Proposed battery facility at Crabb’s Green.
POINTS TO MAKE IN YOUR OBJECTION
Points for you objection are grouped under 12 headings.
We suggest that you choose between 2 and 5 of these points as the focus for your objection. You can select as many of the detailed bullet points as you like.
Feel free to expand on them!
1. The proposed application is contrary to the overarching policy on development in Stocking Pelham;
2. The Visual Impact of the proposed scheme will be unacceptable;
3. The Landscape & Visual Impact of the proposed development cannot be satisfactorily mitigated;
4. The impact of the development on listed buildings is unacceptable;
5. There will be a negative impact on users of footpaths;
6. The proposed access arrangements for construction traffic are not suitable;
7. The noise which will be generated by the BESS is unacceptable – insufficient information has been provided;
8. The risks of a fire & explosion have not been considered and cannot be adequately mitigated;
9. There is insufficient mains water to deal with a fire at the site;
10. This application should not be considered in isolation. It should be assessed in conjunction with the prospective application to build a solar farm adjacent to Violets lane in Furneux Pelham;
11. There has been no consideration of the loss of high quality Agricultural Land. An assessment of the land classification is needed; and
12. A BESS is NOT a source of renewable energy – it is a standalone industrial development
See below for more detail on each of these areas.
1. The proposed application is contrary to the overarching policy on development in Stocking Pelham
Stocking Pelham is classified by East Herts DC as a “Group 3 Village” for the purposes of assessing planning applications. The relevant local plan policy (Policy VILL3) states that all development should:
(a) Relate well to the village in terms of location, layout and connectivity;
(b) Be of a scale appropriate to the size of the village having regard to the potential cumulative impact of development in the locality;
(c) Be well designed and in keeping with the character of the village;
(d) Not represent the loss of a significant open space or gap important to the form and/or setting of the village;
(e) Not represent an extension of ribbon development or an addition to an isolated group of buildings;
(f) Not unacceptably block important views or vistas and/or detract from the openness of the countryside;
(g) Not be significantly detrimental to the amenity of neighbouring occupiers.
The proposed battery scheme does not comply with Policy VILL3.
2. The Visual Impact of the proposed scheme will be unacceptable
The proposed acoustic barn is absolutely enormous. It will not integrate into the rural context – particularly as the rest of the site will contain cabinets or containers (yet to be disclosed). This is contrary to planning policy VILL 3.
The proposed materials to be used in construction of the “barn” (e.g. Box Profile Metal Cladding and Metal Roller Shutter Doors) are not in keeping with the rural setting. They are appropriate to industrial distribution centres – not rural outbuildings.
The design of the proposed development is sketchy at best. It is not possible to work out what the development will look like from the information that has been submitted.
If approved, the development would cause harm to the character and appearance of the area as a result of the loss of an area of open land and from the presence of industrial like structures and retaining walls, particularly during the winter months.
The proposed development would be visible from the footpath that runs along the South of the site, from Crabbs Lane itself, from the open countryside and PRoW between Stocking Pelham and Berden.
The proposed development is 130 meters from the Berways meadow – a conservation area that will be negatively impacted.
3. The Landscape & Visual Impact of the proposed development cannot be satisfactorily mitigated
The thick woodland that is referred to in the application is only in evidence in part to the South of the site, and only during spring and summer months. To the north of the site there is a thin strip of woodland along Berways boundary – which during winter months would mean that the site is clearly visibly.
The approach to planting around the existing BESS shows that newly planted hedgerows do not adequately mitigate the visual impact of huge BESS developments such as this.
The top of the acoustic barn roof is over 6 metres high!!! It will be visible above the line of any proposed planting.
The soundproof fencing will be over 3 metres high and would not be in keeping with the natural environment. It will also be visible above the line of any proposed planting.
4. The impact of the development on listed buildings is unacceptable
Crabb’s Green Farm is a listed building. As the site for the paddock is owned and associated with Crabbs Green Farm the site is within the curtilage of a listed building and require listed building consent.
An industrial barn of the sort and size proposed is not appropriate within the curtilage of a listed buildings.
There are several Grade 2 listed properties within 200 meters of this site – White Hart Farm, The Brooder House, Silver Birches, Longcroft, Bennils, The Old Rectory and Cockswood as well as Crabbs Green Farm.
The proposed development will be clearly visible from White Hart Farm – a Grade 2 Listed property.
5. There will be a negative impact on the users of footpaths
This access “road” has been used since the 1960s when the substation was built by local people, local walkers etc... This is why there is a pedestrian access gate at the entrance which allows people to use the road when the gates are locked. For years this road has been used by people walking dogs, teaching children to ride bikes, roller skating etc....
The access road to the substation is also a public footpath – this will become dangerous with the construction traffic.
