I am writing to strongly object to the planning application for the Energy Storage System (ESS) on land off North Cray Road. I urge the department to refuse this application primarily because the site is not Grey Belt, the proposal constitutes inappropriate development in the Green Belt, and it would cause significant and fundamental harm to Green Belt openness and its purposes.

My specific concerns are as follows:

1. Inappropriate Development Fundamentally Undermining Green Belt (NPPF Chapter 13):

The applicant’s claim that this site constitutes ‘Grey Belt’ (Green Belt Assessment [GBA]) is incorrect. NPPF Annex 2 defines Grey Belt primarily in relation to previously developed land or land not strongly contributing to Green Belt purposes. This site, however, is undeveloped agricultural land, stated in the applicant’s Site Selection Report (Para 1.3, 2.1) as comprising Grade 2 and Subgrade 3a agricultural land. It is therefore not previously developed.

Furthermore, the development of this industrial facility would fundamentally undermine the purposes of the remaining Green Belt across the plan area (contrary to NPPF Para 155a criteria for even considering non-inappropriate development). This is due to:

• Severe Encroachment and Loss of Openness: The introduction of up to 200 storage units, a 132kV substation, large water tanks, and ancillary buildings represents a massive industrialisation of open countryside. This directly contravenes the Green Belt purpose of safeguarding the countryside from encroachment (NPPF Para 143c) and keeping land permanently open (NPPF Para 142). The visual impact of this industrial complex, especially when viewed from publicly accessible locations such as Chalk Wood (as detailed in Point 4 below), will significantly diminish the perceived openness and rural character of this part of the Green Belt.
• Contribution to Urban Sprawl through Noise and Industrial Character: The operational noise from a 200MW ESS, including cooling fans and other machinery, will extend the perceptible urbanising influence into this currently rural area. This auditory impact, combined with the visual industrialisation, contributes to a creeping urban sprawl (NPPF Para 143a), eroding the tranquility and character of the Green Belt.
• Failure to Assist Urban Regeneration: By selecting a high-quality greenfield site, the proposal directly conflicts with the Green Belt purpose of encouraging the recycling of derelict and other urban land (NPPF Para 143e).

This development is unequivocally ‘inappropriate development’ within the Green Belt and, by definition, harmful (NPPF Para 153). The scale and nature of the proposal ensure this harm is substantial and fundamental to the Green Belt’s integrity here.

2. Absence of Very Special Circumstances (VSC) & Flawed Site Selection (NPPF Para 153):

The VSC required to outweigh Green Belt harm have not been demonstrated.

• Site Area Discrepancy: The SSR (Para 4.18) filters alternatives based on a 7.0 ha need. However, the applicant’s Arboricultural Report (ARBORICULTURAL_REPORT-3224383.pdf) indicates a development boundary fence. GIS analysis of the land within this fence line shows an actual development footprint of only approximately 2.6 ha. This discrepancy invalidates the site selection process, which improperly dismissed smaller, potentially less harmful sites.
• Inadequate Search for Alternatives: The SSR’s 3km search radius is insufficient. The applicant fails to justify why this specific Green Belt site is necessary when numerous other substations may exist nationally in non-Green Belt or genuine Grey Belt locations (NPPF Para 148).

3. Technological Maturity, Safety, and Environmental Risk to Green Belt:

The proposal’s safety implications, particularly concerning fire risk within the Green Belt, are gravely concerning:

