By Brian Pain
The installation of the vast array of solar panels is proceeding apace at Cleve Hill, quaintly named as Project Fortress, and the total blanket coverage of almost 1000 acres of the North Kent Marshes at Graveney, an area of international importance to wildlife (home to an estimated 390 species including protected birds such as the skylark, lapwing, marsh harrier and Brent Geese), is now a reality.
It can be still argued that the 800,000 densely packed solar panels arranged in rows up to half a kilometre long with just a 30cm gap between each of them is ill conceived because the panels will effectively kill off the saltmarsh on which it is located, and saltmarsh is a vital element in the fight against climate change as it absorbs large amounts of carbon dioxide. An analogy might be a plan that involved chopping down a forest to build windmills to produce carbon dioxide free electricity.
The Campaign to Protect Rural England (CPRE) stated: “Cleve Hill Solar Park: making money at the expense of the environment in the name of the environment.”
However, the continued strong local opposition is to the proposed huge 700 MW Battery Energy Storage System (BESS) at the heart of the development.
The solar installation does not in itself pose an immediate potential threat to human life but the BESS which would use Lithium Ferro Phosphate (LFP) batteries certainly does.
Cleve Hill Solar Park Limited has yet to be granted permission for the battery installation from Swale, the local planning authority, as they are yet to satisfy the planners that the BESS is safe.
On the Swale Planning Portal submissions in support and those arguing for refusal can be viewed. The application number is 23/5038/SUB: Submission of Details to Discharge Requirement 3 of the Cleve Hill Solar Park Order 2020-Battery Safety, Phase 2.
We have written extensively about the very real and world-wide concerns of the proliferation of these large arrays of lithium-ion batteries. See Faversham Eyes 2, 4, 5, 6, 8, 10 and 11.
Regularly at lithium battery storage facilities there are reports of explosions and very often the release, and sometimes in large quantities, of the highly toxic gas Hydrogen Fluoride.
Dr Alistair Gould, senior partner in Faversham’s largest medical practice has written:
“The toxicity of hydrogen fluoride goes easily through the skin and into the tissues of the body. There it damages the cells and causes them to malfunction. The gas, even at low levels, can irritate the eyes, nose and respiratory tract.
Breathing in hydrogen fluoride at high levels can cause death from irregular heartbeat or from fluid build-up in the lungs. At lower levels breathing the gas can damage lung tissue. Eye exposure can cause prolonged or permanent defects, blindness or even total destruction of the eye. People who survive may suffer ongoing chronic illness.
I am extremely concerned that the potential hazards of such a large BESS pose an unacceptable risk of death or long-term illness to my patients.”
In more sensible countries any large-scale BESS installation tends to be sited in desert areas miles away from human settlements.
In February this year the Swale Planning Committee met to consider the submissions of Cleve Hill Limited regarding whether their proposed Battery Safety Management Plan satisfied Requirement 3 regarding battery safety.
On this chilly evening, some of the many members of the public who oppose the BESS met at Swale House in order to attend the meeting and to give support to Professor Sir David Melville CBE, Bsc, PhD, FInstP, CPhys, HonDsc, Sen MemberIEEE (USA) the Vice-Chair of the Faversham Society and a genuine expert in the field of battery safety who was presenting the argument against acceptance in the pitiful few minutes he was permitted to speak.
Local opposition is vociferous and well informed
Despite the Planners recommendation that Cleve Hill Limited’s Battery Safety Plan should be accepted and dire warnings of financial disaster from some members of the planning committee if they rejected that advice, the majority of the members bravely voted for refusal.
Subsequently on March 1st 2024, Swale Borough Council issued a Planning Decision Notice, it stated:
“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 the event of a fire.
The lack of a detailed emergency plan
The lack of a 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.”
In South Korea battery fires have occured in 23 of the country's 1,490 battery storage installations since 2017
Written submissions from the Faversham Society and the Graveney Rural Environment Action Team (GREAT) are by necessity long, detailed and genuinely authoritative. They include input from Professor Peter Edwards Statutory Chair of Inorganic Chemistry at Oxford University, the late Prof Goodenough Nobel Laureate in Chemistry and the “Father of the Lithium Battery” who didn’t think a mass rollout was wise because of the considerable fire risk. Prof Peter Dobson OBE, BSc, PhD, C Phys, F Inst P, FRCS and Dr Bruno Erasin BSc, PhD as well as Prof Melville.
