dedicated to biodiversity. Those aren’t merely a fresh lick of green paint; they’re meaningful alterations.
They don’t, however, make the awkward bits vanish in a puff of environmentally friendly smoke.
The first elephant in the field is the field itself. Agricultural surveys have covered only 812 of the project’s 1,208 hectares, leaving 396 hectares still to be classified. Of the land surveyed, eight hectares are Grade 1, 414 hectares are Grade 2 and 256 hectares are Grade 3a. That makes 678 hectares — roughly 84% of the surveyed land — Best and Most Versatile agricultural land. The final figure can only stay the same or rise as the remaining ground is examined; it can’t magically shrink.
The comparison with other nationally approved solar projects is eyebrow-raising. One Earth Solar Farm, the closest match in overall size, involved 244.8 hectares of Grade 2 land and 416.1 hectares of Grade 3a — 660.9 hectares altogether. South Brooks has already identified more BMV land at 678 hectares, despite nearly one-third of its boundary remaining unsurveyed. More strikingly, its 414 hectares of Grade 2 land are 169.2 hectares above One Earth’s Grade 2 figure. Officers say the loss should carry “clear negative weight” and want proof that poorer land has genuinely been preferred wherever possible.
Then there’s that slippery little word, “temporary”.
South Brooks wants to operate for 60 years. National policy quoted by FHDC says “an upper limit of 40 years is typical”, although other projects have secured longer periods. Sixty years might be temporary in the geological sense, but it’s most of a human lifetime and several turns of the farming wheel. Officers want to know whether removing large chunks from individual holdings would leave the remaining fields commercially workable, because a farm can be killed by cutting away its viable parts without taking every last acre. They also want South Brooks assessed alongside South Kent Energy Park and Shepway Energy Park rather than each project pretending it’s the only combine harvester in the lane.
The landscape assessment is still missing some fairly important scenery. FHDC’s consultant says a full Landscape and Visual Impact Assessment hasn’t been supplied, leaving gaps in the methodology, study area, viewpoints, visualisations, receptors, cumulative schemes and proposed mitigation. A two-kilometre study area won’t do; the council wants five kilometres as the starting point, particularly because substations and associated structures would rise well above the panels and the Marsh hasn’t got hills to hide them behind.
Officers aren’t merely asking for better paperwork. They’re proposing actual surgery. Arrays north of Midley Wall should be removed, they say, while those south of Midley Wall and beside Romney Road should be pushed considerably farther back. Putting a substation or battery compound in Parcel C could have significant visual effects because it sits close to New Romney. Planting a hedge isn’t a magic trick either: the Marsh’s character comes partly from its openness, sparse vegetation, long horizons and enormous skies. Screening industrial equipment with walls of new planting can change the landscape nearly as surely as the equipment itself.
The heritage work has holes large enough to march a medieval congregation through. The applicant’s material records 219 designated heritage assets in the wider study area, 172 non-designated archaeological assets inside the site, another 1,026 outside it and 49 known archaeological assets within the boundary. Yet FHDC’s adviser says there isn’t enough information to be confident that the built-heritage assessment is “robust, proportionate and fully informed”.
New Romney, Old Romney, Lydd and Dungeness conservation areas haven’t been properly brought into the assessment. Nor have several potentially affected landmarks, including St Nicholas Church, New Romney; the ruins of Midley Church; the Dungeness lighthouses; and the Romney, Hythe and Dymchurch Railway. The landmark role of Grade I-listed All Saints Church at Lydd hasn’t been recognised across every parcel and connection route. Even the Cosway Monument, more than nine kilometres away, may matter because its designed views sweep across the landscape towards the proposed development. No cumulative built-heritage assessment has yet been produced.
One document seems to have gone walkabout altogether. The developer’s environmental material relies upon a Preliminary Risk Assessment when discounting some contaminated-land effects, but the assessment wasn’t included with the consultation papers. FHDC’s consultant says a robust opinion can’t be given without it. The available summary suggests serious health effects are unlikely, but scoping out a risk using a document nobody’s been allowed to inspect is transparency through a letterbox.
Drainage remains the bit nobody can afford to bodge.
Large parts of South Brooks sit in Flood Zones 2 and 3. The land contains main rivers, ordinary watercourses, ditches and old field-drainage systems, some of which may not be fully mapped. High groundwater means ordinary soakaway drainage isn’t proposed; water would instead need attenuating and releasing into watercourses under controlled conditions. The developers say significant hydrological effects aren’t expected once mitigation is applied. FHDC wants the sums, modelling and practical detail before taking that on trust — including climate change, tidal-defence breaches, historic drains, damaged pipes, compacted soil, watercourse crossings and effects on groundwater-dependent habitats.
Battery firewater is part of the same knot, not a separate sideshow. The battery compound would need sealed and impermeable drainage capable of holding contaminated firefighting water rather than letting it escape into the Marsh’s connected network of ditches. FHDC wants the Battery Safety Management Plan, containment strategy and emergency arrangements in enough detail for proper scrutiny at the DCO stage. “We’ll deal with it later” won’t wash when the later in question involves batteries, flood-prone ground and internationally protected wildlife sites downstream.
