CHSP Examination

Additional submission for deadline 3, following Open Floor 2

On behalf of the Faversham Society

Battery Energy Storage System (BESS)

1. The Faversham Society and others have raised our concerns about the hazards associated with large scale BESS in written submissions. Following Open Floor Hearing 2 at which a number of participants, including the Faversham Society, reiterated these concerns and raised others, we have requested a further ISH on the Batteries and Related Technology and will shortly be sending you an extensive range of questions requiring responses from the applicants.
2. One of the central issues is the lack any National Planning Statements on BESS, and indeed a general lack of guidance, both national and local.
3. The Health and Safety Executive (HSE) has however begun to recognise the need for research and guidance and have established a Battery Safety and Energy Storage Test Facility: https://www.hsl.gov.uk/what-we-do/large-scale-testing-and-evaluation/battery-safety-and-energy-storage
4. In 2016 the HSE initiated an extensive review of BESS - the 3-year  ‘HSE Shared Research Programme: Energy Storage’: https://www.hsl.gov.uk/energy-storage. The focus is on commercial or grid-scale technologies. As far as we can ascertain the results have not yet been published.
5. There is however guidance for the Insurance industry in the form of a Technical Guidance Note from Allianz Risk Consultancy entitled Battery Energy Storage Systems (BESS) Using Li-ion Batteries:  https://www.agcs.allianz.com/content/dam/onemarketing/agcs/agcs/pdfs-risk-advisory/tech-talks/ARC-Tech-Talk-Vol-26-BESS.pdf
6.  At Open Floor 2 we quoted extensively from this detailed publication which concludes ‘BESS using lithium-ion batteries are susceptible to thermal runaway and have been involved in several serious fires in the last few years’. The document recognises the lack of guidelines and highlights current knowledge gaps; describes the loss experience due to BESS fires in Hawaii, Arizona, Wisconsin and Belgium; describes the hazards; and makes detailed recommendation for the planning of BESS in relation to: Fire and Rescue Services; Construction and Location; Material, Equipment and Design; Ventilation and Temperature Control; Gas and Smoke Detection; Fire Protection and Water Supply; and Maintenance.
7.  There is no reference to these crucial safety issues in the application and thee applicants chose not to respond when we raised them at Open Floor 2.
8. The Faversham Society feels strongly that the applicants should be required to respond to these and other questions given that their proposed BESS is subject to all of these concerns and is of an unprecedented scale. Further, we believe these matters are of such importance that they should be subject to thorough investigation in a further Issue Specific Hearing.

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

Vice-Chair

The Faversham Society

Three representatives of Gladman attended a meeting co-organised by St Mary of Charity and the Faversham Society on 16th January. The meeting was well attended with over 170 people braving a cold wet evening to come and hear what Gladman had to say and to question them. The questions covered many topics including traffic, drainage & sewage, disruption to people’s lives, affordable housing and the degradation of Class 1 Agricultural Land. Gladman did say that the pace of house building would be dependent upon demand and that it could take up to 25 years to build the whole development.

It is fair to say that the current plans for 5000 houses are largely conceptual, they have not done the work that the Duchy has done to consult the community and develop their plans. If they are invited by Swale Borough Council to proceed to the next stage, they will begin that work. Gladman has agreed to come back to Faversham at our invitation later in the year to talk about where they have got to and to answer our questions.

Gladman was approached by Saville's to create a concept, a capacity plan, and promote it to Swale Borough Council on behalf of the four landowners. The landowners would hope to sell with planning consent to developers. Gladman recognised the need for new infrastructure but no detailed work has been done. They talked of a high street, surgery, dentists, convenience stores, and the creation of some employment - but emphasised that this would not be a new town to rival Favdersham.

Their promotional prospectus can be downloaded here

The PowerPoint presentation can be downloaded here

• The Solar Power Station is bigger than Faversham. The panels will be 3.9m/12.5 feet high: the height of a double-decker bus.
• Just the electrical compound - the electrical substation and the batteries behind the bund will extend over 10ha - 20% bigger than the Faversham Recreation Ground which is a mere 8.1ha.
• The batteries are unspecified this is an emerging and largely untested technology,
• The Cleve Hill Solar power station will be built over land that has been part of the Faversham floodplain for hundreds of years
• If built, we would have a huge industrial site on Faversham’s doorstep, changing the character of our historic town and reducing the amount of wildlife-rich amenity land available to us - just as the town grows rapidly.

Speak Up

East Kent Recycling Limited has applied for an environmental permit to expand their operation at Oare. You have until Tuesday 22^nd January to comment. As the Environment Agency makes clear concern about increased traffic going to and from the site is not a matter for the Agency, Full details of what the Environment Agency can and cannot take account of is on their site. This is also where you comment
https://consult.environment-agency.gov.uk/psc/me13-7tx-east-kent-recycling-limited/

Helen Whately, our MP, has written to the Planning Inspectorate objecting to the expansion on planning grounds. There are some environmental grounds on which you can object, consider objecting about:

• Noise and odour from the site affecting the neighbours, new housing is planned very close to the EKR plant
• The site is on the edge of an SSSI, a SPA and RAMSAR area.
• Noise and dust already emanates for the site disturbing residents, wildlife and the Saxon Shore Way- The new plant is likely to be  much noisier –an enforceable decibel limit should be included in the permit.
• Many locals have reported seeing discolouration in the lagoon into which the East Kent Recycling plant discharges water
• Light  pollution from the site, already an issue,  will become a more significant issue if the site  is allowed to operate from 05:00 to 20:00 hours

You may also wish to express concern about how much supervision and inspection the Environment Agency will be able to regularly undertake to ensure compliance with the permit if one is issued.  

