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EKR KCC/SW/0237/2019 Condition 28 Noise management

The Board of the Faversham Society on 26th November discussed the three conditions for which EKR have made submissions and which are currently the subject of public consultation.

The Faversham Society does not have any comments in respect of the following:

KCC/SW/0249/2019 Condition 53 Complaints procedure

KCC/SW/0248/2019 Condition 47 Landscaping.

However, the Society has concerns about the submission on condition 28 as below:

KCC/SW/0237/2019  Condition 28  Noise management

Condition 28 requires that the monitoring locations of noise generated by the plant reflect the nearest noise sensitive receptors to where the site operations will be carried out. The monitoring period shall be a minimum of two non-consecutive measurements of 15 minutes duration at each location. Noise monitoring shall take place during normal working periods and checked to confirm that the measurements were taken during normal working periods. There is a requirement in the condition to provide written reports to the Waste Protection Authority within one month of the date of each monitoring visit. If noise exceeds the permitted limits, there is a need to set out and implement the steps required to reduce the levels to those set out in condition 27.

There is also a condition about making sure the plant operates at the correct noise levels when it is in operation.

The sensitive sites for monitoring identified by the applicant include Pheasant Farm on Church Road, Oare and the Oare Lakes residential development. At present, the monitoring site for the Oare Lakes development is shown on Ham Road next to the nearest part of Goldfinch Close. There is a process set out for what needs to happen if the noise exceeds the required level involving working with KCC.

These are reasonable locations at present. It is stated that the applicant will move the Oare Lakes monitoring station when the site is completed and occupied. There is no indication where this will be moved to but the nearest houses to the active parts of EKR will be in phase 2 of the Oare Lakes development. The houses in phase 1 which are being built are a lot closer to the EKR plant than the initial location for the sound monitor in Ham Road and some of these houses are likely to be occupied within the next six months or so. It is recommended that KCC should ask for the location of the relevant noise monitor to be moved towards the further end of the present Evers Road as soon as phase 1 starts to be occupied and then again when the houses in phase 2 are built in the extension to Evers Road (or any closes which are nearer to the plant).

Prepared by
Anne Salmon BA  MCD  MRTPI

There has been controversy sparked by the report in the Faversham News.

We were represented at the meeting about the future of 12 Market Place. There was no discussion about selling the Magna Carta. The Society's view is, to quote William Morris, that “We are only the trustees for those who come after us.”

It is not for us to sell the Magna Carta.

The option of loaning the Magna Carta for exhibition for short periods abroad is worthy of serious consideration. This would raise revenue which could be used for heritage in Faversham and it could encourage people to visit Faversham.

This was submitted to the examiners today.

I am fully aware that all deadlines for submission have passed, but the submission below is based on an important recent official document relevant to the several references to the 2012 battery fire in Flagstaff Arizona, that have been made throughout the CHSP Examination. The relevant regulator - Arizona Corporation Commission has recently (2/8/19) published its determination in that matter and in the matter of a more recent  2019 BESS fire and explosion in Surprise, Arizona. Given it's authoritative, definitive and conclusive nature, I am requesting that for completeness this submission is brought to the attention of the Examiners before they make their recommendation to the Secretary of State.

Addendum to Deadline 7 Submission by the Faversham Society to the CHSP Examination Relevant to the Dangers Associated with Lithium-ion Battery Energy Storage Systems
Determination by the Arizona Regulator – The Arizona Corporation Commission: August 2, 2019 RE: IN THE MATTER OF THE COMMISSION’S INQUIRY OF ARIZONA PUBLIC SERVICE BATTERY INCIDENT AT MCMICKEN ENERGY STORAGE FACILITY PURSUANT TO ARIZONA ADMINISTRATIVE CODE R14-2-101. (DOCKET NO.E-01345A-19-0076)


1.Introduction
Throughout the course of the CHSP Examination, the Faversham Society and others have raised serious concerns about the safety of Li-ion Battery Energy Storage Systems (BESS) as evidenced by the incidence of runaway fires and explosions at BESS around the world. All such incidents involved BESS considerably smaller than that proposed by the applicants for CHSP. In our previous submissions and discussions during the examination, one of the more serious BESS fires - the 2 MWh battery fire in Flagstaff Arizona in 2012 was referenced, but at that time no conclusions had been drawn by the US authorities. 


