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To register your interest contact Gill gill.art.connelly@gmail.com

by Saturday 14th September 2019

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The Faversham Society has made our latest submission to the Planning Inspector’s inquiry into the proposed solar power station at Cleve Hill. This submission has been made after the first set of hearings– after which we still have some very serious concerns about the proposed power station and felt many questions have yet to be answered by the developer. We do not feel in any way that the case for allowing the proposal to move ahead can be supported.

We have asked the Planning Inspector to hold further issue-specific hearings on two major areas of concern – namely the proposed battery energy storage system (BESS), and the evidence of need for the power station to be built.

In relation to the BESS, we have made clear to the Planning Inspector that we feel the developer has failed to satisfy concerns about safety, including the capacity of Kent Fire and Rescue to deal with any potential emergency. We have also raised that the developer has failed to make clear its plans for installing the BESS, leading to further questions about why the developer has chosen that model.

The Faversham Society has also submitted evidence that there is no evidence of need for the power station to be built. The National Grid has stated that future energy need to 2050 will be met from distributed generation rather than centralised energy plants such as Cleve Hill. We have also raised with the Planning Inspector our firm view that choosing Cleve Hill for the location of the power station is simply opportunistic, and a proper review of alternative sites is necessary.

In addition to these two issue-specific hearings, we have also asked the Planning Inspector to request further evidence on a number of other issues – including biodiversity, carbon sequestration, the financial model behind the proposal, and impact on agriculture, cultural heritage and transport.

We await the Planning Inspector’s response and remain firm in our objection to the proposal for Cleve Hill. Our full submission can be read here: https://favershamsociety.org/deadline-3-submission/
and for all the Society's Cleve Hill posts https://favershamsociety.org/category/cleve-hill/

The exhibition we ran over the last two weeks has gone well and we have received a great deal of support. Depending on the decision of the Planning Inspectorate we may need to launch a campaign in the autumn.

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At the end of the first set of hearings, the Faversham Society still has some major concerns since many questions remain unanswered, and new questions have been raised. While the applicant may answer some of these in written submissions, the Society considers that these answers should be subject to challenge. It was clear from the first set of hearings that there are inadequacies and omissions in the documentation submitted by the applicant and that the applicant’s submissions need to be challenged.

We also have serious concerns about the capacity of Swale Borough Council (SBC) to undertake the work necessary to adequately address the Discharge of Requirements if this becomes necessary. The fact that the applicant has a right of appeal against SBC decisions and their refusal to give up this right is worrying. The developer’s extensive resources pitted against SBC’s limited resources constrained by public spending limits do not augur well for SBC ability to adequately provide oversight. In order to level the playing field, we would urge that the DCO is as explicit as possible about those requirements that need to be satisfied.

If the development is built it is not clear to us how the various conditions might be enforced. This also means in particular that our cogent arguments on the limitations of the Rochdale envelope should be accepted, and that much more detail on the technology is provided now.

As already notified, we request additional Issue Specific Hearings as follows:

  1. The Battery Energy Storage System(BESS)

As you will recall, the applicant suggested that after 40 years the PV panels would be removed, but that the battery compound and batteries might be retained. The applicants did not respond when we tried to pursue this. This statement is in stark contrast to other statements by the developer that the BESS is not an essential part of the development and may be replaced by additional PV panels. Given the huge cost and construction time of the bund around the BESS enclosure, the developers admitted that such a decision would have to be made at the start of the project. Not implementing the bund would require a major change to the proposal as it stands, not least to time scales and traffic plans. But as we have also pointed out, exchanging a BESS with more solar PV is a major change of technology and fundamentally changes the nature of the proposal. Why has such an important and fundamental decision not been made already?

The considerations above lead us to a requirement that the developers are explicit on their intentions for the BESS both during and after the 40 year lifetime of CHSP.

  • Is its main purpose for smoothing intermittent supply from renewable energy sources or is it primarily a means of storing and trading energy?
  • Does it have a role in relation to the existing wind power capacity or is the possible use after 40 years simply for energy trading?

 These and other questions, on for example the energy specification of the BESS, are fundamental and the answers may possibly indicate an intention to create what is effectively a standalone BESS  which is very different from a proposal for a solar PV plant.