The Faversham Society is working with heritage and history groups in Swale and our adjacent districts to promote history and heritage to residents and visitors.

There will be a programme of talks and presentationsalongside the stall.  The Fair will beopen to the public and anyone interested in history and archaeology includingthose researching their house, family history, buildings and detectorists. Come along take a stall and show others what you are doing.

The Historic Swale Fair is taking place on Saturday March 2nd 10:00 until 16:00. This is also a Best of Faversham market day and the town will be busy. 

Tabletop pitches (£24) are available to heritage groups and attractions and those engaged in historical research. This is an opportunity to share your work and to engage with fellow enthusiasts, make new connections and build your audience at the beginning of the season.

For further information or to arrange a speaking slot please contact harold@haroldgoodwin.info 01795 532737. PowerPoint will be available. We are looking for “taster talks” of between 10 and 20 minutes on history and how to do history.

To book a stall contact theAlexander Centre on: 01795 591691 or by email: bookings@thealexandercentre.com

For more information about the Alexander Centre https://www.thealexandercentre.com/about

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The government has published a new National Planning Policy Framework.

The Campaign for the Preservation of Rural England (CPRE)  has published research on affordable housing:

60,000 houses being planned for land that will be released from the Green Belt, while the percentage of ‘affordable’ homes built continues to fall

The Green Belt remains under severe pressure, despite government commitments to its protection, according to a new report from the Campaign to Protect Rural England (CPRE).

CPRE’s annual State of the Green Belt report [1] highlights that there are currently 460,000 homes being planned to be built on land that will soon be released from the Green Belt [2]. Moving Green Belt boundaries when reviewing local plans makes it easier for local authorities to release land for housing, but is only supposed to take place under ‘exceptional circumstances’. This strategic shrinking of the Green Belt, as a way of getting around its protected status, is as harmful as building on the Green Belt itself.

The report also demonstrates that building on the Green Belt is not solving the affordable housing crisis, and will not do so. Last year 72% of homes built on greenfield land within the Green Belt were unaffordable by the government’s definition [3].

Of the 460,000 homes that are planned to be built on land that will be released from the Green Belt, the percentage of unaffordable homes will increase to 78%.

CPRE warns that this release of land looks set to continue, as one-third of local authorities with Green Belt land will find themselves with an increase in housing targets, due to a new method for calculating housing demand. The London (Metropolitan) Green Belt will be the biggest casualty [4].

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Dear Sir/Madam,

I am writing to you to inform you of our upcoming Phase Two community consultation for Cleve Hill Solar Park, to update you on how our proposals have developed and to invite your feedback on this. Please see the enclosed Community Consultation Leaflet for the latest information and details of our consultation process.

Our formal Phase Two community consultation will begin on Thursday 31 May 2018 and end on Friday 13 July 2018.

In this consultation leaflet, we would like to draw your attention to the Phase Two consultation event dates. These are as follows:

• Wednesday 13 June from 4.30pm to 7.30pm at Ferry House Inn, Harty Ferry Road, Harty, ME12 4BQ
• Thursday 14 June from 1.30pm to 8pm at Graveney Village Hall, Graveney, Faversham, ME13 9DN
• Friday 15 June from 11am to 4pm at Seasalter Christian Centre, Seasalter, Faversham Road, Whitstable, CT5 4AX
• Saturday 16 June from 11am to 5.30pm at Faversham Guildhall, 8 Market Place, Faversham, ME13 7AG

Our consultation events will give you the opportunity to view our full suite of consultation materials on the detailed proposals for Cleve Hill Solar Park. These consultation materials will include:

• Copies of our Preliminary Environmental Information Report (PEIR) on display
• Copies of our non-technical PEIR to take away
• Display boards of the latest project information
• Photomontages showing visualisations of the proposals from various viewpoints
• Plans for improved local amenities including additional permissive pathways and a community orchard

All of our consultation materials will also be available to access online via our website: www.clevehillsolar.com from 31 May. Further, from 31 May you can also view the consultation materials at our Community Access Points (CAP sites), details of which are on our website.

When you have had the opportunity to view our full suite of materials, we’d encourage you to complete our feedback form which will be available to complete from this link from 31 May 2018. Please note the deadline for feedback is Friday 13 July 2018.

In the meantime, if you have any questions or queries, please don’t hesitate to contact a member of the project team at the details below.

Kind regards,

Hugh Brennan

Managing Director

For and on behalf of Cleve Hill Solar Park Ltd

Freepost: Cleve Hill Solar

T: 0800 328 2850

E: info@clevehillsolar.com

W: www.clevehillsolar.com