GREAT Update December 2022



GREAT continues discussions with : 

Helen Whately :

GREAT continues to correspond with Helen and one of the main issues raised is the battery storage facility where we are asking her to support our campaign against it. In her latest email she states the developers are considering the safest method of battery storage.

GREAT will collaborate with the Parish Council and invite Kent Fire and Rescue to a meeting to hear their views on what is being proposed. They have been identified as a statutory consultee by Swale Borough Council so their response to the Outline Battery Storage Safety Management Plan , once published, will be very important.   

The Developers :

GREAT have been attending the Traffic Management Group meetings which started on the 19th October, as provided for in the Construction Traffic Management Plan. These have been held on a fortnightly basis with wide representation , including the School , Parish Council and Swale Borough Council and have facilitated an ongoing dialogue with the developers with an opportunity to deal with questions raised by the parishioners. At the last meeting on 30th November the developers were asked to respond to meetings which had taken place with those near neighbours to the site boundaries and questions were raised regarding the intrusive levels of noise caused by the test piling operations. The developers have confirmed that they are still assessing strategies to minimize noise. This is not necessarily about being a good neighbour , but about the Code of Practice BS 5228 (1&2) : BS 5228 (Noise Control on Construction and Open Sites)

This standard provides guidance to enable compliance with Section 60.  Part 1 of this Code considers basic information and procedures for noise and vibration control, as approved under Section 71.

Section 61 allows the person intending to carry out construction works to apply for consent to operate prior to any activity commencing at a site. The consent must detail the methods by which all noisy activities are to be carried out.

Under Section 72 a contractor must use “Best Practicable Means” to control noise on the site.

We will raise this again in the meeting with the developers this week as we feel that hydraulic piling should be used and so far , this has not been the case.

A question has also raised issues regarding Equality of Opportunities. This may be relevant to sectors of our community and we are currently awaiting a legal opinion on the application of the relevant legislation.  

Swale Borough Council :

We have questioned the lack of engagement with the residents of Graveney and Goodnestone and a written complaint was raised which is currently ongoing. This focused on their inconsistent approach to decision making , including the fact that Swale Borough Council did not have due regard to factual information relating to the Construction Traffic Management Plan – which had been specifically raised with the Case Officer prior to the approval of the Plan submitted by the developers. In addition , there was no clear indication as to how they had taken account of the views expressed by statutory consultees when approving Plans presented by the developers , even when these were at variance with their final decision.  

GREAT has submitted a few questions via the Parish Council relating to the policy commitments of Swale Borough Council to community feedback and also a question asking them to outline what their legal responsibilities are. These questions have now been relayed to a meeting later this week when senior officers from Swale Borough Council will be present.  


The Solar Alliance Campaign :

Solar energy applications are continuing to come in thick and fast across the country. Some of the more recent Nationally Significant Infrastructure Projects ( NSIPs) are concerned with even larger solar arrays and battery storage facilities. There are currently some 11 NSIPs being proposed.

This campaign group enables us to have access to the UKs most eminent battery storage scientists and publications and last week we were also able to secure pro bono advice from a planning expert which we are following up on.


Cleve Hill Solar Park

Update 29 May 2020

The application for Cleve Hill Solar Park has been granted development consent by the Secretary of State.

The decision letter can be read here.

In response to the decision, Cllr Stewart, Chair of the Parish Council, made the following statement:

Please see below the statement which has been issued by GREAT following the Secretary of State’s decision to approve the Development Consent Order for the Solar Park and battery storage compound. Having read through the lengthy decision letter what I find so disappointing is that the Examiners in their recommendations decided that the real and valid concerns expressed throughout the Enquiry on so many different aspects of the development were either largely unfounded , of minor significance , or could be accommodated within the final Management Plans for Construction Traffic and Battery Storage. I am very proud of the efforts which so many people have made in mounting a very credible opposition campaign against the scheme having regard to the significant resources which Cleve Hill Solar Park Ltd had at their disposal throughout the process.

GREAT and the umbrella group which includes The Faversham Society and CPRE formed after the Enquiry have a virtual meeting this evening to review the decision in more detail and consider the options which may now be open to them to challenge this.’

Statement from GREAT (Graveney Rural Environment Action Group):

‘GREAT are incredibly disappointed to confirm that the Secretary of State has yesterday, 28th May 2020, decided under section 114 of the 2008 Act to make, with modifications, an Order granting development consent for the proposal by Cleve Hill Solar Park Limited to build a vast industrial Solar Power Station on Graveney Marshes.