6. The proposed access arrangements for construction traffic are not suitable
Hertfordshire County Council as Highway Authority have recommended that permission be REFUSED on the grounds that construction traffic associated with the proposal would be detrimental to highway safety contrary to NPPF and LTP4 policies. Hertfordshire County Council states that they are concerned that the proposed route for construction vehicles and construction HGVs will use narrow country lanes to get to the site. They note that in some sections the roads leading to this site have got no footways and that paedestrians, horse riders, cyclists, dog walkers walk along these lanes. Agree with this conclusion!
The proposed route to the site (through Little Hadham, Albury and Clay Chimneys) is unsuitable for large construction vehicles. The road state is such that in places it is falling away into the ditch.
The route also takes the trucks past the Pelhams Pre-School where it is often extremely difficult to get past due to the parking of cars.
There is no footway along Ginns Road. This road is frequently used by walkers, cyclists and horse riders. Children walking to and from the school bus use this road in the mornings and afternoons. Parents getting their children to Pre-School park along this road and walk toddlers to the Village Hall.
The proposed route leaving the site (through Berden) is unsuitable. It passes by the play ground and narrows beside the village hall (where there is no footpath).
The unnamed access track is the access road to the Pelhams Sub Station. This is the access road to the substation and is principally used for those working there. It is used daily by cars and vans visiting the national grid vans and vehicles we see driving around.
7. The noise which will be generated by the BESS is unacceptable – insufficient information has been provided
The noise report was undertaken over the period of 4 days in February. The noise from the existing BESS and substation is already extremely intrusive to residents of both Berden and Stocking Pelham who live in close proximity to the site. Complaints about the levels of noise generated by the existing BESS have already been made to both East Herts and Uttlesford. The Crabb’s Green BESS (if approved) would make the situation even worse!
The cumulative impact of 3 BESS installations and the substation noise would ruin the peace and tranquillity of the area.
East Herts Environmental Health Department has OBJECTED to the proposed BESS and makes the following points (all of which you can repeat):
The application does not contain enough information for East Herts DC to conclude that the proposal adequately assesses the noise impact of the proposed development. It lacks a significant amount of detail surrounding the overall noise frequencies resulting from the development.
No air conditioning units have been mentioned in relation to this development yet presumably there would be some sort of air cooling device fitted (which is the case at the existing BESS site opposite) these act as an additional noise source in themselves, this is point requires clarification.
The report also refers to generic information regarding transformer noise and doesn’t specify the exact equipment proposed.
A full noise frequency analysis should be submitted which shows the levels of noise that are predicted internally and externally day and night compared to the existing frequencies experienced (excluding the current BESS site) for the nearest residential receptors.
The proposed site is close to another recent battery storage (BESS) application of a similar nature (at Green’s Farm 3/21/0969/FUL). The noise report for the Green’s Farm BESS application found the area to have a very low background level of 19dB, reflecting the rural nature of the location. However, the noise report submitted in conjunction with the Crabb’s Green application found a background level much higher than this of (34dB). As the main substation is equidistant from both sites there are no significant sources evident that would cause this discrepancy other than the existing BESS site along Crabbs Lane.
This existing BESS site should not be increasing the background levels in the way that is currently is and is therefore creating an artificially high background level which is not in line with what would be expected or acceptable in such a quiet and tranquil area.
The Crabb’s Green BESS application should not judged against this level, but instead is based on a background level which excludes the existing BESS completely.
The NPPF guidance seeks to protect the tranquillity of areas that have remained relative undisturbed by noise and prevent adverse impacts on the quality of life of the nearby residents and impacts on the natural environment.
As a result of complaints received about the existing BESS site it is evident that noise from BESS facilities fluctuates not only as a result of environmental factors such as wind and temperature but also as a result of grid demand etc. All these factors would need to be considered and a worst case scenario used.
8. The risks of a fire & explosion have not been considered and cannot be adequately mitigated
Paragraph 97(a) of the NPPF 2021 states that “Planning policies and decisions should promote public safety and take into account wider security and defence requirements by (a) anticipating and addressing possible malicious threats and natural hazards, especially in locations where large numbers of people are expected to congregate. Policies for relevant areas (such as town centre and regeneration frameworks), and the layout and design of developments, should be informed by the most up-to-date information available from the police and other agencies about the nature of potential threats and their implications. This includes appropriate and proportionate steps that can be taken to reduce vulnerability, increase resilience and ensure public safety and security”
The proposed site is very close to the existing BESS site and there will be 3 of these battery sites within 1 square mile resulting in 150 MW of battery storage, the energy stored is the equivalent to 150 tonnes of TNT.
There have been over 35 BESS fires in the past 3 years, five of which have occurred in the last 18 months. Recent BESS fires have been in new facilities, and have occurred typically during commissioning or shortly after.
A fire at a BESS in Merseyside in September 2020 took 59 hours to extinguish. Debris from the fie was blasted up to 75ft away. A report by Merseyside Fire & Rescue Service (MFRS) found that efforts to put out the blaze were hampered after water hydrants proved 'inadequate'.
