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 It is assumed to apply to existing,  safe technology which may be superseded during the course of a development.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.