The Secretary of State’s summary is as follows:

The Secretary of State considers that there is a strong case for granting development consent for the Cleve Hill Solar Park. Given the national need for renewable energy infrastructure and the substantial weight the Secretary of State attaches to the contribution of this development to meeting that need the Secretary of State does not believe that this is outweighed by the Development’s potential adverse impacts, as mitigated by the proposed terms of the Order.

Concerns about this development have certainly not gone away. GREAT will be taking stock, studying the modifications requested by the Secretary of State to the proposal and considering next steps with the fantastic team of supporters and experts that have formed this two year campaign. Please keep checking back for further news.’

Update - August 2019
The project is now in the examination stage which means the Planning Inspectorate is in the process of holding hearings and looking at evidence. The deadline to complete the examination is 29th November 2019. The first round of hearings has now finished, but additional hearings may be held from 9th September. Information on deadlines, hearings and all evidence is available from the Planning Inspectorate website here.
To view the submission made by Graveney with Goodnestone Parish Council, please click here.
Update December 2018
One year on, the project has been accepted by the Planning Inspectorate. This does not mean that it will necessarily go ahead, merely that it will be examined and assessed.

All residents and other interested parties are encouraged to register with the Planning Inspectorate here. This will allow you to make representation and keep up to date with progress.
November 2017
The proposal to build Cleve Hill Solar Park was unveiled on Thursday 9th November 2017. Graveney with Goodnestone Parish Council is committed to working with the developers and residents to ensure the best possible outcome. At present, the proposals are in their infancy and we look forward to hearing more as time goes on.

GGPC is setting up a working party to deal with the proposal; residents should have received a letter about this. If you have not and would like to be involved, please contact the clerk. A copy of the letter can be viewed here.

A local resident has set up a website about the proposal. You can visit it here. Please note, this is run independently of the parish council and any views expressed are not necessarily those of GGPC.

You can visit the developers’ website here.
You can see the developers’ briefing document here.
You can see the press release from GGPC here.

Cleve Hill Planning REF 22/503259/SUB - Parish Council Response






Graveney with Goodnestone Parish Council would make the following comments and observations in respect of the Cleve Hill Solar Park - Construction Traffic Management Plan.


We would question the validity of some of the information provided in the Plan as this is based upon details submitted in connection with the London Array sub station which was constructed at the Cleve Hill site some 12 years ago. Since that time the number of vehicles , walkers and cyclists using the local road network has increased significantly. The last traffic survey undertaken by the developers was published back in 2019 at the time of the Planning Inquiry.


Since then there has been a continued upsurge in tourist traffic to Faversham and Whitstable and as a result there has been a proportionate increase in the use of the coastal route through Graveney and Goodnestone. Additionally, in the last few years circa 1,000 new homes have been built in and around Faversham and there is a further circa 3,500 homes shown on housing allocation sites in the Local Plan review. This has, and will continue to substantially increase vehicles using the route through Graveney and Goodnestone. This includes those vehicles looking to avoid the Thanet Way due to congestion at Estuary View and also when there are accidents or other incidents along the Thanet Way;Seasalter Road and Head Hill Road then serve as a diversion route causing extreme congestion in the villages.


 There is clearly the need for an up-to-date traffic survey to give a realistic view of the current vehicle movements which in turn will provide clearer evidence of the impact which the proposed construction traffic will have on the local road network. This should reasonably include business user data which has so far been largely ignored.


The major impact which the Solar Park development will have on the villages has not been fully recognized or respected in the Plan. There is also great concern over the impact of dust, noise, pollution and structural damage which have not been addressed.


In 1.3.2 and throughout the Plan the names of certain stakeholders needs to be amended.

Graveney with Goodnestone Parish Council

Graveney Rural Environment Action Team (GREAT)


In 2.2.3 it now indicates that the development will be built in 4 phases. The original plan provided for 2 phases with an indicative timescale. We find it unacceptable that the current development plan provides no clear indication for local residents as to how long the disruption to their daily lives will last.


In 2.6.1 and 2.6.7 it states that 6 abnormal indivisible loads will be required and these will move through the villages during off peak periods,typically at night. However, there is no evidence in the Plan as to the trailer configuration and Network Rail’s requirement for structural surveys of Graveney Bridge at the pre and post works stages. It is also unclear as to who the ‘stakeholders‘ are and whether this group will include the Parish Council.


