December 2023 - Eastbourne ECO Action Network

Suncoast Solar Farm Planning Application (ref.230800): setting the context

This guest blog is from Miles Berkley, who was one of the co-founders of the Eastbourne ECO Action Network CIC, and is a Director of TechResort CIC which works from its base in Devonshire Ward helping to tackle digital exclusion, here and across East Sussex. He’s also a member of the multi-agency Lewes District Cost of Living Partners Action Group, and is a subscribing member of Friends of the Earth.

Setting The Context:

Friends of the Earth notes the need to increase at a minimum the amount of locally generated renewable energy in Eastbourne from about 4.8 GWh currently to 28GWh i.e. 5.8 times present levels (UK Climate Change Committee). In fact, Friends of the Earth recommends we go further to reach 56.1 GWh. For more details, look here: https://groups.friendsoftheearth.uk/near-you/local-authority/eastbourne#energy

The Eastbourne Borough Council Carbon Neutral Annual Report (Dec 2023) reveals that the town’s emissions in 2021 rose 6% from 2020 levels to 277.4 ktCO2e, the main source of which is domestic buildings, closely followed by transport. Eastbourne Borough Council has pledged to achieve a carbon neutral town by 2030, which the Tyndall Centre at the University of Manchester states that it requires an overall reduction of emissions by 12.3% per year – which is not being achieved.

We are experiencing the destabilising effects of accelerating global warming with more extreme weather events: storms, flooding, heatwaves, wildfires – all devastating the habitats of every species. We need to rapidly scale up action to decarbonise our energy sources, moving away from fossil fuels, as well as improving the UK’s national energy security.

Biodiversity Net Gain – improvements needed.

The present proposal presents a Biodiversity Net Gain (BNG) of between 24-29% based on the creation of new habitats and water courses, plus the addition of 11.51 new hedgerow units.

In comparison, another similar sized local development of 17MW (compared to 20MW for Suncoast) achieved a 243% net gain in habitat areas, and 104% in hedgerows. This, the Ouse Valley Solar Farm, is supported by Greenpeace.

The Cleve Hill Solar Farm (373MW) development on the North Kent Coast achieves a 65% BNG and is supported by Swale Friends of the Earth Group. The latter development achieved this by reducing the overall area covered by solar panels to 45.5% of the developable area, leaving the remaining arable land to be managed for biodiversity benefits.

The Berwick Solar Farm in Wealden has, for example, installed a Swift Tower, orchards, and thermosolar beehives.

The developers need engage the professional opinion, and support of, local ecologists to conduct further studies, to obtain detailed expertise regarding the site, and to help oversee the delivery of a far-reaching and rigorous biodiversity net gain management programme. Preferably, they could work with Sussex Wildlife Trust which advised the Berwick Solar Farm, and possibly Buglife, who also provide specialist advice to realising the biodiversity of solar developments.

This proposal should seek to improve the BNG target, either through reducing the density of solar panels on the existing developable area and/or including other areas within the proximity for biodiversity investment, as done at Cleve Hill.

Local Community Benefits – needs a clear, significant, and defined local gain.

The proposal indicates that a Community Benefit Fund may be created but falls short of specifying the financial contribution envisaged, or the process for managing this, and does not set out transparently the financial gains to the developer, or landowner (Chatsworth Estate/Duke of Devonshire).

Suncoast state that the 20MW capacity can supply c6.400 homes. They use a metric of 2,900 kWh per home (slightly higher than the Ofgem average of 2,700 kWh consumption of electricity). The Energy Stats portal, which monitors the wholesale market price of energy, indicates the average price is currently around 10p per kWh – which if achieved would result in a minimum annual income to Suncoast of £1,856,000 annually, though market prices fluctuate e.g. prices have been twice or three times this level during the past 12 months, this could result in a turnover of c£4-6 million per annum.