A further ISH on batteries and associated technology is needed to explore the many outstanding questions relating to the BESS, which besides those raised above would include:

  • Justification by the developers of their blanket use of the Rochdale envelope and reaching a defined position on the appropriate level of detail in the light of the well-documented hazards associated with large scale BESS
  • Specification and type of batteries and criteria for their choice based on, for example, safety record. E.g containerised vs stand alone
  • Worst case scenario on proposed total energy storage
  • Previous UK and European experience of this scale of BESS
  • Implications of current best practice advice on large scale BESS including that previously presented at Open Floor 2 from the insurance industry
  • Spacing of batteries to avert thermal runaway and provide emergency services access, and the impact of spacing on total energy storage
  • Access by emergency services by external roads and through the bund to all points in the BESS in order to ensure individual fires can be dealt with
  • Liaison with Kent Fire and Rescue Service (KFRS) in the BESS design stage and sign off by them and the HSE
  • Fire elimination and suppression measures to be built in, in the light of their previous well-documented failure in Hawaii, Arizona and Belgium
  • An independent assessment of the local knowledge and capacity of KFRS to deal with a runaway fire, including proposed suppression methods, extinguishing, cooling, and reignition (which has been shown to occur well after an incident). This to include best practice for lithium-ion batteries as well as the possibility of free lithium being produced in the event of an explosion, making the use of water extremely dangerous. Ability to cope in a toxic emission situation
  • Impact of hydrogen fluoride and other toxic gas emissions from a fire on neighbouring receptors including the whole of Faversham. See the submission by Bruno Erasin on HF emissions at Open Floor 2
  • Need and Alternative Sites


We have submitted further evidence on need for deadline 3 drawing on the recently published FES 2019 projections form the National Grid. This shows that there is no evidence of need for CHSP. The National Grid also points out that right through to its 2050 projections, future energy need will be met from distributed generation rather than centralised energy plants such as CHSP.

This authoritative and seminal view of need derived from the National Grid’s FES 2018 and FES 2019 is an unexplained omission from the application which has not been raised in the Examiner’s Questions nor has it been discussed in Hearings.  Our view is that it is essential that the applicants provide a response and that they can be questioned on it.

Having carefully read the applicant’s submission and listened to their evidence, we are now firmly of the view that the location is opportunistic. The site has been chosen because of the availability of the link to the national grid due to the spare capacity from the London Array, and we would like to point out that further wind power generation would almost certainly have had less negative environmental impacts than the Cleve Hill proposal. We would like to see further evidence on need and a proper review of alternative sites.

++++++++++++++++++++++++++++++++

In addition to our proposals for two further Issue Specific Hearings above, we have outstanding questions relating to the following topics. We would like these questions to be put to the applicants in the next round of Examiners’ questions.

  1. Agricultural Land
    The wide difference between the applicant’s assertions about the quality of the site as agricultural land and that presented by Dr Bruno Erasin is cause for concern. His evidence provides a substantial critique of the timing, methodology, data and the applicant’s evidence; sufficient to call into question the reliability of the applicant’s evidence.

  2. Managed Retreat

Marshland is now recognised as important for carbon sequestration and we have not found any acknowledgement of this in the application. We would like the applicant to be required to present data on the value of the ecosystem of the land as marsh compared to its use for power generation.


There was reference by the Environment Secretary in a speech on UK Climate Change Projections  to coastal realignment and a new strategy by the Environment Agency[i]  he said 'We are also pioneering ‘natural flood defences’, which support biodiversity and sequester carbon while lowering the risk of flooding.”

In the scientific literature, there is increasing evidence of the significance of the marsh for carbon sequestration:

“If coastal habitats are maintained at their current extent, their sequestration capacity over the period 2000–2060 is valued to be in the region of £1 billion UK sterling (3.5% discount rate). However, if current trends of habitat loss continue, the capacity of the coastal habitats both to sequester and store CO2 will be significantly reduced, with a reduction in value of around £0.25 billion UK sterling (2000–2060; 3.5% discount rate). If loss-trends due to sea-level rise or land reclamation worsen, this loss in value will be greater.”[ii]

The justification for the development of CHSP is its contribution to addressing greenhouse gas emissions, should the applicant not be asked to provide evidence that the net greenhouse gas benefit is positive taking into account the greenhouse gas emissions from establishing and operating the CHSP including the loss of carbon sequestration if the area reverted to salt marsh through managed retreat?