2.7.1 suggests that the daily peak traffic volumes quoted in the Outline Plan will not be exceeded. However, the peak durations have been deleted and no indication of these has been provided. This is similarly the case for daily peak HGV movements. We have also calculated that some 500 bulk carrier HGVs will be required to bring materials for the construction of the new internal access roads serving the transformers ( as detailed in the Requirement 2 submission ) and this would represent a significant increase in HGV traffic movements over the period required to create these roads. We strongly challenge the developer’s claims that this falls within the contingency allowance and would like to see the basis of this calculation.


In 3.2.1 the distance of the route from Whitstable Road to the site is 3.4 kms,not 1 km as stated.


3.2.8 suggests that the widths of Head Hill Road and Seasalter Road are between 4.5 m and 7.5 m. These measurements were previously challenged and check measurements taken at the time ranged between 4.2 m and 6.1 m. The developer should be required to provide specific locations where the 7.5 m width was recorded so that these can be validated.       


4.2.2 suggests that,based on OS mapping , there are only 4 places along Head Hill Road and Seasalter Road where a large HGV and large car may experience difficulty in passing each other and a further location where this would apply to two large HGVs. Our local knowledge and experience enables us to identify other areas where similar width restrictions would apply. These include the entire section of Head Hill Road from the Whitstable Road junction to the bend at Poplar Hall; the section opposite Baron’s and Hobbit’s Oasts along Head Hill Road,and the section from Church Lane,Goodnestone to the Langdon Manor Farm entrance. We would also maintain that no account has been taken of further limitations on effective road widths and usage due to overgrown verges and hedges encroaching upon the highway,the presence of cyclists and pedestrians, cautious drivers requiring more space to pass,in addition to the planned and emergency maintenance of the highway and utility services.  We would maintain that at all stated locations,including those which we have identified,it is not possible for an HGV and large car to pass.


 We would also wish to see more extensive restrictions and monitoring in critical areas such as Graveney Bridge,Graveney Primary School,and Head Hill Road between the Whitstable Road junction and Poplar Hall. Furthermore,the developer should undertake revised and current measurements to ensure accurate details are recorded,the Plan updated accordingly and their implications properly considered.


4.2.3 suggests there is good forward visibility in all places where ‘two vehicles may struggle to pass’. This is clearly not the case and we would use the bend by Poplar Hall as a prime example. Once again these conclusions need to be reassessed accurately and expediently , the Plan updated accordingly and the revised implications properly considered. We would also make the point that an HGV will have better forward visibility due to the cab height which a car driver would not have the benefit of thereby putting the drivers at much greater risk.


4.2.12 suggests that in all places identified as not being sufficiently wide for two vehicles to pass safely that there are suitable places along the public highway for vehicles to give way. No specific details have been provided as to the exact locations of these places,but this assumption is completely inaccurate. Apart from road junctions there are no such public areas for vehicles to pull over along the entire route through the villages to the development site. The only ‘available’ places are private laybys or driveways. The developer should therefore be required to detail the areas which they have identified so that these can be properly validated and that the developer provides full assurance that any use of private property has not been inappropriately assumed.


In 5.1 and Appendix D   ‘No access to construction traffic‘ signage should be erected at the Seasalter Road junction with Cleve Hill and at the junction of Homestall Lane with the Brenley Corner roundabout.  As the road through the villages is an important cycling route with a section of Seasalter Road being designated as a National Cycling Route additional signage should be positioned to alert construction traffic to the use of the village roads by cyclists in order to help safeguard them.  


In 5.3 core working hours should be tightly controlled and limited to the hours specified in 5.3.1 without the extra hour provision. We would oppose any variation due to ‘exceptional circumstances’ as this potentially affords the developer too much latitude without any proper checks being implemented.


In 6.4 the HGV movement restrictions stated in 6.4.4 should apply to all vehicles associated with the development to safeguard Graveney Primary school.


In 6.5 HGV omissions are stated as being compliant with Euro Standard IV class. No emission standards are prescribed for other construction vehicles. We would argue that higher emission standards should apply to all construction vehicles in accordance with Euro 6 which was introduced in 2015.


