Manor Farm forms a large part of North Cray's precious Green Belt. As undeveloped open farmland, with its important contribution to the character of our landscape and the prevention of urban sprawl, it is not a "grey" area of the Green Belt appropriate for industrial or other development. There are no "Very Special Circumstances" to justify this in this case. In these uncertain times, too, the need for food security is important.

The site has been farmed for centuries, forming a part of the ancient Manor of North Cray and subsequently the North Cray Place Estate belonging, in the early 19th century, to Lord Bexley. The southern boundary of the site is part of the boundary between North Cray and Ruxley dating back to Saxon times. Manor farmhouse is a historic locally-listed building dating from the early nineteenth century. The site is approached by a farm track with thick and well-established hedges of at least 200 years old on both sides, which will inevitably be damaged by the frequent passing of wide vehicles during the 12 months (at least) of construction

Disruption will last at least a year. Limited visibility of oncoming traffic for the many heavy vehicles leaving the site presents a dangerous hazard. Large amounts of additional heavy traffic will make congestion on the North Cray Road even worse. In order to connect the site to Hurst electricity sub-station in Bexley the entire length of the North Cray Road from Bexley to the St James Way U-turn will have to be dug up to lay cables which will take months causing traffic chaos

Manor Farm abounds with Wildlife of all kinds: bats, a kestrel/hawk that nests in the ancient Chalk Wood that adjoins the Farm's hayfield, pheasants and other birds that nest in its many hedgerows, and there are badgers on most of its land. The creation of a large intrusive ESS on this farmland, and the destruction of its ancient hedgerows, which like badgers are protected by law, would have a devastating impact. The remedial action that has been proposed, such as planting new hedgerows, a wildflower meadow and fruit trees to assist foraging, is unconvincing

Lithium-ion batteries are a fire risk that cannot be extinguished with water.Fires can occur at ESS facilities because they contain millions of battery cells. If just one cell catches fire and is not insulated from the rest of the battery, then the rest catch fire, which is called thermal propagation. Some batteries used in ESS’s are second hand life lithium batteries previously used in electric vehicles that, therefore, have a higher risk of fault. Battery fires can be extremely difficult to extinguish as they contain fuels to sustain a fire. When on fire they produce hydrogen and oxygen, further fuelling the fire. The subsequent build up of gas and pressure will then lead to explosions.The gases produced from these fires are toxic and hence extremely dangerous to health. When combined with materials used to extinguish these fires, they will create a massive irreversible risk to our delicate ecosystem and wildlife.