  • Biodiversity

We believe that there is good reason to question the quality of the applicant’s work on biodiversity. We heard evidence at the hearings of the importance of the site for European eels, Dormice and the Great crested newt. We would also like to have the opportunity to question the outcome of the Habitat Management Steering Group, about which, to date, we know very little. There should be an opportunity to challenge the evidence presented by the applicant on no net loss.

We heard Natural England inform us that monitoring of SSSIs is not taking place, what monitoring might we expect of the conditions attached to the DCO by either the Environment Agency or Natural England?

  • Cultural Heritage and the Views

We share Historic England’s concern about the level of harm to the setting of the listed buildings at All Saints Church (Grade I) and Sparrow Court and Graveney Court (Grade II).

We are concerned about the applicant’s lack of demonstrated concern and provision for the treatment of the WWII aircraft and any other archaeology which may be found on the site and have poles driven through it.

The cross-section drawings will assist with assessing the proposed planting and its impact on the intervisibility between the listed buildings and the Graveney Conservation Area.

We think that special regards should be paid to the relevance of the Barnwell case.

  • Transport

During construction of the London Array, there were specific measures to avoid movement by Graveney School at busy times. We have been surprised and dismayed by the lack of detail on safety, dirt, noise, visual intrusion and disruption to the education of young children
We have also not heard from KCC on the impact on traffic levels and the roads.

  • Finances

We realise that we have no access to the financial model behind the proposal, but we understand that the applicant has told residents that there is insufficient profitability to make any contribution to local causes. This contrasts markedly with the London Array development and raises questions in our mind about the viability of CHSP and leads us to suggest that there should be a bond to cover removal, disposal and habitat restoration.

Pole driving to support the panels will be both noisy and difficult to remove. It has been suggested to us that it would be more appropriate to use helical poles which would cause less disturbance to people and wildlife and would be easily removed and reused.

Professor Harold Goodwin

Chair, Faversham Society

For and on behalf of the Faversham Society


[i] https://www.gov.uk/government/speeches/michael-gove-speech-on-uk-climate-change-projections.

[ii] https://www.sciencedirect.com/science/article/pii/S0272771413005143?via%3Dihub

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Submission on behalf of the Faversham Society on the Need for CHSP -  Deadline 3\

  1. Introduction
    We recognise the urgent need to decarbonise electricity generation in the UK as outlined in the applicant’s Statement of Need and Addendum submission. This paper considers the deployment projections for solar PV currently in planning against deployment projections for requirements of solar PV by the National Grid, the UK System Operator.

    Comparing a case including the generating capacity of Cleve Hill against one excluding Cleve Hill, it concludes that the Solar PV deployments will be exceeded without the Cleve Hill site, thus concluding that there is not a need Cleve Hill Solar Park.

    2. National Grid Future Energy Scenarios
    National Grid in its role as the UK’s System Operator managing the electricity grid, prepares annual forecasts known as the Future Energy Scenarios (FES) (http://fes.nationalgrid.com/fes-document/). This sets out the three different scenarios it considers most likely given energy demand, expectations for electricity supply, current policies, decarbonisation requirements and requirements of energy security. The most recent version is FES 2019 published in July, just before the ISH on Need. FES 2018 enables detailed forecast demand figures to be extracted up to 2030. A careful study of FES 2019 reveals that it differs only in that it takes account of a proposed zero carbon target by 2050.  However, for the period up to 2030 FES 2019 is identical to FES 2018. We have therefore used the detailed figures from FES 2018 in this submission. We discuss the impact of the new zero-carbon policy framework in 4. below. The three scenarios identified and fully explained in FES 2018 and 2019 are:

    Community Renewables
    Two Degrees
    Steady Progression
    Consumer Evolution

3.The UK solar market
Many markets globally have ended direct subsidies in favour of unsubsidised markets or auction processes where governments procure electricity from the least expensive plants available. This has all driven the requirement for PV to become competitive with other forms of generation. The supply chain has responded in improving production efficiencies of PV systems and their constituent parts, resulting in reductions in capex of PV plants globally.

