Further to the article posted on Monday 5th February (scroll down), the following is the text of the Association's letter of objection:
The comments given below on planning application 24/00017/FUL, for the construction and operation of a Battery Energy Storage System (‘BESS’) on strongly performing Green Belt land adjacent to the Charlton Lane EcoPark, are from the Lower Sunbury Residents Association (LOSRA).
LOSRA dissociates itself from the impression given in paragraph 1.9 of the submitted PDAS that it supported the proposed development that was presented to local residents on 19 June 2023. Not only did LOSRA attendees express no such support at the time; LOSRA is now strongly objecting to the submitted proposal for the following reasons:
1. The proposal comprises ‘inappropriate development’ within Green Belt under paragraphs 152-156 of the National Planning Policy Framework (NPPF):
The Applicant has therefore put forward a ‘Very Special Circumstances Report’ in order to argue that the application should nonetheless be approved
2. The claimed ‘very special circumstances’ do not justify such approval:
- Whilst the application argues the country’s need for electricity storage in order to manage intermittent renewable generation more effectively, it does not justify using the Sunbury Green Belt site in order to do so.The site is land-locked, with only a single route to the public highway over land owned by others. In spite of claims to the contrary, it is a considerable distance from the nearest Grid Supply point:
- The application points out that a cable route of 2.8km in length is ‘at the end of viability…due to the cost of laying cables long distances’. But the route shown actually measures around 3.5km (on the Surrey CC Interactive Map).
- It is also claimed that the cable route ‘will avoid any major infrastructure’, and yet it has to cross not only the six-lane M3 motorway but also the Staines Aqueduct – twice.
- The land-locked site is also surrounded – by the M3, the Shepperton branch railway, Charlton Village, Ashford Common Water Treatment Works, Upper Halliford’s Birch Grove area and the Charlton Lane EcoPark.
- The application claims to provide ‘support for the rural economy’. This is simply implausible for an operationally unmanned industrial complex on suburban Green Belt with its major components, the 96 battery modules themselves, specified from a Chinese supplier.
- It is also claimed that the proposed development is ‘temporary’, since it will only last for 40 years and then revert back to nature. That is not only both unenforceable and unlikely, but also of no advantage whatsoever to current local residents.
3. If it were to be built, the BESS complex would represent an unacceptable industrial visual intrusion and extensive health and safety risks:
- Although the Applicant has provided no drawings showing the actual appearance of the overall proposed BESS scheme, it is not difficult to imagine what 144 industrial containers laid out in rows across the stated 5.9 hectare site will look like; it would surely be irredeemably ugly.
- It is further stated that the site layout has been amended as a result of advice from the Fire Services and reference to the planning guidance from the National Fire Chiefs Council. This resulted in the battery modules being located further from the M3 motorway in order to avoid the impact of the smoke plume on vehicles in the event of a BESS fire. The site is also required to have 9 large water tanks containing a total of 225,000 litres water to fight the fire. A battery fire is a chemical fire that provides its own oxygen; quenching it requires the provision of huge amounts of water to cool it down over many hours and sometime days.
- Depending on the wind direction at the time, the smoke plume from such a fire, which would contain a range of toxic gases, might not affect the M3 but rather Charlton Village, Upper Halliford, the Ecopark or, most worryingly, the Ashford Common Water Treatment Works. If it were raining at the time then presumably the toxic chemicals in the plume would wash out into whatever lay beneath.
- In a similar vein, the large volumes of water being used to quench such a fire would inevitably pick up those chemicals, most notably hydrogen fluoride, and potentially pass them into the water table should the sump manholes surcharge.
- The ‘Framework / Outline Safety Management Plan’, written by consultants and submitted with the application, might have been expected to provide details of how these fire and other risks would be managed, but it is almost entirely conditional upon the receipt of further information from the Applicant. As such it does not provide the level of detail necessary to make an effective assessment of an intended Full Planning Application.