CHSP Battery Safety Management Plan Final Document - June 2024




The battery storage plant proposed for construction at the Cleve Hill site will constitute one of the largest thus far created anywhere in the world. It is therefore encouraging to see many of the controls in both construction and operation that have been described reasonably extensively within the plan.


However, we draw your particular attention to the following points:


·         A variety of changes have been made to the proposals including the construction of the battery storage containers, capacity and indeed the fundamental battery chemistry itself. These changes have been made beyond the time at which some of the parties consulted, specifically on matters of safety and logistics, have responded. It is therefore obvious that their comments and recommendations are at risk of being incomplete or even inaccurate as a result.

·         It is astounding that HSE have broadly failed to input on this matter. Their site has comprehensive advice on various aspects of battery safety aimed at the residential consumer and linked to the various lithium-based technologies. One can only assume that the sheer scale of this proposal simply falls outside of their skills and experience.

·         The site will go through a set of transition states during its evolution to operation and beyond. With such precipitous risks, the adequacy of the safety controls and measures at each stage must be quantified and assessed. We do not believe this is anything other than a highly complex task and, further, we do not believe that the data contained in the proposed plan or that supplied to the consultees (e.g. KFR) is adequate to enable these matters to be appropriately or fully considered.

·         To these points then, it must be considered that perhaps the risk of a catastrophic safety event in this colossal battery concentration is small. However, it must equally be fully accepted that the consequences of the crystallisation of such a threat undoubtedly risks loss of life, a very significant profile of injuries and profound and extensive environmental consequences, to say nothing of the colossal media interest and political damage that would undoubtedly follow.   


We fully accept that there are commercial consequences to the developer resulting from any delays in their plans, howsoever caused, and that this will naturally create tension and pressure simply to approve the proposals. Nevertheless, we cannot support an approval which does not appear to have fully considered all risks, nor properly and fully mapped out the mitigants and, particularly, the impacts, plans (including their logistics and constraints) in the event of an emergency.  


Where any of the consultees have unanswered questions, especially on matters of that may pertain ultimately to human safety, it is clearly imperative that time, resources and expertise must be brought to bear to resolve them completely and satisfactorily in full consideration of prevailing data. 


This in our view, has yet to happen and we therefore urge you, in the strongest possible terms, to withhold approval pending their full and appropriate evaluation.




Other points of consideration (with references, in order, to sections of the plan noted where appropriate).

You will have seen the report submitted by Professor Sir David Melville. In this well-structured summary, he echoes our comments on the changes that have been made to the plan, the need for further considered expert input based upon the current plan and complete (rather than partial) data, and cites a number of examples of the potential consequences to human life and the environments caused by lack of rigour, measures or planning on very much smaller installations. 

We are in possession of a report prepared for the Sunnica Energy Farm in Australia, submitted by Dr. Paul Christensen (Lithiumionsafety Ltd) on 3 December 2022. This draws out some of the balance of risk to be considered when using LFP battery chemistry which is more helpful in the deliberations of the Cleve Hill plans beyond the simple sentiment that ‘LFP is safer than Lithium Ion’.   Whilst this may be true macroscopically, it’s findings and recommendations should certainly be brought to bear in this application and we trust they will be properly considered.


7.  350 MW should equate to 700 MWh , not 1400 MWh. We assume a typographical error.


9.  As referenced above, the comments submitted by KFRS are limited by the absence of significant information and documents. They have requested these from CHSP, whilst enquiries have been made, we have not yet received confirmation that these have been forwarded, analysed and responded to. With the time remaining, it is obviously crucial to ensure that evaluation of critical areas of safety have not been compromised by inadequate submissions from CHSP on these matters.


10. The absence of a comprehensive response from HSE is very troubling. If, as we suspect, it simply falls outside of their remit and expertise, it further strengthens the case for you to seek appropriate and independent counsel on the range of matters that fall within this plan so that you can be fully and independently assured that the safety issues have been fully mitigated using the latest thinking and that emergency planning has been properly thought out and will be fully tested and effective.


13.h  We note that CHSP will need to apply to SBC as the Hazardous Substances Authority for consent.

15.   It is hard for us to determine that the critical steps and project stages identified for Li-ion (originally proposed) are still appropriate and wholly interchangeable for the proposed Li-iron phosphate (LFP)?  We would welcome assurance that any changes have been challenged and accepted.