Given the costs reductions currently in train, the initial costs of installing solar PV in the UK are currently estimated to be c. £400-500k/MW. Given these prices, UK solar is now on the verge of cost competitiveness, and as these cost reductions continue, it is widely considered that it will be competitive with other generation within months.

The UK solar industry is responding and localised solar PV development is increasing with many development and construction cycles which are much shorter than those for other forms of renewable generation. This is especially so for those under the less than 50MW devolved planning process undertaken for all solar PV generation to date. CHSP is the first and only PV plant to be going through the NSIP process.

Submissions in local planning portals provide an accurate estimate of the solar PV projects that are currently in development. These can be considered in conjunction with those in pre-application and consultation phases to give a reliable indication of solar PV coming on stream over the period 2019-2022.

4. FES 2019 and Zero Carbon by 2050

As noted above, FES 2019 takes account of the new policy framework and target for zero carbon by 2050. FES 2019, Fig 5.4 indicates a 2050 solar capacity (demand) of c52GW of which only 42% is centralised. Moreover, FES 2019, Fig.3.2 on decentralisation is also of interest since it indicates that for the Community Renewables scenario, total centralised capacity stays fairly constant right up to 2050. This indicates that even in the zero-carbon scenario there is no role to be played for massive centralised installations such as CHSP. FES 2019  projections also detail and take account of significant energy demand reduction measures up to 2050.

5.Conclusion The chart below shows the total estimated new generating capacity outlined by National Grid in each of the National Grid deployment scenarios described above over the four-year period 2019 to 2022

As shown in Table 2  above the highest deployment projection for solar currently envisaged by National Grid (Community Renewables) is 4.1 GW from 2019 to 2022. Even without new additional solar PV, which will inevitably come on line in the coming years, the estimated capacity currently in planning (Table 3), excluding Cleve Hill is 4.3 GW which exceeds this projection. In addition the trend is away from centralised generating capacity such as Cleve Hill.

This indicates that by the planned completion date for CHSP there will already be sufficient solar PV capacity in the UK to meet our projected energy and decarbonisation needs.

This establishes conclusively that CHSP is not needed and will be redundant before it is completed.

Professor Sir David Melville CBE, BSc, PhD, CPhys, FInstP, Sen Mem IEEE(USA)

Vice-Chair

The Faversham Society

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The Faversham Society

Response to Examining Authority’s Written Question 1.08 regarding conformity with National Planning Statements

