The solution
The spirit of government policy is to protect the function of FZ3b (‘the functional floodplain’) to store and convey flood water. Our challenge was to convince the EA that neither would be impaired by the construction of a solar farm on the site, or at least over the majority of the site; and negotiate where panels should be excluded as there was no policy or guidance to draw from.
We argued that wind turbines should be treated as a proxy for solar panels: an argument attempted elsewhere, but not yet successful in FZ3b. Our hydraulic modelling work not only defined the extent of FZ3b, but also provided flood depth, velocity and hazard data to allow a better understanding of the risks across the site. The results demonstrated that flooding in all events would, in fact, be quite shallow (less than 0.3m, not deep enough to reach the bottom of the panels), and slow flowing across most of the site.
Knowing the risk that the EA would cite concerns about the possibility of tree branches and other debris catching in the legs of the solar panels, we met the EA officer on site to show the lie of the land. Although the ground upstream was steep, there were not many trees to be swept down, and the land itself was relatively flat with small drainage channels.
The original proposals were to cover the majority of the site with solar panels. In the end, the EA agreed to mitigation measures. A particularly vulnerable area would be excluded: about 3% of the total site area. In part of that section, the ground would be lowered by 0.1m to collect water, more than offsetting the potential loss of storage capacity due to access roads and the slender legs of the thousands of panels.