The Faversham Society
to Issue Specific Hearing on the Development Consent Order 18 July 2019
have a number of concerns about the content of the DCO and about how compliance
will be assured.
- 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
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.
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.
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?
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?
believe that the DCO should ensure that the batteries installed are subject to
effective and enforceable regulation by an appropriate public authority.
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
The Faversham Society
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