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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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The Faversham Society Opposes the Cleve Hill Power Station

The Faversham Society has registered its objection to the Cleve Hill development. Although we support alternative energy, we have grave reservations about the developer's plans for Cleve Hill.

Our strong objection to this planning application is based on these areas of serious concern:

Batteries

This is one of the largest Li-Ion battery installations in the world, with no track record of this scale of installation in the UK. This remains an emerging technology. It is well-established that such batteries can catch fire or explode, especially when exposed to water. The safety of the batteries has not been adequately addressed.  Given that the batteries are the shortest-life components with individual variability, what are the replacement arrangements for these units, including traffic management and hazardous waste removal? How much traffic will be generated by the need for maintenance?  The batteries will occupy an area the size of Faversham recreation ground - the equivalent of 20,000 Tesla cars piled two deep. How will Kent Fire and Rescue Services gain access in the event of a fire which could start in any one battery?

Access and Traffic 

Construction plant, equipment and materials will be delivered to the site via three access routes.  All are routed via junction 7 on the M2, which is already overloaded and has a poor accident record.  Any blockage or closure will result in lorries using unsuitable rural roads. During the two year construction phase it is estimated that there will be up to 80 HGV movements per day. ie one very six minutes during the working day. 

Despite the application’s claims of negligible risk, heavy vehicles engaged on construction projects have a poor safety record particularly as regards collisions with cyclists.  The freight access route coincides with the Sustrans National Route 1, frequently used by cyclists. No risk mitigation measures have been proposed.

Graveney Primary School is on the access route for site traffic. Children must cross that road to access the playing field. Increased industrial traffic will pose an increased safety risk to these children. Also, increased industrial traffic may disrupt access to the school for staff and parents. The raised levels of goods traffic will erode the quality of the environment and the quality of life for local people. The associated loss of amenity is unacceptable, whether or not there is residual damage.

We also have serious concerns about noise, vibration and air quality.

Landscape, Visual Impact and Loss of Amenity

The proposal would have a destructive impact on this landscape. 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.

Graveney Marshes are at the entrance to Faversham Creek and this area has amenity value for Faversham, the marsh provides valuable open space and places to walk and cycle. The population of the town could double to over 40,000 in the next two decades. The loss of amenity land is a serious issue for Faversham,

The Faversham Society's Vice Chair, David Melville, was interviewed on KMTV video

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 am writing on behalf of the Faversham Society to inform you that I wish to speak at the Preliminary Meeting on the 30th May 2019 under the following agenda items:

Cultural Heritage
The adverse impact on the Grade 1 listed All Saints Church, Graveney, constructed in Norman times, mainly 14th century. 

Environmental Statement (relates also to Water ,flooding etc)
Limitations of the Rochdale Envelope in relation to hazards associated with emerging battery technology.Batteries - Flood risk mitigation, fire risk,(3 further unexplained, spontaneous Li-ion car battery fires in the past month) and associated access arrangements and expertise for Kent Fire and Rescue ServicesResponsibility for the assessment of risks associated with the use of emerging technologies

Landscape
Loss of amenity in the light of potential plans for a rapidly enlarging urban population connected to Faversham.

Traffic and Transport
Inevitable ongoing heavy traffic issues 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 domestic PV solar installations in the USA  indicate a 7-10 year lifespan. Has this been researched by the proposers and factored into traffic plans? The main route close to the primary school is of great concern.


In addition, the Faversham Society feels that the Draft Examination Timetable does not explicitly cover the applicant's inadequate technical detail relating to batteries, fire safety, transport etc and requests that this be made the subject of an Issue Specific Hearing. The applicants fail to acknowledge that their proposal embodies one of the largest ever battery installations using a still emerging technology with a problematic safety record.

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


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The Faversham Society has registered its objection to the Cleve Hill development. Although we support alternative energy we have grave reservations about the developers plans for Cleve Hill.

Our strong objection to this application is based on these areas of serious concern:
Batteries
•       The safety of batteries has not been adequately addressed.  
•       This is one of the largest Li-Ion battery installations in the world, with no track record of this scale of installation in the UK. 
•       This remains an emerging technology. It is well-established that such batteries can catch fire or explode, especially when exposed to water. 
•       This raises crucial questions:
1.      Which body will be responsible for assessing the battery proposal?
2.      Will Kent Fire and Rescue have access to the site and battery units; and do they have the appropriate expertise?
3.      Is there secondary flood protection, and how is this compatible with emergency access?
4.      Given batteries are the shortest-life components with individual variability, what are the replacement arrangements for these units, including traffic management and hazardous waste removal? 