Their written submissions are summarised at the end of this article.
Cleve Hill Solar Park Limited has now given Notice of Appeal through Pinsent Masons LLP their representatives. Pinsent Masons are a very high-powered international law firm with much experience in advising and representing companies involved in energy projects.
Their Appeal against the refusal by Swale to discharge requirement 3 of the Cleve Hill Solar Park order 2020 is to be presented by Envams Ltd another large organisation with experience in overcoming planning objections.
Envams in their appeal evidence have argued that the provision to on-site water is adequate, the single access to the battery storage enclosure for the emergency fire services is acceptable as they can also use the pedestrian access gates, there is no need for a detailed emergency evacuation plan nor a detailed risk assessment.
All these arguments are strongly rejected by opponents of the BESS proposal.
Pinsent Masons have stated that: “Given the evidence in support of approving the submitted Battery Safety Management Plan, this appeal should not have been necessary. In these circumstances it is appropriate and proportionate for the Council to pay the Appellant’s (Cleve Hill Limited’s) costs of the appeal.”
The potential financial rewards to the owners of the site for having an electrical storage system which would allow them to supply energy to the National Grid at times when the unit price is highest means that they are highly incentivised to employ expensive lawyers and consultants to overcome all reasonable concerns of safety expressed by local residents and groups.
The commonly held assumption by parties attempting to push through contentious planning applications is that most local planning authorities such as cash-strapped Swale will buckle under the threat of having to pay exorbitant costs if they lose at appeal.
However, it would be thoroughly depressing if all reasonable objections to potentially highly dangerous technology, which is well known to be unreliable, can be pushed through planning despite the potential for a major disaster because of the risk to a local planning authority of having to meet possibly massive legal costs.
In the event of a major accident involving loss of life would Cleve Hill Solar Park use their limited liability to walk away from the consequences unscathed?
We await the outcome of the appeal with justifiable trepidation.
THE CASE PUT FORWARD BY THE FAVERSHAM SOCIETY
By Professor Sir David Melville
It is important to note from the outset that the proposed 300MWh Battery Energy Storage System at Cleve Hill is planned, if expanded to its full capacity of 1.4 GWh*, to be one of the largest in the world.
*Eye note 1.4GWh =1,400,000 KWh. Based on average household electricity consumption, this is sufficient energy to supply around 3,500,000 UK households with electricity for one hour
Plan of Cleve Hill site showing its relationship to Faversham Creek and the Swale Estuary
Most other such Grid-Scale BESS are built in remote, often desert, locations well away from human habitation. The Cleve Hill site is uniquely close to local villages, a primary school and the town of Faversham. Given the large number of BESS incidents worldwide there are great concerns locally regarding the safety of the proposed development. Consequently, the Battery Safety and Management Plan (BSMP) has been subject to close scrutiny. Along with the Faversham Society and GREAT it has been rejected as unsafe by local residents, five nearby Parish Councils and finally by the Local Planning Authority. Their decision is the subject of this appeal.
In the view of the Faversham Society, the appeal document fails to provide any addition evidence to refute the decision of the Swale Borough Council Planning Committee (‘’the Committee”) to reject the BSMP and therefore should not be allowed. In our view the appeal claims to present evidence to demonstrate that the four grounds for refusal cannot be sustained and then fails to do so.
It is clear that the appeal simply reiterates statements in the BSMP, all of which were available to the Committee and on which the Committee based its rejection. Moreover, the appeal continues to rely on the advice of the Council’s consultant (Mr Gregory of BST&T), a non-scientist, whom we have previously demonstrated to have a serious conflict of interest.** His advice is therefore insecure. The appeal also falls back on the views of the Kent Fire and Rescue Service who provide opinions which contradict the National Fire Chief’s Council guidelines as well as the advice of Fire and Rescue Services elsewhere in the UK. This renders their advice contestable at best.