The MFRS report for that Merseyside incident was in March 2022 and highlights a number of recommendations and lessons learned. These are relevant to the Crabb’s Green BESS and include (i) the need and recognition of hazardous materials on site (ii) the recommendation to install blast walls (ii) the importance of upwind access; and (iv) the need for on site or nearby mains water and hydrant provision.
There is no evidence of any fire hydrants on site and there is a well known lack of water supply to the Pelhams in the event of a thermal runway incident. There is only one access road – which is the access road to the substation. In Professor Paul Christensen’s report for the Green’s Farm Battery it is suggested that there is a clear need for a circular road surrounding the site – which would not be achievable here.
BESS facilities of this size should be assessed for Hazardous Substances Consent (HSC) and should be subject to the COMAH Regulations.
The Council must request the applicant to provide details (type and mass) of any dangerous substance which:
is stored or produced during normal operation;
or can result from a fire, explosion or other event if there is a loss of control of the process.
9. There is insufficient mains water to deal with a fire at the site
There are no fire hydrants evident on site – there should be 1,900 litres of water available per minute for a minimum of 2 hours in accordance with Allianz and the Suffolk Fire Service. There is under half of this available in the Pelhams.
In the September 2020 Merseyside BESS fire all preventative measures failed. The early warning alarms failed. The operational cooling system failed. And the aerosol fire suppression system failed (at least until it was too late to be of any use). The pace at which the incident progressed was very rapid.
It is clear from the report prepared by the Merseyside Fire & Rescue Service (MFRS) that the key mitigation measure used in dealing with the significant incident was the nearby access to mains water and water hydrants. However, even this was insufficient. “As near-by hydrant fed water supplies were inadequate to meet the needs of the ongoing firefighting, a High Volume Pump (HVP) was requested via National Resilience Fire Control for the purposes of augmenting water supplies.
10. This application should not be considered in isolation. It should be assessed in conjunction with the prospective application to build a solar farm adjacent to Violets lane in Furneux Pelham
It is already clear that the applicant (Renewable Connections) intends to build a solar farm on land adjacent to Violets Lane. The 2 applications should be considered together. The current BESS application clearly forms part of a massive proposal for renewable energy production and storage.
The visual impact and cumulative impact on the local area and local community needs full consideration, not by ad hoc planning applications.
11. There has been no consideration of the loss of high quality Agricultural Land. An assessment of the land classification is needed.
The Agricultural Land Classification map Eastern Region (ALC008) published by Natural England shows the proposed site of the Battery Plant to be on Grade 2 Agricultural Land. This is "best and most versatile" land. To allow the development would be contrary to National Planning Policy Framework para 170 b) which requires that Planning decisions should "recognise the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services - including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland"
There is no evidence that a search has been undertaken for better sites. The Council must require the applicant to produce evidence that other options have been considered together with an explanation as to why lower quality land has been discounted.
There is a presumption in the NPPF and Local Plan policies against the use of best and most versatile agricultural land i.e. land graded 1, 2 or 3a. This designation serves the strategic security purpose of preserving that resource so that we can feed our densely populated country. It should not be chipped away at.
The argument that the permission is temporary and the land reinstatable is false: the construction and pad destroys the inherent complexity of the soil structure with its mychorizal content. Reinstated soil can never return to the same quality. In reality we all know this site will become forever brownfield, and either the lease and permission will be extended or the landowner will let the operator off the requirement to remove the pad and its base, so it can use it for hardstanding or something else non agricultural.
The Council should take into account the conclusions of the Planning Inspectorate in the relevant appeal decisions including Appeal Ref: APP/H1033/W/17/3186235 in which the Inspector concluded that the proposal would have an adverse impact on the rural character and appearance of the landscape and area, matters to which the Inspector attached significant weight. The Inspector concluded that the harm caused by the potential development did NOT outweigh the potential benefits.
12. A BESS is NOT a source of renewable energy – it is a stand alone industrial development
Question whether a battery storage plant is actually a renewable scheme at all. There is no mention of battery storage in the Planning Guidance on renewable and low carbon energy. East Hets Local Plan Policy includes policy CC3 Renewable and Low Carbon Energy which says that
1. The Council will permit new development of sources of renewable energy generation, including community led projects, subject to assessment of the impacts upon: (a) environmental and historic assets; (b) visual amenity and landscape character; (c) local transport networks; (d) the amenity of neighbouring residents and sensitive uses; (e) air quality and human health; and 22 (f) the safe operation of aerodromes. II. In considering the impact of renewable technologies, the Council will attach particular importance to maintaining the special countryside character of the rural area, including the preservation of long-distance views from public rights of way.
However, batteries do NOT generate renewable energy - they simply store energy that is generated elsewhere (and not necessarily by renewables). The battery proposal is not governed by Policy CC3.