  1. Our understanding is that the critical test for a NSIP is conformity with National Planning Statements (NPSs) rather than with any Local Plans. However, there is no NPS for either solar power or battery storage technology. Given the unprecedented scale of this development (see 9. Below) the Faversham Society regards it as totally inappropriate and indeed reckless to proceed without such planning statements for guidance. We support the view of Swale Borough Council that this constitutes a fundamental objection to the proposal.
  2. Presumably, appropriate NPSs will be developed in future so it might additionally be argued that consideration of the current, clearly singular, proposal would likely preempt or prejudice such development.
  3. In relation to our objections to Heritage Impact on listed buildings, the need to balance ‘benefits’ and ‘harm’ lacks any basis for judgement without relevant NPSs
  4. Your question relates to the Applicant’s suggestion that NPSs EN-1 and EN-5 are potentially ‘relevant and important’ in relation to the Examination. We firmly assert that they are neither, other than in a very general (and unsupportive) sense for EN-1. (see 7. & 8. below)
  5. The Applicant refers to the National Policy Statement on Renewable Energy (EN-3) which provides no guidance on solar energy or battery storage installations and is therefore irrelevant.
  6. Similarly, the National Policy Statement for Electricity Networks (EN-5) relates primarily to new overhead electricity lines of 132kV and above, along with associated sub-stations etc. It refers consistently to the impact of power lines and its focus is clear.  No such infrastructure is proposed in the application and there is no reference to PV arrays or energy storage systems. We believe that EN- 5, therefore, can be discounted along with EN-3.
  7. The Overarching National Policy Statement for Energy (EN-1) provides the background for the consideration of other NPSs on specific technologies, but equally makes no reference, nor provides guidance on solar or energy storage. Whilst EN-1 is supportive of low carbon energy production it is not in any sense supportive of development on the scale of the proposed CHSP. Rather it encourages decentralised and community installations with increased connectivity, as well as supporting reducing energy demand.
  8.  NPS EN-1 also stresses the importance of considering the impact on tourism and rights of way, wildlife habitats, European sites, and landscape issues, especially in coastal areas. Importantly it highlights the dangers of flood risk and advocates the siting of vulnerable parts of developments away from areas of highest risk.
  9. We can only speculate as to the reasons why there are no NPSs for solar energy. Whilst large scale batteries have only become of interest recently, PV cells were developed in the 1950s and we used them extensively in space applications in the 1960s. Large scale (over 200MW) PV arrays have been developed worldwide since 2012 (India) but they are (unsurprisingly) predominantly in remote locations in China, India and the USA. The only other current solar power station in Europe over 200MW is in Cestas, France (300MW 2015) It is itself an outlier, being twice the size of the largest in Germany. The largest in the UK is currently 72 MW at Shotwick, Flintshire (2016, completed in 6 weeks).
  10. Clearly the proposed CHSP at 300MW is well beyond anything envisaged and well beyond the scope of existing NPSs and planning experience in the UK. Any solar array development on this scale must surely require national policy guidance. Additionally, the proposal for such a large scale energy storage system using emerging and potentially hazardous technology requires specific national policy guidance.
  11. In conclusion, the Faversham Society is firmly of the view that not only is there a lack of NPS guidance to determine the CHSP proposal, it is inappropriate to consider at this time an application of this unprecedented scale and with still emerging technology.

Professor Sir David Melville CBE CPhys FInstP
Vice-Chair
The Faversham Society Sir David Melville CBE, CPhys,FInstP, Sen Mem IEEE, HonDSc, HonDLitt, HonDUniv is a former Professor of Physics, Vice-

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The Faversham Society

CHSP Examination

Submission to Issue Specific Hearing on the Landscape and Visual Amenity Matters 23 July 2019

  1. We have a number of concerns about the impact of CHSP on landscape and visual heritage.

  2. We strongly the support the Local Impact Report submitted by Swale Borough Council on Residential Amenity, Cultural Heritage and Tourism and Economy

  3. On the London Array website the developer recognised “rich cultural heritage, with a number of historic structures and listed buildings” of the Cleve Hill area and worked to minimise the visual and environmental impacts. CHSP is quite different.

  4. At the Open Floor Meeting on 16 July we made representations about landscape character and the archaeology, and made the case for a protected Country Park. The population of the town could double to over 40,000 in the next two decades. With the growth in population and consequent urbanisation there will be very significantly greater demand for recreational space.

  5. CHSP will be clearly visible at the entrance to Faversham Creek as boats arrive form London and the European mainland. A Heritage Harbour is being developed in the heart of Faversham to conserve the historic port, the most northerly of the extant Cinque Ports, with the original Town Warehouse (II*) and gunpowder heritage. This is a major cornerstone of the regeneration of the area through tourism and specialist businesses.

  6. We have particular concerns about the Grade 1 listed All Saints Church, Graveney, constructed in Norman times, is mainly 14th century and will  be adversely affected. Graveney Marshes is part of Kent level Area of High Landscape Value and this has recently been endorsed as such for the new Local Plan. Graveney arable lands have been designated moderate condition/sensitivity and Graveney grazing lands as good condition/high sensitivity.  Views from England Coast Path/Saxon Shore Way will suffer major impact. It is also harmful to distant views, including Wraik Hill. The developers have admitted that the significance of the Church will be 'harmed' but claims this is 'less than substantial'. The Faversham Society disagrees.