** Eye note. A letter to Mid Kent Planning Support from Simon Bell, Counsel to the Faversham Society (available on the Swale Planning portal, as are all documents quoted in this article) raised concerns over the independence and quality of the advice provided to Swale Planners by their consultant BST&T over the safety of the BESS and adequacy of the Safety Management Plan. The letter suggests amongst other things that the advice provided was superficial, depended on the reassurance of the battery manufacturers as to the safety of the battery system and completely failed to address many concerns raised by the Society.
Visualisation of how the area of Cleve Hill may look after the development of the complete solar array (By Jim Bennet)
Further the letter suggested that given that BST&T normally acted for the applicants of schemes such as the Cleve Hill BESS, there was a clear commercial interest in their holding back on critical appraisal of BESS projects in order to show that their consultancy have been instrumental in securing planning approval.
In taking this approach the appeal also fails to address or take into account the expert evidence previously provided by the Faversham Society on the known science and safety aspects of grid-scale Lithium Ferro Phosphate (LFP) BESS. This evidence is based on the expertise of a published scientist in this field, papers published in the scientific literature and the accounts of tens of BESS fire and explosions incidents around the world.
To summarise, in our submissions we have laid out nine specific shortcomings in the BSMP which had not been addressed in the Officer’s paper to the Committee. These reasons were frequently mentioned as concerns by Councillors at the Committee. They are:
The need for measures related to the increased risk of explosions for LFP batteries- These batteries pose almost 100% greater explosion risk.
The need to seek Hazardous Substances Consent.
The use of minimum recommended (6m) container spacing for such a large BESS when there is experience of 23m flames.
The potential almost five-fold expansion of the BESS at some unspecified future date to make it one of the largest in the world.
The failure to consider lessons from previous world-wide experience of BESS failures as required in the National Fire Chief’s Council guidance.
Failure to consider the possibility of simultaneous fires.
Failure to consider or reference the authoritative independent Atkins Report for the Northern Ireland Health and Safety Executive on airborne hazards in order to downplay the risk of potentially lethal toxic fumes in favour of their own cursory analysis – the Atkins report suggests serious health risks in the neighbourhood in the event of a fire or an explosion.
A serious undersizing of the amount of fire water potentially required based on actual fire experience elsewhere – 26 times the approved amount was needed to suppress the much smaller 2020 BESS fire in Liverpool.
Failure to provide full details of the potentially dangerous fire suppression system in the sprinkler system proposed.
The Faversham Society evidence then goes on to address in detail each of the claims of the appeal to the Committee’s four reasons for rejection.
The complete document can be found on the Faversham Society website.
The Graveney Rural Environment Action Team (GREAT) made many similar points but emphasised the following:
Matt Deadman, Assistant Director of Kent Fire and Rescue Services has repeatedly stated that “a fire at Cleve Hill Solar Park is inevitable”.
As this is the largest battery storage proposal in the UK, it represents a key planning decision and therefore depends on full and detailed disclosure of all facts. The BMSP as currently presented is incomplete, misleading and lacks crucial detail.
The BSMP and toxic gas plume dispersal modelling is based on unrealistically small battery fires and does not include any robust safety measures.
The BSMP makes reference to both a Construction Emergency Research Plan and an Operational Emergency Response Plan, but these essential documents are not included.
GREAT point out that it is commonly accepted that it takes 6,000 gallons of water to extinguish one Tesla battery, it is clear that the amount of water proposed for fire suppression is totally inadequate. The site has no access to a body of water and the water pipeline infrastructure itself in this rural area cannot be relied on to provide a consistent and sufficient volume of water for cooling.
Faversham Eye adds:
Unofficial conversations with members of the Kent Fire Services indicate that Fire Officers are insufficiently trained and equipped to deal with a serious lithium-ion battery fire at Cleve Hill and do not have more than a handful of fire engines available to deal swiftly with any emergency especially in the case of likely thermal runaway.
Also, it is understood that the solar farm and battery system will be monitored remotely. There will be no personnel on site to raise the alarm in the event of monitor failure.
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