We should also be given information as to the air quality impacts for Graveney Primary School ,the elderly ,and those with respiratory problems. Accordingly ,an air quality impact assessment should be required for monitoring purposes for all vehicles using the development site. Indeed ,having regard to the nature of this development, we would ask why is there no undertaking from the developers to use a meaningful proportion of electrically powered construction vehicles.     


6.6.9 suggests the use of laybys on the Thanet Way for HGVs to wait prior to being called forward to approach the site. However, this is a somewhat optimistic proposal as these laybys are frequently closed by the Highway Authorities and even when they are open, many foreign and UK drivers use them for their rest periods. We would like to understand the plans for the marshalling of HGVs when the laybys are not open and for effective traffic management and communication with the drivers.


6.7.1 suggests that the call forward layby positions have been identified and agreed. However as already stated in 4.2.12 we do not believe there are any such places. We would request that the developer confirms the respective locations so these can be properly validated.


In 6.9.1 a maximum speed limit of 20 mph for all construction traffic should apply to the entire route along Head Hill Road and Seasalter Road as the majority of this route has no public footpath and additionally reasonable adjustments are needed for children as well as elderly residents and those with disabilities.


6.10 We consider the Incident Management Plan to be inadequate. It does not provide any detail as to how incidents which may occur on the site (such as battery fires or other accidents) would be handled. We would also maintain that the installation is a potential target for theft or even terrorism given its strategic significance ,size and accessibility. There is no detail as to how incidents or traffic would be managed with Kent Police ,the Ambulance Service and Kent Fire & Rescue.

We understand that Kent Fire & Rescue will be consulted and are required to approve the design of the battery storage area. However,we believe it is essential for Kent Police to be consulted on security and evacuation arrangements for the villages in the event of a major incident occurring.  


In 7.2 there has been no consultations to date with local groups despite the Plan stating categorically that a Traffic Management Group would be established prior to any construction work commencing. This is of concern to us bearing in mind how advanced the project is and our observation that previous calls from local groups for a meeting with the developers have been ignored.


7.2.3 suggests that Traffic Management Group meetings would be scheduled twice a year. This is wholly inadequate for such a large scheme, particularly given the estimated volume of construction traffic. We believe meetings should initially be held at least on a fortnightly basis so that the impact of the scheme can be closely monitored and appropriate adjustments made quickly and effectively. We note that the London Array project commenced initially with weekly meetings and these were very effective and enabled emerging issues to be dealt with rapidly.    


7.4.2 and 7.6.1 There have been no consultations to date with local groups despite the Plan stating that a complaints management procedure needs to be in place prior to the start of construction. Local groups also need to be consulted on the penalties and enforcement procedures relating to infringements by construction traffic.This is crucially important and must be agreed at the earliest opportunity.


Thanet Way junction with Whitstable Road


The accident rate at this junction is particularly high, given the short slip road and the configuration of the bend. We believe that for safety reasons this should be urgently redesigned to ensure the safety of road users both entering and exiting Whitstable Road. There is every likelihood that HGV drivers who are unfamiliar with this junction coming into conflict with oncoming traffic and the sheer volume of HGV construction traffic will increase the risks significantly. We would ask that the relevant Highway Authority be asked to comment on this specifically.




We would ask that a detailed noise impact assessment be undertaken to cover all planned construction vehicle traffic using the local road network for monitoring purposes.




We have experience of structural damage being caused to properties along the construction traffic route when the London Array development was underway. To safeguard these properties and the interests of their owners there needs to be a comprehensive condition survey of all properties in close proximity to the route before construction commences so that this can be properly monitored and appropriate remedial action taken by the developers at their expense. These properties need to be identified as a matter of priority and their owners contacted.  


Mitigation measures


We feel very strongly that there should be temporary provision put in place during the construction phases for pedestrians and cyclists to be able to pass freely and safely through the villages. This could be achieved by creating dedicated footpaths and cycle routes ,some of which could then become permanent and be seen as a lasting legacy for the community. One initiative which has already been put forward is the Faversham Community Corridor and Solar Cycleway. The Parish Council and other local groups are ready and willing to engage with the developers to establish the appropriate mitigation schemes.




Cleve Hill Planning REF 22/503313/SUB - Parish Council Response






Graveney with Goodnestone Parish Council would make the following comments and observations in respect of the Cleve Hill Solar Park - Detailed Design and Fencing submissions.


