Written Evidence submitted by Say No To Sunnica Community Action Group (FS0057)

Thank you for the opportunity to submit evidence to this Food Security Inquiry. I chair a community action group opposing a 2500-acre ground-mounted solar and battery NSIP (Sunnica Energy Farm), proposed entirely on high quality, and high yielding, agricultural land across East Cambridgeshire and West Suffolk.

Like many other similar solar campaign groups (we are members of the Solar Campaign Alliance, which comprises over 50 solar campaign groups across the nation) we are not anti-solar or anti other renewables. But we strongly believe that such developments need to be in the right place and we are concerned at the number of these developments being proposed and built on the UKs best farming land. There appears to be no accurate monitoring of this agricultural land loss, which we feel needs to be addressed as a matter of urgency, as outlined in our evidence below.

  1. What are the key factors affecting the resilience of food supply chains and causing disruption and rising food prices – including input costs, labour shortages and global events? What are the consequences for UK businesses and consumers?

One of the key factors affecting food supply chains is climate change. We are already seeing signs of the effects of drier summers, wetter winters, etc. in the UK. But the effects of climate change are being seen throughout the world. Recent reports are already highlighting a decrease in the yields of the world’s top 10 crops, with the greatest impacts being seen in Europe, Southern Africa and Australia. In Spain, a large proportion of the country is at risk of increased desertification. African countries are also severely affected by extended drought.

Alongside this, the UK is currently losing significant amounts of its most productive and versatile farming land to development at an alarming (and unmonitored) rate. Figures of over 40,000 hectares of agricultural land lost each year have been cited (1), but this is likely to be an underestimate. Our food-growing land, a valuable national resource, is being devoured by housing projects, large-scale ground-mounted solar and battery farms, as well as environmental projects such as rewilding etc. We need to address this loss of farming land urgently and reduce land use conflicts.

Land is finite, and high-yielding, versatile farmland cannot be recreated, so a clear plan is needed to protect this resource whilst achieving our housing and environmental goals.

Given the climate crisis, it is no longer possible, or wise, to assume that we no longer need to preserve our best growing land for farming and that we can simply import our food from elsewhere. Climate change is a global problem. The competition for food will only ever become fiercer and the prices higher as a result.

We need to be smart about where and how we develop. For example, according to the BRE National Solar Centre, there are over 250,000 hectares of unused south facing commercial rooftops in the UK which could be used for solar PV installations and which do not conflict with land used for food or environmental benefit or housing (2). A recent report by the UK Warehouse Association concluded that even if just 20% of the UK’s biggest warehouse rooftops were fitted with solar, it would immediately double our solar energy output and meet our 2030 net zero targets (3). Clearly if more than 20% were developed, this would produce even mor solar energy. And if other commercial and domestic rooftops were fitted with solar PV, this would improve the energy security situation further still.

Unfortunately, this is not happening – instead we are seeing a rush by solar developers to lease valuable farming land to convert into large-scale ground-mounted solar farms. This needs to stop. Such developments are being approved even on our Best and Most Versatile Land, which according to the NPPF is meant to be avoided, and this is largely due to unclear guidance for planning authorities. In Wales, planning authorities have been told to place considerable weight to the quality of the land when faced with applications on farmland. In England there is still some ambiguity.

Combined with the absence of a national database for capturing agricultural land loss to development (see Section 2), we could be heading into a serious reduction in our domestic food supply.

Land-based solar may well be needed in the energy mix, but this should be on brownfield land or alongside areas of existing major infrastructure (e.g. roadsides, rail tracks etc), as is done in countries like Germany. We therefore agree with the food strategy that land-use change [should be targeted] at the least productive land, to increase the environmental benefit from farming and to increase yields with minimal impact on food production.

The UK could learn more from other countries e.g. where deployment of rooftop solar is more advanced. For example, in Germany, over 72% of their solar energy output is from commercial and domestic rooftop installations and the solar output in Germany is over 45 GW (4), compared to around 14 GW in the UK. This, along with the earlier cited reports about the need for investment in rooftop solar, demonstrates that rooftop solar PV is viable and can play a role in protecting our food supply chain.

We agree with the food strategy statements that “successful domestic production is what gives us national resilience in an uncertain world. Those countries that are entirely dependent on imports for their food supplies tend to be characterised by less choice and higher prices.

However, given the increasing population and the uncertainty of crop yields due to changing weather patterns, international conflicts etc, we do not feel that a target of “broadly maintaining the current level of food we produce domestically” is the best course of action as it will inevitably lead to food shortfalls and likely more reliance on imports (with the consequences of higher prices, scarcity, lower quality, etc).