  7. Graveney Marshes are at the entrance to Faversham Creek and this area has considerable amenity value for Faversham, the marsh provides valuable open space and places to walk and cycle. The loss of amenity land is a serious issue for Faversham,

Professor Harold Goodwin
Chair
The Faversham Society

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The Faversham Society

CHSP Examination

Submission to Issue Specific Hearing on the Development Consent Order 18 July 2019

  1. We have a number of concerns about the content of the DCO and about how compliance will be assured. 

  2. We have concerns about the limitations of the Rochdale Envelope about hazards associated with emerging battery technology. The application lacks detail on the battery technology to be installed. Li-ion batteries are potentially hazardous.

  3. It is not clear from the developer’s plans how the Fire Service would secure access to the battery storage area or effectively fight a fire within the compound, remembering that the compound is comparable in size to the Faversham recreation ground. We believe that the DCO should require the specification of all access routes.

  4. It is not clear what discussions have taken place between the Kent Fire and Rescue Service (KFRS) and the developer. KFRS have pointed out to us that “all risk reduction strategies start with prevention and it is the ‘responsible person’ for the premises that has responsibility for this as stated in the Regulatory Reform (Fire Safety) Order 2005.” There is very little in the application to assure that this has competently been done, nor what site-specific information will been provided to KFRS.

  5. KRFS informs us that: “In broad terms and prior to a decision relating to any on-site fire suppression systems, KFRS would extinguish a fire on the site by applying large volumes of water. Alternatively, if no life risk were present, then a controlled burn strategy may be considered and employed in order to try to minimise the possible environmental pollution that may be caused with fire water run-off.”  It seems reasonable to assume from this that there has been no discussion between the developer and KFRS. Is this acceptable when a new emerging and potentially very hazardous technology is proposed?

  6. There is no acknowledgement or proposed mitigation measures for the risk of a small fire spreading to other cells and becoming catastrophic with highly toxic emissions of Hydrogen Fluoride gas from burning Li-ion batteries in the air over Faversham or Graveney?

  7. We believe that the DCO should ensure that the batteries installed are subject to effective and enforceable regulation by an appropriate public authority.

  8. We also have concerns about the effective enforcement of any specification in the DCO on the numbers and timings of traffic movements. Who will be responsible for enforcing the traffic movement permissions? Do they have the capability and capacity to effectively enforce the DCO?

Professor Sir David Melville CBE, CPhys, FInstP
Vice Chair
The Faversham Society

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The Faversham Society
CHSP Examination
Submission to Issue Specific Hearing on Need, 17 July 2019

  1. Our submission relates to the need in terms of electricity generating capacity for a solar power station of this magnitude when it is balanced against the harm resulting  from: Damage to Heritage Assets and Archaeology; Habitat Loss; Flood Risk; Landscape and Footpath Impact; Damage to Local Communities; Traffic and Transport Impact; and is considered in terms of the nature of future energy distribution in the UK.
  2. The proposal is not only massively out of scale with the local environment; its dimensions do not relate to any significant argument on national need. Rather the location, dimensions and proposed generating capacity appear to be based entirely on opportunism as a result of the spare capacity resulting from the previous development at Cleve Hill.
  3. The chart below shows the total estimated new generating capacity outlined by National Grid in each of the National Grid deployment scenarios described above over the four years 2019 to 2022.
This image has an empty alt attribute; its file name is image.png

As the National Grid chart above shows, the highest deployment projection for solar currently envisaged by National Grid is 4.1 GW from 2019 to 2022. Even without new additional solar PV, which will inevitably come online in the coming years, the estimated capacity currently in planning, excluding Cleve Hill, is 4.3 GW, which exceeds this projection. We submit that there is sufficient solar PV capacity in the UK to meet our current energy and decarbonisation needs.

4. This 350 MW solar power station (the generally accepted title) is almost five times larger than the UK’s current largest solar power station in Shotwick, Flintshire (72MW). The latter was built in 2016 and completed in six weeks. Contrast this scale with the two year construction period, plus a possible further six months for the Applicant’s proposal.

5. This 350MW solar power station, if agreed, will be the largest in Europe, with the next being 300MW in Cestas, France. Apart from a 166MW installation in Meuro, Germany all others in Europe are less than 85MW, making Shotwick currently Europe’s 4th largest solar power station. Such an outlier as CHSP in terms of current European practice needs much stronger justification than that provided in the application.