Our understanding is that the requirement under Regulation 19 of the Development Consent Order is for Swale Borough Council to only give approval to changes considered to be immaterial and that those changes may not give rise to any materially new or materially different environmental effects. In our opinion the developer has not fully justified the issues which we have identified , nor have they adequately considered their overall impact in the context of the Environmental Statement ( ES).




We would wish to see evidence that there has been no material impact on biodiversity as a result of the changes proposed to the size of the panels and the indicative width reduction between the tables from 10 m to 6 m. We note that the minimum width remains at 2.5 m


We would like to understand whether the changes to the solar array have resulted in any material changes to the height profile of the modules across the site or the distribution of heights across the site.


We would like to understand whether,as a result of the various changes that have been made to the size and spacing of the panels, a revised Glint and Glare assessment has been undertaken.


We would like to understand whether a reassessment of the impact of rainwater run off as a result of changes to the solar array has been conducted.


As the final details concerning the method of piling the panel supports has not yet been determined, we consider that a vibration assessment should be undertaken before any piling works commence to establish whether there will be any detrimental effects on the buildings which may be affected by the piling operations, particularly historic structures.


We seek evidence that the ES conclusions are unchanged due to proposed variations to the solar array.    





It is unclear why the original proposal for the UKPN line to run underground has now reverted to the overhead line running 65 m. There are no ditches on the site which are 65 m wide and there is no mention as to whether this will have any impact on the ES.









We understand that the rationale put forward to increase the height of the bund by 300 mm is to account for potential settlement. Surely this would have been reflected in the original design principles so we would question this design change and the consequential visual impact of a higher bund.


There is no clear explanation as to why the developer would want to change the basis of measurement for the electrical compound from 10 ha to 11.4 ha. We would ask Swale Borough Council to verify that this does not represent any material change to the configuration of the compound and the protection bund.




The material required for the construction of the two new access tracks to the main transformers represents a substantial quantity amounting to 7,728 cubic metres. The developer has acknowledged that this will result in additional lorry movements. However,we would challenge the assessment that these would realistically fall within their contingency allowance for traffic volumes. Our conservative estimate suggests that there could be some 500 extra deliveries by HGVs over a relatively short construction period which we would regard as a material change and could not reasonably be accommodated within a contingency allowance. This would also have a material effect on the assumptions made in the Construction Traffic Management Plan.


We would like confirmation that further assessments have been undertaken to ensure the ES conclusions are unchanged.        





The construction and operation of this compound should be in compliance with all relevant Health and Safety requirements  





We note that the colour of the transformers has changed from RGB Grey 128 to 155. We would like to understand whether there a particular reason for this change.


There has been a notable change in the configuration of the main transformers and their overall footprint which has increased from one transformer extending to 116 square metres to six transformers totalling 267 square metres. We would like to understand the rationale for this change since no comment has been made for this change, nor has any comment been made on the potential impact on the ES caused by this proposed alteration.  



Cleve Hill Planning REF 22/503315/SUB - Parish Council Response






Graveney with Goodnestone Parish Council would make the following comments and observations in respect of the Cleve Hill Solar Park - Surface and Foul Water Drainage submission.


We would ask that Swale Borough Council satisfy themselves that the developer has fully consulted with Kent County Council and the Lower Medway Internal Drainage Board so that all drainage proposals are fully compliant with the requirements and recommendations of these Agencies. This should include the variations and works now proposed to the solar array and new access roads as detailed in Requirement 2 of the Development Consent Order.


We would ask specifically where any excess surface water is going to be discharged over and above the current design limits.


Are there adequate provisions to discharge rainwater run off from the solar panels and internal roads serving the site ? In the event that flooding of adjoining farmland and land holdings occurs, will there be compensation provisions for the respective owners from the developer, together with appropriate mitigation measures to prevent any reoccurrence ?        

Cleve Hill Planning REF 22/502676/SUB - Parish Council Response






Graveney with Goodnestone Parish Council would make the following comments and observations in respect of the Cleve Hill Solar Park – Phases of Authorised Development submission


We would wish to stress the importance of the developer adhering to the specified Phases for the development with any variations communicated at the earliest opportunity to local groups and the community , particularly if this may have a bearing upon the Construction Traffic Management Plan.


We would ask that the commencement date for Phase 3 be determined and communicated as soon as practicable.


We would ask that Swale Borough Council regularly monitors current activities on the site as no construction work should be undertaken until the relevant approvals are in place, particularly in respect of the Construction Traffic Management Plan