It would be immoral to deprive poorer nations of food from the global supply chain that we could readily grow in this country in larger quantities, but choose not to as we prefer to use the land for other purposes. And particularly where alternative options for these other purposes are available (such as rooftop solar instead of land-based solar on farmland).

Finally, if more of our agricultural land is lost, and landowners decide to convert more and more land to developments, we will see a significant number of job losses in the agricultural sector, as well as in supporting industries, and an overall loss of farming know-how. We welcome the food strategy objective to “ensure that by 2030, pay, employment and productivity, as well as completion of high-quality skills training will have risen in the agri-food industry in every area of the UK, to support our production and levelling up objectives.”

Obviously this requires better protection of the UK’s best agricultural land to achieve this and to encourage our farmers to continue farming.

  1. What is the outlook for UK food price inflation in the short and medium term? What policy interventions should the Government consider to manage these pressures?

- A proper land use strategy is urgently required, which protects productive, high yielding farmland from development to ensure that the UK’s food security is improved. If this is not done, food prices are likely to continue to rise, along with food scarcity.

- There is currently no accurate monitoring of the amount of farmland being lost to development. As cited in section 1, this is likely to be in excess of 40,000 hectares a year.

For example, when it comes to monitoring renewable energy projects, BEIS have a renewable energy database which records wind, solar and other renewable applications, where they are deployed etc. But it only records whether e.g. a solar development is ground-mounted or rooftop. Critically, the type of land being used is not recorded. This would be a simple addition to the database and could provide a valuable tool for planning authorities to use to review cumulative impacts, proposals on BMV land, etc.

We are not aware of any other database that records this information in DEFRA, or if any database in the DLUHC records what land type is being proposed for e.g. housing developments etc.

A more comprehensive database and better data sharing between Government departments is required – particularly between DEFRA, DLUHC and BEIS - so that a shared tool that monitors agricultural land loss to development can be created, and land use conflicts minimised as a result.

Without an accurate picture of what is happening across the country, we could be sleep-walking into a significant reduction of domestic food supplies and continued increase in price.

As an example, solar developers state that they will aim to put solar on non-agricultural land, or land that is considered ‘poor quality’. But in reality this is not the case. Our local community action group carried out research into solar developments in the East Cambridgeshire/ West Suffolk region and it was noted that over 20 solar developments were in operation/ under construction within a 15 mile radius of the Newmarket area. All but one of these were on Best and Most Versatile farming land which, according to the NPPF, should not be developed.

-            Clearer guidance to planning authorities is required, and more weight needs to be given to the retention of productive farmland, as mentioned in Section 1.


-            The principle of Agricultural Land Classification (ALC) assessment has been reviewed by the Welsh Government and regarded as fit for purpose. However, the ALC assessment on infrastructure and planning projects is carried out by a contractor employed by the applicant. In order to avoid bias in these assessments planning authorities should be employing an independent qualified soil expert with fees reclaimed from the applicant.

Since many statutory consultees e.g. NE rely on the ALC assessment to inform their response to a planning application, it is vital that an independent, accurate assessment, using accredited methods, is obtained to prevent our best quality farmland land being lost.

-            In the policy brief SP1104 The Impact of Climate Change on the Capability of Soils for Agriculture as Defined by the ALC it was determined that droughtiness was likely to have the greatest effect on ALC in the future. Farmers are already planning for this increased requirement for irrigation by building more reservoirs which can be filled during the winter, thus reducing water levels during times of potential flooding. The EA see this as part of their strategy.


This stored water can then be used to irrigate crops in the drier months. We need to ensure that this kind of farmland with irrigation from winter-filled reservoirs is retained as this is better suited to adapt to climate changes.

  1. How are the rising cost of living and increasing food prices affecting access to healthy and nutritious food?

Locally grown food is fresher and therefore more nutritious compared to imported produce. It helps mitigate climate change as it reduces the carbon footprint of food miles. It is so important that everyone has access to locally grown produce as much as possible, and that our future generations understand the connectivity with nature, food origins, food nutrition, sustainability, etc.

We agree with the food strategy comments that locally produced food with reduced distance between farm and fork can provide societal benefits, such as creating personal connection between producers and consumers, supporting local food cultures and local economic growth, and improving traceability of food through shorter supply chains


Children growing up in agricultural areas are likely to have a better understanding and appreciation of healthier foods and are more likely to eat and enjoy them as they can see where the food has come from, how it is grown etc. It can give them a sense of pride, a sense of place and promotes long term healthy eating habits. As an example, where we live, PYO strawberry and pumpkin farms are hugely popular with families; children enjoy trying different varieties of these fruits and vegetables. Local ‘Open farm days attract thousands of visitors and help to provide that essential connection between communities, food, nature and place.