6. In Global terms the five countries with most of the solar installations larger than the proposed CHSP (China, India, USA, Brazil and Mexico) all have much larger populations and sunnier climates than the UK, as well as large land areas on which to build them. In short, for these countries, large solar installations are more appropriate and more efficient.

7. In terms of need such a large scale proposal is not congruent with national policy guidelines (NPS EN-1) which encourages decentralised, and community installations with increased connectivity, as well as supporting reducing energy demand.

8. A 2015 article by Steve Holliday, CEO of the National Grid in energypost.eu https://energypost.eu/interview-steve-holliday-ceo-national-grid-idea-large-power-stations-baseload-power-outdated/ argues that large scale localised power stations are already outdated and that the future ‘base load’ ie the core of world power generation is already ‘moving towards much more distributed electricity production and towards microgrids’. He notes that these means were, in 2015, resulting in over 1,500 MW (4 CHSPs) of solar power being added in 3 months, and that small-scale distributed generation would represent a third of total capacity in the UK by 2020.

9. Such considerations from an authoritative source, who is the manager of our national energy system, indicate the irrelevance of a 350MW centralised solar power station, such as CHSP, to the total solar capacity which is growing much more rapidly and is more in tune with future distributed needs.

10. This suggests strongly that the adverse effects and ‘harm’, summarised in 1. above, far outweigh the potential benefits of an out of scale, massively disruptive proposal which may be unnecessary and is already being outflanked by more appropriate and more effective small-scale developments.

Professor Sir David Melville CBE, CPhys, FInstP
Vice Chair
The Faversham Society

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CHSPSubmission to Open Floor Hearing 2 - 22 July 2019 Presented on behalf of The Faversham Society by Professor Sir David Melville CBE

Energy Storage System - Safety Issues

 1. We are concerned at the limitations of the Rochdale Envelope in relation to hazards associated with emerging battery technology. The Rochdale envelope is neither a blank cheque nor a Trojan Horse. It is assumed to apply to existing,  safe technology which may be superseded during the course of a development. It is not appropriate for technology, known at the outset to be a potential hazard with an unknown improvement path. Caution is further advised given the lack of any NPSs relating to solar PV and energy storage systems. 

2. We are concerned at the unprecedented scale of energy storage (Batteries) and known fire risk. (3 further unexplained, spontaneous Li-ion car battery fires in April/May this year). Imagine the area of the Faversham recreation ground filled with over 20,000 Tesla cars piled two deep.

3. Flood risk mitigation (the bund around the batteries) needs to specify associated access arrangements and expertise for Kent Fire and Rescue Services. Published plans do not specify any access roads to the perimeter of the bund. How is a fire at the centre of the installation to be dealt with?

4. Li-ion battery fires are acknowledged as among the most difficult to suppress. Some advice is to ‘let the fire burn itself out’. This is not practicable in a large scale battery installation. Conventional sprinkler systems are unlikely to be effective. Modelling is needed on the risks of individual failure leading to a runaway catastrophe.

5. Besides uncertainty on the type of fire extinguisher to use there are known emissions of highly toxic Hydrogen Fluoride gas from burning Li-ion batteries (Nature 2017).  

6. What systems for fire suppression are proposed and what are the precedents for their effectiveness for large scale installations?

7, Who is responsible for the assessment of risks associated with the use of emerging technologies and what professional advice on safety will the Examination commission? 
The application is totally lacking on technical detail on the energy storage system. In view of the potential hazards this must be provided to enable scrutiny and professional assessment.

Traffic and Transport 
Inevitably there will be ongoing heavy traffic issues (noise, pollution and danger passing the Graveney Primary School) beyond the construction period, associated in particular with the (potentially toxic) battery replacement cycle.
Lifespan data on large Li-ion installations is sparse, but warranties and reputable tests (NREL) on batteries for domestic PV solar installations in the USA  indicate a 7-10 year lifespan. In addition there will be traffic movements due to replacements resulting from PV panel maintenance and improved technology upgrades.
This should be researched by the proposers and factored into traffic plans for the whole lifetime of the solar power station
Professor Sir David Melville CBE, CPhys, FInstP, Sen Mem IEEE(USA)Vice-ChairmanThe Faversham Society(Former Professor of Physics, Vice-Chancellor and Permanent Secretary) 