From this the developer would need to repay the capital costs, say £424,000 per annum (£16 million capital investment at 6% interest depreciated over the 40 years expected lifespan) less other costs such as network connection fees, business rates, maintenance and rent to the landowner. If the development achieved an average net margin of say c20% of turnover, this could result in a net profit somewhere between £360,000 -1,080,000 each year (depending on market prices)

This speculation goes to the heart of the difference of this type of commercial development compared to a community energy scheme where the financial profile is more transparent, and the community benefit better defined. It would be beneficial for Suncoast to share its financial forecasts.

Level Up our deprived parts of town in a targeted and direct way

This proposal needs to recognise the financial wealth historically extracted from Eastbourne by the Chatsworth Estate (valued at some £905 million) together with opportunity to “level up” those parts of the town which are most deprived, from the latest LSOA data i.e. these are Hampden Park, Langney, the northeast of town centre, Roselands, and Devonshire Ward.

Given the historical perspective, and depth of the local need I suggest that a minimum fund of £5,000-10,000 per MW annually is provided by Suncoast i.e. £100,000 -200,000 each year. With the fund to be administered by a board of local constituted third sector grassroots organisations directing the funds to tackle deprivation in all its manifestations (energy and food poverty, homelessness, digital exclusion, and other aspects of deprivation) in these areas. This would augment and better target the now much reduced Eastbourne Borough Council Devolved Ward Budget Scheme.

Review of 2023: a personal perspective from our Executive Director

Another year has gone by, so time for a review of what the Eastbourne Eco Action Network (EEAN) has been up to in 2023, following on from the reviews of our activities in 2021 and 2022.

The highlight of our year was undoubtedly our widely acclaimed Sustainable Transport & Active Travel Summit in November, which opened with a keynote speech from Chris Ralls, a member of the EcoTransport Group. This summit brought together all the main players in the local transport sector to investigate ways of deepening collaboration on plans and actions to tackle Eastbourne’s notoriously chronic traffic congestion and pollution, as well as its over-dependence upon cars for travelling across town. Transport accounts for over 25% of the town’s carbon emissions, a proportion which has so far stubbornly refused to decline. The quality of presentations and workshops was very high, and together with the extensive networking evident during the summit, there is perhaps a good chance that the barriers to progress on local transport will finally be overcome, leading to more, better, safer walking and cycling infrastructure as well as more reliable bus services operating on dedicated bus lanes supported by more bus priority measures. The first opportunity to see such progress will come if the new Local Transport Plan 4 prepared by East Sussex County Council gets final approval and adequate funding for its implementation. You can comment on it now that it is open to public consultation until February 2024.

The One Planet Eastbourne online community ecosystem platform for mapping and tracking progress towards a more sustainable town was developed by the EEAN this year using the innovative OnePlanet app, designed to facilitate deeper collaboration between local organisations on climate actions and environmental initiatives. Extra grant funding has now been secured to significantly extend work on this platform and to help other local local groups to use the OnePlanet app.

The EEAN organised an Eastbourne Carbon Neutral 2030 Gathering at the Town Hall in May, bringing together many of the local groups involved in helping to make the town Carbon Neutral by 2030. It was an excellent opportunity for those groups to give updates on their progress and to network with other local groups. Hopefully another such gathering can be organised in 2024.

The EEAN partnered up with Energise Sussex Coast to train up local volunteers to become Energy Champions, equipping them to run local energy projects such as giving basic energy advice to local residents and supporting local energy efficiency or clean energy initiatives of various kinds. The first event organised by the Eastbourne Energy Champions was a Business Community Energy Day in July at East Sussex College’s Green Training Hub in Hampden Park The first cohort of Energy Champions have now completed their training, and more cohorts will be trained up in 2024.

Eastbourne Borough Council decided this year to fund a scheme for offsetting the carbon emissions of Airbourne 2023, by far the town’s biggest festival of the year. The council approached us for advice on which scheme to fund, and we advised that the best scheme would be one developed locally by the Eastbourne United Nations Association. This scheme, which has been running successfully for many years, channels donations from local organisations into supplying free tree saplings to local communities in Uganda, proving these communities with much needed biodiversity improvements as well as nutritious fruit and natural medicines. The amount of carbon sequestered by the scheme is much greater than any similarly-sized tree planting scheme in the UK because of the special nature of the trees planted and the very favourable climate of that part of equatorial Uganda where the tree are planted.

