A SUBMISSION BY GRAVENEY WITH GOODNESTONE PARISH COUNCIL TO SWALE BOROUGH COUNCIL IN CONNECTION WITH THE APPEAL LODGED BY CLEVE HILL SOLAR PARK LTD – APP/V2255/3343902 AGAINST THE REFUSAL OF THE BATTERY SAFETY MANAGEMENT PLAN - REQUIREMENT 3 OF THE CLEVE HILL SOLAR PARK ORDER 2020
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.
Summary
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.