19.a.iii. We are aware of course of the meteoric rise of the Chinese battery firm CATL and it is therefore of little surprise to see them as the proposed supplier of the batteries for this development (section 19.a.iii). However, we are troubled by the emerging stories of the use of slave and child labour in their manufacturing processes. We are of course protected in this country to a large extent by the 2015 Modern Slavery Act, but we feel it would be disingenuous of us not to raise the concern that, as your own ESG Policies evolve, you would surely not wish to support a proposal where there are significant questions in the ethical standards applied by a major manufacturer in the supply chain.


19.c.i. There are various issues regarding spacing, particularly in view of guidance from the Fire Authorities. Examples include the power conversion system blocks being only 3m from the containers and the separation distance from the containers to other facilities being 20m. In light of guidance from the Fire Authorities together with concerns noted on within the other reports submitted, we strongly recommend a thorough review of spacings, considering both planning requirements but additionally served by practical examples and emerging data. 

19.c.ii & e.ii.  We were alarmed to see such clear examples noted in Professor Sir David Melville’s summary about adequacy of onsite firewater provisions. These would imply that those within the plan would be wholly inadequate in the event of an emergency. Whilst we acknowledge that the volume of water proposed may meet the current recommendations, we would point out that experience of using this technology at scale is still very much emerging and that real world examples suggest strongly that this volume will be grossly insufficient.  It is therefore vital that this topic is properly assessed using current data and experience; the discovery that provisions are inadequate during an emergency would obviously prove catastrophic.

24.  The assessment of risk of potential break-in for theft, curiosity or terrorism is unknown to us but should obviously be properly considered, especially given the remoteness of the site. This section of the report proposes simple palisade fencing and is shown as being 2.4m high. We believe this will be hopelessly inadequate in terms of both height and structure to provide any realistic deterrent to malicious break-in and requires a far more appropriate solution with a very significant step-up in security measures required.

26.  We are deeply concerned that, despite the guidance provided by KFRS, it appears that CHSP has disregarded it and there is thus still only one roadway proposed for access/egress from the site. In the event of an emergency, we believe that this commercial saving is wholly ill-advised and a potential compromise to safety. Logistical constraints will inevitably be a direct consequence of this reduced access/egress.

27.  Linked to points 19.c.ii & e.ii above, water tank capacity is based upon usage of 1,900 litres per minute for 2 hours which accords with the KFRS guidelines. However, Professor Sir David Melville’s report cites a number of examples where such a low limit proved totally inadequate in real fires in other battery storage facilities.   We strongly advocate further assessment on this crucial point of safety to be fully assured that the capacities and flow rates are adequate, based upon real case data.

34. - 36. The specification of SLA’s, response times and resolution times is extremely vague. This section needs to be set out clearly and quantitatively and further set out the human resource plans that will ensure the timeliness of response and on-site resolution where required. Simply listing out some of the monitoring attributes by itself gives us no confidence that the delivery of the services in very controlled timescales has been properly planned.

53.d  Makes reference to ‘local emergency services’. As at the time of writing, there is no Construction Emergency Response Plan and this entire section talks about a set of things that will be done. This is a crucial component to the response to any emergency and we cannot therefore see how the plan in it’s entirety can be signed off when this section remains so qualitative and unplanned.

60.  There is reference to Fire Marshalls on site on a 24/7 basis between delivery of the battery modules and commissioning of the automatic fire detection systems (FDS). What is meant by the temporary installation of FDS in each container during this period? What are the transition states and how will this aspect of safety be managed in each of them.

88.b.  As per point 53.d. above, there is presently no Operational Emergency Response Plan that we have seen. It is simply unfathomable that the safety plan could be signed off without a very detailed Operational Emergency Response Plan being published and scrutinised for adequacy.

114 & 115. Does the ‘two enclosure’ scenario cover adjacent or separate enclosures? Some risks have been excluded from evaluation here. The only explanation is that ‘it is considered that’ such an event won’t happen. The evidence provided by true experience appears to contradict this hypothesis. Without full, independent expertise challenging these assertions, we feel the risk that the developer’s assertions may inappropriately be considered sufficient.