Submission to Open Floor Hearing 1 - 16 July 2019 
Presented on behalf of The Faversham Society by

Dr Patricia Reid Ph D
Archaeology

1.      The Graveney marshes are an artificial landscape created from the mid-medieval period onwards and feature salt mounds, sheepfolds, former sea walls and early post-medieval decoy ponds with a decoy house, Kye Cottage (now demolished). None of this landscape apart from the Cleve Hill substation itself has been investigated, and this landscape deserves recognition, protection and investigation before it is overtaken by the sea in the near future. 
2.      Underneath the marsh lies a Saxon/ Roman/ prehistoric landscape of great importance, of which only minute glimpses have been achieved so far: this too must be protected.
 3.      The section of the Graveney marshes east of the lower part of Faversham Creek is especially important historically, as the route whereby Bronze Age, Roman, Saxon, Viking, medieval and modern ships have traveled on their journey to the port of Faversham. It is likely that there is much to be discovered as a result. 
4.        There is an extremely strong emotional bond between Faversham people and their Creek.  The solar power station plans already set aside the eastern end of the marshes, next to the Sportsman, for birds etc.  A very strong case can be made for the western section of the marshes (bordered to the east by the footpath line which goes north from Nagden farm) to be protected and joined with a) the Ham Marshes west of Faversham Creek and  b)  the Isle of Harty on the other side of the Swale (Harty is historically closely linked to Faversham) to form a protected Country Park. This is especially vital because of the rapid and unavoidable increase in housing over the next 10 years along the line of Watling Street (see current proposals).  At present there is a danger that the marshes around the lower Creek will become a dystopian landscape.

Dr Patricia Reid PhD
Director of the Faversham Society Archaeological Research Group 

CHSP
Submission to Open Floor Hearing 1 - 16 July 2019 
Presented on behalf of The Faversham Society by
Professor Harold Goodwin
Transport and Traffic

1. Routeing: Construction plant, equipment and materials will be delivered to the site by HGV along one of three possible access routes.  All three are routed via junction 7 on the M2, which is already overloaded and has a poor accident record.  The Faversham Society is concerned that during the construction period any blockage at this site, or closure owing to an accident, will result in lorries being re-routed along unsuitable rural roads. 

2.  Safety: the proposers claim that there is a negligible risk of accidents arising from the anticipated levels of site traffic during the construction period.  However, it is well known that nationally, heavy vehicles engaged on construction projects have a poor safety record particularly as regards collisions with cyclists.  The freight access route along the Seasalter Road from the railway bridge to the site entrance coincides with the Sustrans National Route 1, frequently used by recreational cyclists at weekends and for the whole week during the summer months, and the proposed construction management plan does not appear to include measures for dealing with the increased risk. The lack of pavements throughout Graveney Village also poses heightened risks to pedestrians.

3. Risk to Children: The route passes a primary school whose playground and buildings are a few metres away. Only short stretches of pavement exist. Children need to cross the road to access their playing fields. The proposed vehicle movements of up to 80 per day (one every six minutes for two years, mostly during the school day) will result in unacceptable levels of noise, pollution and danger to children at the school.

4.Operation and Decommissioning: Plans need to be presented for traffic movements in the operation phase associated with battery replacements ( years 7- ) and PV panel replacements (years 10-20). Failed battery cells may possibly be toxic. Similarly decommissioning is likely to lead to parallel hazards to the construction phase.

5.  The Faversham Society believes that the raised levels of goods traffic will erode the quality of the environment and the quality of life for local people during the construction period, and that the associated loss of amenity is unacceptable whether or not there is residual damage. We have concerns about danger, noise, vibration and air quality. 

Professor Harold GoodwinChairman
The Faversham Society

Notification of wish to attend Accompanied Site Inspection (ASI)
We request that Professor Harold Goodwin, Chairman, attend the ASI on behalf of the Faversham Society.
We have no specific site suggestions.

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Registered Charity  Number 1135262 - Company No 07112241
The Faversham Society - Registered Address: 10-13 Preston Street, Faversham, Kent ME13 8NS

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