Access and Traffic  

•       Construction plant, equipment and materials will be delivered to the site via three access routes.  All are routed via junction 7 on the M2, which is already overloaded and has a poor accident record.  Any blockage or closure will result in lorries using unsuitable rural roads.
•       Despite the application’s claims of negligible risk, heavy vehicles engaged on construction projects have a poor safety record particularly as regards collisions with cyclists.  The freight access route coincides with the Sustrans National Route 1, frequently used by cyclists. No risk mitigation measures have been proposed.
•       Graveney Primary School is on the access route for site traffic. Children must cross that road to access the playing field. Increased industrial traffic will pose an increased safety risk to these children. Also, increased industrial traffic may disrupt access to the school for staff and parents. 
•       The raised levels of goods traffic will erode the quality of the environment and the quality of life for local people. The associated loss of amenity is unacceptable, whether or not there is residual damage. 
•       We have serious concerns about noise, vibration and air quality. 

Landscape and Visual Impact

•       The proposal would have a destructive impact on this landscape.
•       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 – as will views from footpath ZR478. It is also harmful to distant views, including Wraik Hill.

Socio-economic effects and tourism

•       It is insufficient to limit the tourism impact assessment to Kent or district level. It must be assessed at Faversham area or Whitstable area level.
•       People visit Faversham and Whitstable as historic towns with unusual shops and restaurants, and for their proximity to outstanding countryside and wildlife. The power station would destroy this appeal due to its industrial appearance and scale, and immediate impact on wildlife. 
•       The power station would impact part of a long-distance footpath and a national cycle route. This will deter people from using these for tourism and for amenity. The latter is significant as the population of Faversham is set to increase significantly with proposed housing developments. There will be more need than ever for open space and places to walk and cycle. 

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You have until 11:59 pm on Monday 28th January 2019 to register objections.

The Planning Inspectorate has now accepted the planning application and there will be a public enquiry. Whilst the developer has made some minor changes to the original proposal the Faversham Society's view has not changed.

The Faversham Society enthusiastically supports the development of all forms of renewable energy. We recognise the importance of using wind, solar and tidal technologies for power generation to reduce the use of carbon fuels and meet the UK commitments to reduce levels of greenhouse gasses.  However, we have grave concerns about the negative environmental and amenity impact of the solar power station being proposed at Cleve Hill and across the surrounding marshes. There are alternative brownfield sites available, and distributed generation is both possible and more desirable.

The developer's map showing the extent of the Solar Power Station

Those concerns are:
> Unprecedented scale.
What is being proposed on the outskirts of our town is an extremely large industrial development, as big if not now bigger, than Faversham itself. A development of this scale cannot fail to have a profound negative effect on the environment and reduce the economic and amenity value to those both living in and using the area.

>Site enlargement.
The developers have included a Site of Special Scientific Interest and the seawall, the latter to enable the developer to negotiate with the Environment Agency in order to mitigate the risk of managed retreat on the operator’s assets. (panels, batteries and other industrial plant) This has enabled the developer to now claim that the panels will only cover 55% of the site (as if this in some way reduces their impact) and to include the extra land and the SSSI as part of their calculations concerning the benefit to the environment that they suggest the power station will create. This raises serious issues regarding responsibilities and wider governance.

>Batteries
The developer has not clearly specified what battery technology will be used. This is emerging technology still being developed and tested. It is not unreasonable to have concerns about the health and safety aspects of this new technology. There will be 00mwh of battery storage capacity. The battery storage area will be surrounded by a ~4.6m high bund to prevent flooding.


>Flood Risk
These marshes are a protective floodplain for Faversham. The seawall is currently the responsibility of the Environment Agency and therefore under democratic control. If the Agency were to delegate responsibility to the operators of the site for the flood defences, they would be able to raise the height of the wall at will in order to protect their assets. We have concerns about the impact of insulating such a large area of land from inundation – most particularly on increasing the flood risk in Faversham town – already prone to flooding. The marsh area has long been a coastal floodplain protecting Faversham.

2006 KRUEGER 4.6M HIGH 36 PALLET DROP DECK KURTAINER B-DOUBLE

>The governance of the SSSI
We are concerned that the enlargement of the site puts the future of an important SSSI into the hands of a power company. We know that the way that SSSIs are managed is critical and without oversight, by a public body we are not confident that the incentives of the developer and operator would ensure the long-term protection of the site. The SSSI appears to have been included to assist the developer in increasing the biodiversity of the site merely by acquiring land already managed for diversity.

> The Height of the Solar Panels
The Solar Panels will vary in height up to 3.9 m above ground level and will be dark blue, grey or black in colour. The panels will extend over 176.3399 ha or 436 acres or 218 football pitches.
A Lonon Routemaster is 4.38m high.