118. The maximum area of exceedance of Acute Exposure Level Guidelines (AEGL) is stated as being 29 metres in terms of airborne pollution. The Hoare Lea report suggests otherwise.


122. In view of the comments made in 118 above, we would question whether AEGL limits would not be exceeded at Crown Cottages.


125 – 130. Each zone has its own penstock outlet for firewater run off. What is the capacity?  At the Battery Storage presentation meeting with Graveney Rural Environment Action Team (GREAT) and the Faversham Society, David Fisher pointed out that these tanks could provide an additional source of firewater until it was pointed out to him that this is actually contaminated water.



Of the various plans that fall within the scope of this DCO, the Battery Safety Management Plan is clearly the most technically demanding – but it is also the one that carries the risk of precipitous impact to human life and the environment should a material risk crystallise. 

Battery technology is changing and advancing at reasonable pace; indeed, a number of characteristics of this plan have been changed, including the battery chemistry itself. Data and evidence points are emerging about the real-world consequences of inadequate safety plans and these learnings must clearly be considered, requiring the highest level of specialised technical expertise and input in order to fully evaluate the suitability of the safety measures proposed. We are aware that, to date, some of this data has yet to be provided to the consulted experts that have requested it and this will undoubtedly have had a bearing on their considerations. 

We urge that proven safety of the community, its habitants, wildlife and environment are the paramount factors in the decision-making process together with realistic and very thorough plans that would be put into execution should a major issue occur. These requirements must be placed higher than either timescale or cost.

This project is almost unique in that it combines the proposal for a very large battery storage facility close to human population.
You will undoubtedly be aware that many of the houses in the village including the Four Horseshoes Park for retired people, caravans for the >1,000 migrant farm workers and the many historic properties are obviously not equipped to exclude toxic gas simply by ‘staying indoors and shutting the windows’ that being the advice proffered by KF&R.

The road infrastructure surrounding Cleve Hill is inadequate to support a simultaneous evacuation of the village competing with the arrival of emergency services without both investment and careful planning.

There isn’t an ill-formed evacuation plan – there is just no evacuation plan, but of course in the event of an incident an attempted evacuation will obviously take place out of the 3 little village lanes that connect Graveney to Faversham and Whitstable, where human nature and fear will obviously triumph over KF&R advice.

We are grateful to Swale for consulting with KF&R and a battery expert. We are also aware that Cleve Hill have been co-operative and that some aspects of safety and battery spacing have met prevailing requirements.

It is very clear that the key risk in this entire development is the battery storage facility – and a well known alternative of simply extending the solar array, is available.

The responsibility of the Parish Council is to the village, its population and its children. The village is extremely anxious and worried. The plans to communicate an incident to them or to help them escape or survive do not exist. 

Simply put, the villagers believe they are clearly being treated as the acceptable collateral damage at the altar of ESG ambitions and developers’ profit margins.


Pending the above, we therefore object, in the strongest possible terms, to the discharge of these requirements.

GREAT Update June 2024



Swale Borough Council Planning Committee refused approval of the Battery Safety Management Plan – Requirement 3 of the Development Consent Order (DCO) on 28 February, for the following reasons:

“The Battery Safety Management Plan fails to demonstrate that risks to public safety have been adequately assessed by virtue of a lack of on-site water storage capacity; insufficient access to the battery storage enclosure in the event of a fire and the lack of a detailed emergency evacuation plan and risk assessment, and as such the proposal would be contrary to Bearing Fruits 2031 - The Swale Borough Local Plan 2017 and the National Planning Policy Framework.”

On 10 April 2024, Cleve Hill Solar Park (CHSP) submitted their appeal to the Secretary of State for Energy Security & Net Zero, stating:

“In summary, there was simply no independent evidence before the Council to support the decision made. To the contrary, the evidence supported approval of the BSMP. The Council’s planning officers recommended the BSMP for approval. The BSMP also had the support of the Council’s retained battery safety expert, Mr Paul Gregory, of Battery Safety and Testing Consulting (BST&T), and Kent Fire and Rescue Services. The Health and Safety Executive raised no objection.”

The Appeal start date was 15 May and the Secretary of State advised that only representations from CHSP, Swale Borough Council, Kent Fire and Rescue and the Health and Safety Executive would be allowed. However, they confirmed that Swale Borough Council could include submissions from the Parish Council, GREAT and The Faversham Society. These submissions were made by the deadline of 30 May. 