The cable route also runs straight into environmental quicksand. Around 51 hectares of the site fall within the Dungeness, Romney Marsh and Rye Bay SSSI, although no above-ground equipment is proposed there. Depending on which route is chosen, underground cables would cross the Special Protection Area, Ramsar site, Special Area of Conservation, SSSI and National Nature Reserve. The developer itself identifies possible permanent loss or degradation of habitat within protected vegetated shingle, which isn’t the sort of ground that springs back by Tuesday teatime.
The construction timetable can’t make its mind up either. One part of the paperwork says the work could take 48 months; the Transport Assessment uses 24 months. The broader programme anticipates a decision in summer 2028 and completion in 2031, which officers note doesn’t neatly add up to four years. That isn’t harmless diary trouble. Whether construction lasts two years or four changes the calculation for traffic, noise, rights of way, local businesses and the risk of several giant schemes digging up the Marsh simultaneously.
At peak construction, South Brooks predicts 472 daily vehicle movements: 230 by cars and light goods vehicles and 242 HGV trips. Heavy traffic on the B2075 could rise by 87.1%, adding 71 HGV movements a day. South Kent Energy Park would sit immediately beside parts of South Brooks and use much the same road network, while Shepway Energy Park would also be likely to use the A2070. Local people won’t experience those lorries in separate planning files; they’ll meet them nose-to-nose on the same roads.
Up to 600 workers could be employed during construction, but the council’s economic officers aren’t dazzled by the hard-hat headline. They say the long-term operational jobs would be far fewer and warn of a ripple effect through farming contractors, machinery dealers, suppliers, tourism and the wider rural economy. They want a binding employment, skills and supply-chain strategy, including local apprenticeships, training and a “local first” approach, rather than warm words that disappear once the contractors’ vans head home.
There are real benefits, and pretending otherwise would be cheap journalism. The developer estimates lifecycle emissions of 2.83 million tonnes of carbon dioxide equivalent, but forecasts savings of 5.4 million tonnes against average grid power and 10.2 million tonnes against gas generation over 60 years. It predicts the initial carbon debt would be repaid after seven years against the grid average. FHDC accepts the scheme’s contribution to renewable energy but wants those calculations presented as a range, because output, weather, battery use and the future electricity mix aren’t set in stone.
Hands Off Our Marsh remains firmly opposed. Its dedicated South Brooks page still describes the older scheme as covering up to 2,700 acres, while the latest boundary is 2,985 acres. That doesn’t mean 2,985 acres would be carpeted with panels — it wouldn’t — but it does show why figures mustn’t be tossed about like confetti. The campaign group argues that South Brooks, South Kent and Shepway Energy Park would together transform a large sweep of farmland and protected landscape around Old Romney, Midley, Lydd, New Romney and Greatstone.
The council’s own maps make the cumulative point better than any slogan. Appendix 1 shows the proposed schemes bunching together across Romney Marsh alongside existing and approved solar farms. Appendix 2 shows South Brooks’ five parcels and the cable corridors tying them to Dungeness. Planning applications arrive in separate envelopes; landscapes don’t.
The developer is dangling a community benefit fund of £400 for each installed megawatt per operational year. At the full 500MW, that’d be up to £200,000 annually — a nominal £12m over 60 years if the amount stayed flat throughout. The report doesn’t yet settle who’d control it, how communities would qualify, whether it’d rise with inflation or how it’d be legally secured. Either way, a community fund is a benefit, not a planning fig leaf. It can repair a hall roof or support a local service; it can’t unbuild a substation, replace productive soil or put a horizon back once it’s gone.
There’s a quieter problem brewing around New Romney too. Parcels B and C sit roughly 360 to 480 metres from the town’s southern settlement boundary and less than 300 metres from its south-western edge. New Romney and Littlestone form a strategic town in FHDC’s settlement hierarchy, and the council’s Local Plan review may eventually consider expansion. Nobody yet knows whether it will, but locking nearby land into energy infrastructure for 60 years could tie the hands of planners who haven’t even started drawing tomorrow’s map.
National policy gives South Brooks a strong following wind. Renewable electricity is classed as Critical National Priority infrastructure, and ministers say its need will normally outweigh remaining harm except in the most exceptional circumstances. That’s why a serious local challenge can’t rest on “solar bad” or misty-eyed nostalgia. It has to prove, field by field and drain by drain, that this particular development, in this particular place, at this particular scale, creates harms that haven’t been avoided, honestly assessed or properly contained.
FHDC’s officers haven’t reached that final judgement. What they have done is pull away the green wrapping and show how much work remains underneath: 396 hectares of unsurveyed land, no full landscape assessment, an incomplete heritage case, a missing contamination document, unresolved cable routes, two construction timetables, unsettled battery details, cumulative traffic, threatened farm viability and six decades of consequences.
South Brooks might yet clear those hurdles. Right now, though, it’s nowhere near the finishing line.