In October, Eastbourne Borough Council submitted plans to the South Downs National Park Authority for its proposed Black Robin Farm redevelopment, part of its government-funded Levelling Up project. If approved, this would trigger a significant investment in the Eastbourne Downland Estate, the biggest since the downland was saved by popular opposition from being sold off by the council in 2017. Comments on the plan can be made via the SDNPA planning portal. Much rides on how well the plans would protect and enhance the downland biodiversity as well as addressing how transport by visitors to the site by bus, walking and cycling can best be supported and encouraged. I and my fellow directors have submitted comments to the SDNPA about the plans.

In December, plans for a big solar farm in Eastbourne, the first ever, was submitted to Eastbourne Borough Council by a commercial developer. If approved, it will be sited in Eastbourne Park and will supposedly generate 20MW of electricity, equivalent to producing enough clean energy to power 6,400 homes per year. If approved, the solar farm would represent the single biggest increase in solar power within the town, adding to the solar power generated by the solar canopy installed this year by Eastbourne DGH over one of its car parks. Solar power is a key part of the clean energy transition and a key element in the national strategy of weaning the UK off its traditional reliance on fossil fuels for power generation. However, much rides on the quality of the solar farm’s proposals on protecting local biodiversity, and how much the local community would benefit from the project. I and my fellow directors gave advice to the developers on how that might best be achieved.

2023 was the hottest year in human history and 2024 looks set to be even hotter when the current El Nino reaches its climax. No wonder 2023 was full of natural disasters worldwide such as severe floods, droughts and storms. Given that we may be entering the early stages of climate breakdown, there is a need for much more rapid progress not only towards a zero carbon Eastbourne, but also towards building a strong climate adaptation plan to prepare for the inevitable and damaging impacts of climate change upon Eastbourne, a low-lying coastal community that is very much in the front line of climate change, facing the rising seas and stronger storm surges of a rapidly warming world. Indeed, a key part of adapting to climate change is managing and improving our local sea defences. Which is why, in November, the Environment Agency released its list of options for maintaining and improving the local sea defences from 2027 to 2037 and started a public consultation on them. The EEAN is represented on the agency’s Coastal Community Forum for Eastbourne and attended all of its meetings so far, giving feedback about what our network perceives as the key issues that need addressing.

Key to developing the effective climate adaptation plan we need is the development of a strong and resilient local food system that supports local food growing initiatives and provides equitable access to healthy, locally grown or locally sourced food. Fortunately, the good folks at the Eastbourne Food Partnership, one of our partners, are doing lots of work on this and have this year won the Bronze Award from Sustainable Food Places for that work. They deserve congratulations on achieving this significant milestone and look forward to deepening our collaboration with them in 2024, especially through working with them on researching ways in which local food growing can adapt to our changing climate.

But there is so much more to do, especially as Eastbourne Borough Council’s latest update to its Climate Emergency Strategy states: “The Tyndall Centre and the University of Manchester have carried out analysis that recommends a minimum of a 12.3% per year reduction to deliver a Paris aligned carbon budget. The borough as a whole is a long way off meeting this year-on-year reduction”. The effectiveness of the council’s climate action plan was comprehensively assessed this year by Climate Emergency UK, which published a detailed scorecard of progress achieved in Eastbourne so far. Yet, as the strategy update also says, “We must not be put off by the challenge but must rally together and work together to improve the environment of our town for our residents, children, businesses and visitors now and in the future in order to mitigate global climate change”.

I wish to thank all the members and supporters of EEAN for all their hard work. The EEAN is entirely run by volunteers on a very small budget but consistently punches way above its weight, making significant contributions towards the ECN2030 campaign. May you all have a very restful and peaceful Christmas holiday period followed by a very Happy New Year.