CHSP submitted their response to these submissions on 13 June, which was also the last day for any comments to be submitted, so there was no opportunity for us to respond.

All submissions can be viewed at 23/503812/SUB | Submission of Details to Discharge Requirement 3 of The Cleve Hill Solar Park Order 2020 - Battery Safety, Phase 2 | Land At Cleve Hill Graveney Kent ME13 9EE (

The Department for Energy Security & Net Zero confirmed Kent Fire and Rescue Service did not provide a response or representation, and the Health and Safety Executive (HSE) had no comments to make.

There is no deadline for the decision to be made. We will provide an update once that is received.


Cleve Hill Solar Park Newsletter - June 2024

Update from GREAT - April 2024

April 2024

UPDATE FROM Graveney Rural Environment Action Team (GREAT)

We are now in our 6th year of active campaigning. The highlight of the last year was the refusal of the BESS and knowing that, following some National Planning Appeals, it is not completely impossible to win an appeal.

We continue to report to the Parish Council at each meeting.

GREAT  is very grateful to the following organisations, experts and individuals who have shared their knowledge and expertise freely with the villagers in Graveney and Goodnestone:

·         Professor Sir David Melville CBE, BSc, PhD, Hon DSc, FInstP, Sen Mem IEEE(USA) Vice-Chair, Faversham Society. (Sir David is a Faversham resident and GREAT has been very fortunate to count on his local and expert knowledge)

·         Professor Peter Edwards who is the Statutory Chair of Inorganic Chemistry at Oxford University, and assisted Prof Goodenough, Nobel Laureate in Chemistry and "Father of the Lithium Battery". Prof Edwards says his Oxford predecessor didn't think a mass rollout was wise because of the considerable fire hazard. Daily Telegraph 24/11/2023 "We must put a stop to the electric vehicle revolution - before someone gets hurt." "Lithium-ion batteries are unsafe, so why are we pushing on with the EV revolution regardless?"

·         Professor Peter J Dobson OBE, BSc, MA (Oxon), PhD, C Phys, F Inst P, Member of the ACS, FRCS. Dr Bruno Erasin BSc, PhD.

·         Swale Borough Council

·         CPRE

·         Solar Campaign Alliance

·         Helen Whately MP

·         Last but not least – the Parish Council

The main actions undertaken by GREAT during the year include:

·         Detailed responses to the Management Plans, which were shared with the community. Sessions and support for villagers to put in objections to the BSMP which resulted in more than 100 objections from individual residents

·         Contribution to the PC and Faversham Society’ s inputs at the BSMP planning Meeting

Our Mantra which we have re-inforced at every opportunity:

At the 2021 Energy Storage Summit, the Deputy Fire Safety Commissioner of the London Fire Brigade, Charlie Pugsley stated that : "If you've got foreseeable events or got systems with the potential to either harm people or harm the environment, why would you not want to apply a retrospective look to it, to actually see that it's safe, or anything can be done."

He further stated that the London Fire Brigade has spent the past few years "reflecting on what was foreseeable" since the tragic Grenfell Tower fire at a high-rise housing unit in 2017, which was exacerbated by the building's flammable cladding: "If we know some things could fail catastrophically or it could have those effects," he said, "it's going to be a difficult day if one of us is standing there in Court saying we knew about it but we didn't do anything."

·         Attendance at fortnightly Traffic Management Group meetings and actively highlighted deficiencies in the Construction Management Plan.

·         Active Campaign to re-instate the Golden Hour

·         Active campaign to stop all day concrete transport  

·         Continued to update the GREAT website and Facebook pages.

·         Campaigning against light pollution – which is ongoing.

·         Raising concerns about water pollution with relevant statutory bodies and supporting 1 near neighbour whose garden has been totally flooded

Challenges :

·         Difficulties in communicating with Swale Borough Council following the loss of a number of senior planners who left the Council last year and the refusal of the BESS, which was recommended by the Planning officer.

·         Preparing for the inevitable appeal.


GREAT in collaboration with the PC have also been committed  to supporting the village in their objections against the 2 Skylark sites and this has resulted in many objections from residents.

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 Solar Park - Update






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