We are pleased to see targets in the food strategy of obtaining more locally produced food within the public sector and encouraging healthier diets. For school children, increased living costs may mean that a school meal is their main meal and their only chance of obtaining nutritious and healthy food.


According to Sustain, the Government’s Levelling Up and farming programmes should be investing heavily in local food infrastructure and partnerships across the country.


Clearly this requires better, and immediate, protection of the UK’s agricultural land to achieve this before we realise too late that we have lost a high proportion of our best growing land.


  1. How will the proposals in the Government’s food strategy policy paper affect:

a)      the resilience of food supply chains?;


The target of ‘broadly maintaining’ our domestic food production is at odds with the recognised impacts of climate change, loss of growing land due to changing weather patterns, development , etc and a growing population. This is likely to lead to a worsening food supply chain. We should be looking to increase this.


If the policy aims of increasing access to locally grown nutritious food, cutting carbon miles etc. are to be achieved, we need to increase domestic production and the policy needed to underpin all of this is better protection of our productive and high yielding farmland. If this continues to be lost at the current rate outlined previously, the aims described within the food strategy will not be achievable.


b)     the agri-food and seafood sectors?; and


As mentioned in section 1, unless our best, versatile farmland is better protected from development, the agri-food sector will not achieve the potentials highlighted in the report. The agri-food sector will suffer as a result of job losses, loss of knowledge and loss of farming know-how to future generations.


c)      access to healthy, nutritious food?

As described previously, there is a lot of support in the food strategy policy paper, and in the UK as a nation, to ‘buy British’, support our farmers, support local producers etc. The benefits of having access to locally grown, nutritious food are clear, and lead to better long term healthy eating habits.

Increased employment and productivity in the agri-food sector should help to support this, providing that we retain our valuable, high yielding farming land on which to produce.

We do not want our markets flooded with cheap, poor quality food that is less nutritious, increases food miles and takes food away from other countries who may be less able to produce the food we are importing.

  1. Is the current level and target of food self-sufficiency in England still appropriate?

No. As outlined above, the demands on our food growing land are set to increase. Maintaining the status quo will inevitably lead to food shortages and higher prices (with the knock-on consequences on health).

We should be targeting more domestic production to help counter climate change and loss of food producing land globally, as well as to feed a growing population.

High-yielding agricultural land will require irrigation to maintain its productivity which may be lost as a result of climate change. It is therefore crucial that we do not  lose vast amounts of our best, and already irrigated, farming land to development.

  1. How could the Government’s proposed land use strategy for England improve food security? What balance should be struck between land use for food production and other goals – such as environmental benefit?

As outlined previously, our greatest concern is the loss of high yielding, versatile and irrigated farming land to large-scale ground-mounted solar projects. These schemes are very ‘greedy’ on the land area required, occupying many, many acres for a small energy output compared to other renewables such as wind.

Solar developments should first be directed to rooftop installations and brownfield sites or the poorest quality land (as assessed by qualified, independent soil experts, as mentioned above). They should not be on productive farmland.

There is no accurate monitoring by the Government of productive farmland being lost to solar, so the risks to our food security are clear. A land-use strategy is key to ensuring land use conflicts are minimised and that our valuable faming land has better protection.

Environmental benefits such as rewilding projects are important and should not have to compete with other developments that can be located elsewhere and not conflict with land use (e.g. solar developments should be directed to rooftops, not farming land).

The current guidance within the NPPF is not clear enough and planning authorities are approving developments on our best and most versatile farming land. This needs to stop.

Further, it is evident that little is known of the ecological impacts of large-scale ground mounted solar development, since large solar farms are a relatively new addition to the renewable sector. Natural England have concluded that further research is needed in this area. So it is inappropriate to be blindly permitting hundreds of large-scale solar schemes, on agricultural land and wildlife habitats, until we have an effective monitoring and control programme in place and until more is known about the long term environmental impacts. In the meantime it has been shown that other surfaces are readily available for solar PV in the UK.

As Eric Pickles MP said in his 2015 ministerial statement, Meeting our energy goals should not be used to justify the wrong development in the wrong location and this includes the unnecessary use of high quality agricultural land. Protecting the global environment is not an excuse to trash the local environment.”

We whole-heartedly agree with this.



1)      Land use and solar farms (churchillfellowship.org)

2)      BRE (2016) Solar PV on commercial buildings: a guide for owners and developers, (K. Arora, S. Diu, J. Roper and G. Hartnell)

3)      Investment case for rooftop solar power in warehousing Delta-EE Publications (ukwa.org.uk)

4)      4) Source: BSW German Solar Association, Presentation on the German Solar PV market, October 2018


September 2022