Andrew Durling, Executive Director, Eastbourne Eco Action Network CIC

Can We Trust Transport Modelling?

Are you intending to comment on East Sussex County Council’s Local Transport Plan 4 ( LTP4). For those who want to review the proposals the future projections for transport look good. Predicted to have fewer car trips whilst buses, pedestrians and cycling numbers are all up. That is good news! …. but as a reminder LTP3 had similar aspirations

Perhaps now is the time to ask why planners are generating such positive scenarios, that you may feel are not achievable. The predictions are derived from complex algorithms. Often the process is described as a ‘black box’. The definition of which is ‘a complex system whose internal workings are hidden or not readily understood’ . That makes anything it produces as hard to verify

Let us examine the accuracy of such models. From a lay person’s perspective the optimistic scenarios, over the last 10 years, never seem to have been delivered.

This table below , with 19% fewer cars trips, is from the LTP4. Some scenarios deliver an even larger drop in car trips. [As background, on a number of the workshops it had been asked, if some explanation could be be provided as to how the ‘black box’ generated these outputs]

In sharp contrast, in LTP4 it does admit that, across the county, the number of residents cycling has reduced by around 33% in 5 years. Plus there was a large decrease in bus provision over 20 years and even with an increase in funding, bus passengers are only 90% of pre-Covid numbers.

The largely ‘positive’ models are endemic throughout the planning process. Over the last 10 years many focus on a 10% ‘modal shift’, away from cars, towards buses and cycling. However these predictions then feed into other local plans and permeate through the whole planning process.

As an example ESCC’s ‘Hailsham, Polegate to Eastbourne corridor ‘, from 10 years ago, predicted a 10% reduction in modal share for cars. This scenario is then used by developers, on that key route, to show the extra traffic, from their developments, will be offset by the modal shift this original report had predicted. The example used here is taken from the Transport Assessment for Hindsland in Willingdon. (see Tables 6.2 and 6.3)

Method of Travel – Currently (left) and with planned improvements (right)

Notice that the developers take current traffic data and then adjust to the new modal share. So that cars, including passengers, are down from 80% to 70% and this would suggest traffic levels will be lower. To compensate, for the lower private transport, there is an increase in bus trips from 4% to 9%. That is a 125% increase, alongside an increase for cycling up 150%. But there has never been a demonstrable increase in either.

This general approach, to overstating modal shift, is also seen in Eastbourne, by developers, on schemes such as the Magistrates Court and TJ Hughes. The positive transport assessments, produced around higher levels of active travel, seem to satisfy both developers and councils. They do not alter the reality.

Now look at Black Robin Farm (SDNP/23/04238/FUL). Aecom ,in their transport review for Eastbourne Borough Council, provided a comprehensive analysis of transport options. Their algorithm produced –

The reality check is that for Eastbourne 5% of trips are by bus and on the Downs nearer 10%. However there is no explanation as to how 50% Public Transport could ever be achieved. Plus in this scenario cycling at 4% would be an increase from an original estimate of 1,000 to 4,000 trips p.a. Cynics might think the data was to convince South Downs National Park that there would not be a high demand for car parking. Based on the 100,000 visitors predicted p.a.

Many of these models have shown to exaggerate the modal shift away from private cars. To provide reassurance, models need to be validated, to see how accurate they were. The Government’s Transport Analysis Guidance (TAG) “provides an overview of good practice in planning the evaluation of transport interventions to ensure robust evidence can be collected about the difference that they are making in practice. It is intended to support evaluation planning and stronger business cases for a range of transport interventions in terms of mode, type of intervention” Model guidance from Govt

In summary we are asked to take on trust the ‘black box’ approach, that transport planners are using, when our lived experience would suggest something different. Perhaps now is the time to reassess the accuracy of the predictions. If you have doubts then make this clear in your comments for LTP4 and question them about their methodology

Paul Humphreys EEAN Transport Group