2 Summary of the Determination
Commissioner Sandra D Kennedy of the relevant Regulator -  the Arizona State Commission, has now reported on the incident.
Her full report is here
Her conclusions are of great significance and include:


''The Flagstaff Fire Department report ''....references fires with ''10-15 ft flame lengths'' that grew into ''flame lengths of 50-75 ft'' with fire ''appearing to be fed by flammable liquids coming from the cabinets'' '. This highly significant piece of evidence shows how a fire can spread from one container to another and flatly contradicts the CHSP applicant's assertion that 100 containers are no more of a fire hazard than a single container and that any fire will be contained within a single container.
The Fire Department Report also states concerns about ''a serious risk of large scale explosion'' and ''the cabinets involved are full of lithium (sic) batteries that are extremely volatile if they come into contact with water.''
The Commissioner clearly states:
''Knowing now how easily a fire and/or explosion can evidently occur at these types of relatively small(2MW) lithium ion battery facilities, it appears that a similar fire event at a very large battery facility (250MW+) would have very severe and potentially catastrophic consequences, and that responders would have a very difficult time trying to handle such an incident.'' The BESS proposed for CHSP is even larger at 700MWh.
The Commissioner recommends that any large scale BESS  should be ''built in isolation'' and says ''an explosion could potentially flatten buildings at some distance''. She also draws the analogy that ''a 2MW battery facility is equivalent to 1.72 tons of TNT'' This makes the CHSP BESS equivalent to 602 tons of TNT. This is 1/20th of the TNT equivalent of the Hiroshima atom bomb. Moreover the CHSP BESS is within one mile of Graveney village and two miles of the town of Faversham.
The Commissioner  also reinforces our community's fears about batteries ''with chemistries that include compounds that can release Hydrogen Fluoride in the event of a fire and/or explosion and states clearly that ''those types of lithium ion batteries are not prudent and create unacceptable risks'' Moreover, contrary to the claims of the applicants  the Commissioner reinforces Dr Erasin's evidence stating that ''large amounts of hydrogen fluoride could be released and dispersed that would affect and harm the public at a substantial distance downwind'' and adds that ''There would be concerns about lingering hydrogen fluoride contamination in the affected areas.''
The Commissioner is clear that: ''water should not be used to suppress a fire such as a battery facility...'' - yet this was the method the applicants and their advisors favoured for CHSP.

The Commissioner also lays down stringent requirements for the protection of responders (fire and rescue services etc) to any incidents. None of these has been acknowledged by the proposers or by KFRS.
Given the absence of National Planning Statements on BESS, it is important that the Examination is guided by authoritative sources with experience of BESS projects. We would urge that the attached ACC Determination is the most thorough and up-to-date such source currently available.

3. Conclusion
This Determination by the Arizona State Commission clearly reinforces the view of the Faversham Society and others, expressed in evidence to the Examination, that the risks associated with Lithium-ion batteries are unacceptable at any scale and especially when close to habitation. It is clear that a  proposal for a Battery Energy Storage System close to Faversham, which will be over five times the size of the current largest in the world, poses unparalleled risks and must be regarded as recklessly dangerous and totally unacceptable.
Professor Sir David Melville CBE, BSc, PhD, FInstP, CPhys, Hon DSc, Sen Memb IEEE(USA)
Vice-ChairThe Faversham Society

Is it a roundabout? No.
Is it a traffic island? No.
So what is it?
It’s there at the bottom of Preston Street.

In 2017 the hexagon-shaped traffic island/roundabout/‘thing’ at the bottom of Preston Street looked a mess. No one Tim Stonor spoke to knew what it was for or even when it had been built. Where it had once been home to bollards and signposts, these had since been removed and patched up with dabs of tarmac. What was left was a sorry sight of granite blocks, blue bricks and blacktop. 

There was, quite reasonably, some talk about getting rid of the hexagon: either bricking it over or replacing the remaining granite blocks with tarmac. But it struck Tim that the island was there, that it was unusual, that it seemed to make some drivers pause and think about how they should negotiate it - and that it might perhaps stay. 

So it then seemed that the appropriate and perhaps obvious thing to do would be to restore the island. But given that there was no need for a central lamppost or bollards, the question remained as to what should go in the middle of the hexagon. Tim settled on the idea of a stone or, borrowing from the terminology of the cathedral-builders, a ‘boss’. Whereas bosses are typically seen high up in medieval vaulting, at the intersection of ribs, Preston Street’s boss would sit at ground level, at the meeting of the three brick arms.

What should go on the stone? It seemed the best, most appropriate device would be the crest of the town. The Faversham Society agreed to pay for the stone, and for Clive Sherwood to make it and Faversham Town Council had KCC install it.

If you love Faversham, join us. We seek to Cherish the Past, Adorn the Present, Create for the Future

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

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  • 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 22nd 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. 

The Alexander Centre 
15-17 Preston Street, Faversham ME13 8NZ

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


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

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