This bus is 3.9m high

>Archaeology
The Historic Environment Desk Based Assessment commissioned by the developer reveals that the site and its immediate environs make an important contribution to the historical and cultural setting of the town and that the creation of a large power station – albeit solar – would ignore Faversham’s historical importance and compromise the setting of the town and its neighbouring villages to the north, Graveney and Goodnestone. We have evidence of medieval saltings and of a historically significant duck shoot that would be obliterated by the panels. We have seen no assessment of the damage to the archaeology of the area covered by the site.



>Noise & Disruption
The Faversham Society is concerned about the level of disruption that will occur during construction and continue during the normal running of the power station. Although there is some technical detail, we have seen little intelligible analysis of the cumulative level of noise generated by the inverters, transformers, battery packs and other elements of the energy production process.

>Access & Traffic
This is a very large site that would not only be covered with new solar installations but would also require substantial works to provide the roads, new ditches and the electrical plant – including a substantial compound for battery storage. The Faversham Society is concerned that the roads to the site, in particular, Head Hill Road and Seasalter Road are not suitable for the weight and frequency of traffic required to transport such a high volume of materials and equipment to the site. We are unclear about future responsibilities for road maintenance, repair and general restitution.

>Wildlife
The site forms part of the North Kent Marshes Environmentally Sensitive Area. It is also directly adjacent to the Swale Ramsar site which is designated because it has an important assemblage of bird and plant species. The site will also affect the Swale Special Protection Area and the Swale Site of Special Scientific Interest, the South Swale Nature Reserve and the Swale Estuary Marine Conservation Area and on the opposite side of Faversham Creek, the Oare Marshes Nature Reserve managed by the Kent Wildlife Trust.

>Soil & Soil Erosion
Developers propose to create what they have called ‘grazing land’ under the panels with a mix of grasses and wildflower They propose the grazing of sheep. Even if this were to prove possible, such plans are less than adequate compensation for the loss of such a large, grazing marsh so productive of wildlife.

>Landscape, Amenity and Economic Value
The site forms part of a Kent Area of High Landscape Value and a Swale Area of High Landscape Value. The site is visible from long distances including Wraik Hill on the A299 at Whitstable, from Estuary View, from Boughton Hill on the A2 and from Oare village to the west of Faversham Creek – all which have extensive views encompassing the whole marsh, grazing land, fruit farms and orchards. It is an area of high amenity and economic value.

The Faversham and Graveney Marshes ‘brand’ attracts a large number of visitors – whether interested in history, marine life, birds or general recreational walking – to this part of Swale. Although developers assert that for Kent the impact will be negligible, we have seen no analysis of the short and longer economic impact the development will have on Faversham and the businesses that support and service our visitors.

>Footpaths
The Saxon Shore Way runs along the top of the seawall, and so any walker from Faversham to Seasalter would start by looking along the parallel ranks of solar panels and then as they turn east looking over row after row of panels stretching east to west to the back of the marsh. The monotony would only be relieved as walkers passed gaps for the spine road and the drainage ditches. At the eastern end of the site, walkers’ next view would be the battery compound and sub-station across the grazing marsh. Walking the Saxon Shore Way from the Seasalter Road end, there would be views of the sub-station and other works and across the marsh towards the solar panels extending to the sea wall. New security fencing and surveillance is also expected to be installed along all footpaths which would add to the unsightliness and serve to intensify the hostile industrialised atmosphere across the marshes. The character of all of these well established and much-used footpaths that are part of the Saxon Shore Way would be changed beyond recognition.

>Our Judgement
As we have made clear, this unprecedentedly large solar power station will have a profound negative impact on the people that live in Faversham and the surrounding villages. Although it is these local people who will suffer the losses if this development goes ahead, it appears that as currently conceived, it provides no direct benefit for them either in the short or long term.

That lack of attention to what in other large development schemes would be known as ‘planning gain’, demonstrates the lack of regard or concern that developers and builders of the Cleve Hill solar power station have for the interests of the people of Faversham and the surrounding villages.

We have until 11:59 pm on Monday 28th January 2019 to register objections.

You can commnet here:

https://infrastructure.planninginspectorate.gov.uk/projects/south-east/cleve-hill-solar-park/?ipcsection=relreps

The Society will be registering as an objector. We urge as many people as possible to register their views. This development will fundamentally change our environment and local voices must be heard. Remember that anyone can express a view - it is not limited to one 
representation per household 

There is more detail on the Society views here

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The Planning Inspectorate has accepted the Cleve Hill application for examination. You have one month from Wednesday 19th December to register as an Interested Party.

https://infrastructure.planninginspectorate.gov.uk/projects/south-east/cleve-hill-solar-park/?fbclid=IwAR22m9yGTFT8-2hnb4chifb2RlgViKLDTgUkv551W5KfRiG9s80RW7kRwUg

The Faversham Society made representations back in July

http://www.favershamsociety.info/cleve-hill/the-cleve-hill-solar-park-the-societys-concerns/

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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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