The Rt Hon Alok Sharma,
Secretary of State for Business, Energy and Industrial Strategy,
1 Victoria Street,
London SW1H 0ET

Secretary.state@beis.gov.uk

Dear Secretary of State,

The Faversham Society has close to a thousand members concerned to conserve our heritage, our culture, our natural heritage and our built environment. We were initially conflicted about our response to the Cleve Hill development. We support renewable energy but saw the solar ‘farm’ as damaging our heritage and industrialising a large part of the rural hinterland which defines our market town. Our local MP Helen Whately and our parish, town and borough councils also strongly oppose the proposed development

The Faversham Society supports the government’s green priorities, and we support green growth. However, this development will create very little, if any,  local employment. We are dismayed that hundreds, potentially thousands, of new homes are being built around our town with no renewable energy and little attention to water efficiency. We have engaged intensively with the Examination and the more we have learnt about the proposal, the more implacably opposed to it we have become.

Before Covid-19 struck, 64 people had signed our petition before we placed it online. The online petition has at the time of writing been signed by 4,079 people. We regard this as a significant achievement in a small market town, without the benefit of engaging people in our market place or holding a public meeting which had to be cancelled.

We have a number of serious concerns; this is dirty solar, and the proposal should be rejected.

• Degraded Land: We remain unconvinced that it is necessary to construct the development on the Graveney Marsh – there are brownfield sites with grid connections previously occupied by decommissioned power stations. Leakage of heavy metals from the solar panels and Lithium compounds from the batteries will degrade the land and the debris of panels, steel piles and batteries will be left to be removed in forty years. By then the solar power station will have changed hands many times, and, in all likelihood, the company that owns it at the end of its productive life will be dissolved leaving the public purse to clear and remediate the land.
  
  
• Environmental Opportunity Cost: In our Deadline 7 submission, we challenged the need for this development.  We have seen no evidence that it is needed to meet National Grid requirements, nor that the construction needs to be on land which would, on environmental grounds, better be reinstated in the Environment Agency’s plans for managed realignment.The Environment Agency’s proposal (in its draft Medway Estuary and Swale Strategy, MEASS) to allow over 200 hectares of the site to revert to tidal saltmarsh via managed realignment would have multiple and profound benefits not only via improved wildlife habitat but also in the form of other ecosystem services including carbon sequestration, coastal protection and provision of nutrients for marine organisms.  By its own admission, the alternative site to Nagden Marsh that was adopted by the EA in the final version of the MEASS – Chetney Marsh – is not suitable for managed realignment because of the presence of nationally-critical infrastructure so has been earmarked instead for the lesser intervention of “habitat adaptation.”  The opportunity cost of deferring managed realignment at Nagden Marsh by at least 40 years is therefore substantial.  Saltmarshes constitute the second most valuable ecosystem for humans after coral reefs, providing benefits to society valued in 2014 at just under US$193,000 per hectare per year – i.e. roughly £30m every year for Nagden Marsh.
  
  
• Rising Sea Levels: The proposed site is below sea level and protected by a sea wall. Recent high tides have come close to overtopping the sea wall along Faversham Creek. It is absolutely inevitable that the developers will need to raise the levels of the sea wall at some point over the next 40 years if the project goes ahead, at the cost of tens, possibly hundreds, of millions of pounds and thousands more HGV movements along country roads through rural communities.  The carbon footprint associated with that, as well as with the concrete footings for the solar panels and BESS, make a total nonsense of the developer’s claim that Cleve Hill will be a source of cheap, clean energy.
  
  
• Health & Safety: We share the concerns expressed by Dr Alastair Gould, Senior Partner at Newton Place Surgery in Faversham on behalf of the whole practice, about the fire risks associated with lithium-ion batteries and the toxicity of hydrogen fluoride. In the event of a fire and explosion, these hazardous fumes could easily reach densely populated urban areas in Faversham, Whitstable and Canterbury. We note that Arizona has halted the deployment of large BESS on safety grounds. Please think very carefully about your responsibility for approving a development based on emerging, untested and potentially very hazardous technology.
  
  
•  Security and Terrorism: Its significant size and potential for terrorist bomb attacks resulting in a subsequent explosion with the intensity of a small nuclear bomb make the CHSP BESS a major security risk. The applicants in their denial of fire and explosion threats have failed to plan adequate security measures.
  
  
• Industrial Scale: The sheer scale of the development with nearly one million panels the height of a London double-decker bus and 200,000 steel piles over an area the size of Faversham will industrialise a natural landscape of considerable value for recreation, tourism, and wildlife.
  
  
• Traffic: We are concerned about the impact of the construction traffic thundering past the local primary school for over two years, causing pollution and disturbance in addition to the road accident risk.  There will be up to 80 heavy goods vehicles per day passing Graveney School within metres of the school playground and classrooms.  That is one lorry every 6 minutes during construction, and there will be many traffic movements associated with site maintenance when construction is finished. We know from experience with other planning restrictions on lorry movements locally that they are unenforceable.
  
  
• Wildlife: The site sustains thousands of migrating birds recognised as providing essential feeding and nesting ground for many threatened species, including Brent geese, reed-buntings, nesting skylarks, and marsh harriers. RSPB and Kent Wildlife Trust recognise it as providing important connectivity and habitat between the sites already protected.
• Cultural Landscape: The proposed development affects two medieval settlements and will dominate the entrance to Faversham and Oare Creeks undermining heritage and tourism regeneration in Faversham and Oare. These green development opportunities would create employment for local people and revenue for local businesses. The development threatens a significant part of our green growth development strategy for the town.
  
  
• Recreation and Tourism: The marsh has long functioned as a green lung for the town, the more so during the lockdown with many more people discovering and using it. The coast footpath and the views from it are an important recreational and tourism resource.

Many of our members have copied me in on letters which they have sent to you urging you to think carefully about your decision on this application as you weigh the benefits of solar generation against so many negative impacts. If you do decide in favour of the project, the DCO must provide Swale Borough Council with the means to enforce it effectively. The applicant should not be enabled to use the Rochdale Envelope and the threat of litigation to bully the LPA into consenting at the final planning stage.  We outlined the minimum necessary conditions and processes to achieve this in our submission in response to your request of 3 April 2020.

We urge you to reject the proposal recognising that on balance, the benefit of solar generation is outweighed by its negative impacts and the safety and terrorism risks inherent in the battery complex.

Yours sincerely

Professor Harold Goodwin

Chair, Faversham Society

cc Kwasi Kwarteng  Minister.Kwarteng@beis.gov.uk
Helen Whately MP