• Inappropriateness of Using Green Belt for New Technology with Known Fire Risks: Large-scale BESS technology is relatively new. Data from RenewableUK (EnergyPulse, Feb 2024) suggests that of all sites in the entire UK BESS development pipeline (across all stages: ‘in planning’, ‘consented’, ‘under construction’, ‘operational’, etc.), only a small percentage (reportedly around 8%) is currently operational. This very limited pool of widespread operational experience, especially for 200MW facilities, means the technology is not yet fully proven at this scale. Given this context, and the documented history of BESS failures and fires (e.g., EPRI BESS Failure Incident Database; and the recent fire during construction at East Tilbury on Feb 19, 2025, reported by Essex Fire & Rescue), it is wholly inappropriate to use protected Green Belt land as a location for what is, in effect, a testbed for such new technology with known significant safety risks. Green Belt land should not be compromised for experimental or unproven industrial applications.
• Green Belt Vulnerability & Climate Factors: A fire on this Green Belt site could have devastating ecological impacts. Toxic smoke, contaminated firewater runoff, and the fire itself could devastate the local ecology. The “temporary” nature of the development (GBA, Para 6.104) is irrelevant if a catastrophic fire causes long-term or irreversible environmental damage to the Green Belt. Annually rising temperatures globally increase the operational stress on BESS units and the likelihood of thermal runaway or cooling system failures, heightening fire risk, especially during hot summer months. This specific environmental factor, and its impact on Green Belt safety, seems inadequately addressed.
• Emergency Response During Power Outages: Recent major blackouts, such as the one impacting Spain and Portugal on April 28, 2025, highlight the vulnerability of power grids. In the event of a widespread blackout in Bexley during hot weather, a fire at the North Cray ESS site would pose extreme challenges. Questions arise regarding how fire suppression and containment systems, which may rely on power, would function. It is unclear how the on-site water tanks (2 x 240,000 litres, GBA Para 1.15) would be sufficient or deployed effectively under such circumstances.
• Emergency Access & LFB Input: There is no public record that the London Fire Brigade (LFB) has formally provided its specific response or approval for the safety measures and access arrangements for this application. Furthermore, the planning application appears to lack crucial details on multiple safe access and egress points for fire engines and other large support vehicles, which is critical for effective emergency response in a potentially hazardous and prolonged fire incident. A single access point, as may be implied by the “existing agricultural access track” (SSR, Para 2.10), would be wholly inadequate.

4. Potential Omissions in Landscape and Visual Impact Assessment (LTVIA):

The applicant’s LTVIA (by RHLA Limited) may be incomplete. It is requested that the LPA verify that all relevant publicly accessible viewpoints from areas such as Chalk Wood (SINC M118), a Bexley Council managed site with public access (Source: GiGL, M118), which may offer views of the site (even if intermittently from certain tracks), have been adequately considered in the LTVIA. An incomplete assessment could mean the full visual impact on the Green Belt and local amenity has not been fully evaluated, hindering an accurate understanding of the proposal’s detriment.

5. Construction Traffic Disruption to A223 North Cray Road During Peak Hours:

The submitted Construction Traffic Management Plan (CTMP by Mott MacDonald, April 2025) indicates that HGV deliveries (including 16.5m articulated vehicles – CTMP Para 3.2.4) are not subject to specific time restrictions beyond standard construction hours (07:30-18:30 Mon-Fri – CTMP Para 4.4.2). This will inevitably lead to large, slow-moving construction vehicles accessing the site via the A223 North Cray Road during peak morning and afternoon rush hours, coinciding with school runs and work commutes.

The critical issue is the single-track nature of the site access road (North Cray Road), which the CTMP (Para 3.2.8, Table 5.1) acknowledges will require a banksman and holding system to prevent vehicles meeting. Any delay or inefficiency in this system, or the sheer manoeuvre time for HGVs entering/exiting this restricted single-track access from the A223, will directly cause queuing and obstruction on the A223 North Cray Road itself, a 40mph dual carriageway. The CTMP (Table 5.1) states “No temporary traffic management measures are currently anticipated” on the public highway. This lack of proactive measures to manage HGV movements on the A223 during peak periods, given the bottleneck created by the single-track access, will lead to unacceptable delays and potential safety hazards for existing road users.

This development represents an unacceptable imposition on the Green Belt and local community. The applicant has failed to provide robust justification, adequate impact assessments, or demonstrate the very special circumstances needed to override this harm. A precautionary approach is essential regarding the safety of this new technology in a sensitive Green Belt location. I urge you to refuse this application.

Yours faithfully,