Subject: Strong Objection to Planning Application 25/00833/FULM - Proposed 200MW Energy Storage System (ESS) and Associated Infrastructure on Land off North Cray Road, Sidcup.

Dear Sir/Madam,

I am writing as a local resident to strongly object to the planning application referenced above for the construction and operation of a 200MW Energy Storage System (ESS) and associated infrastructure on land off North Cray Road, Sidcup.

My objection is based on the information presented within the planning application documents, including the applicant’s own Planning Design and Access Statement (PDAS), Green Belt Assessment Report (dated April 2025, Ref: 17947, prepared by DWD), and other supporting documents. These documents themselves provide sufficient grounds to refuse this application due to its fundamental conflict with planning policy and its unacceptable impacts.

My objections are based on the following significant concerns:

1. Fundamentally Inappropriate Development in the Metropolitan Green Belt

• Location within Green Belt: The application site is unequivocally located entirely within the Metropolitan Green Belt, as confirmed by the applicant (PDAS para 1.7, GB Assessment Report para 1.8, 2.3).
• Conflict with Policy: National Planning Policy Framework (NPPF) paragraph 142 attaches “great importance” to Green Belts, aiming to prevent urban sprawl by keeping land permanently open, safeguarding the countryside from encroachment, and preserving the openness of the landscape. Bexley Local Plan Policy SP8 explicitly states the requirement to protect the Metropolitan Green Belt from inappropriate development (GB Assessment Report para 2.4).
• Not an Exception: The applicant’s report acknowledges that the Proposed Development is not one of the exceptions to Green Belt control listed in NPPF Paragraph 154 (GB Assessment Report para 3.2).
• Harmful by Definition: Therefore, according to established national and local policy, this industrial ESS proposal constitutes inappropriate development. NPPF Paragraph 153 states that inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances. Substantial weight must be given to this inherent harm.

2. Flawed Justification Using ‘Grey Belt’ Classification

• Contested Classification: The applicant attempts to circumvent the “inappropriate development” designation by arguing the site qualifies as “Grey Belt” under the newly introduced NPPF paragraph 155 tests (GB Assessment Report, Section 3). This argument is flawed, highly contestable, and should be rejected.
• Greenfield Site: The site is acknowledged by the applicant as “undeveloped greenfield land” (GB Assessment Report para 3.8), not previously developed land which might more readily fit a ‘Grey Belt’ definition.
• Understated Contribution to Green Belt Purposes: The applicant claims the site makes only a “weak contribution” to preventing sprawl (Purpose a) and preventing towns merging (Purpose b), and “no contribution” to preserving historic settings (Purpose d) (GB Assessment Report paras 3.20, 3.23, 3.28). This significantly downplays the role of this open agricultural land. It clearly contributes to preventing the sprawl of Greater London southwards (Purpose a) and fundamentally serves to safeguard the countryside from encroachment (Purpose c - NPPF para 143), a purpose the applicant admits the development would compromise (“a degree of encroachment”, GB Assessment Report para 3.35). Classifying undeveloped green fields adjacent to the urban edge as making only a weak contribution misunderstands the visual and spatial role Green Belt land plays. Any contribution is relevant, and development harms these purposes.
• Subjectivity of Assessment: The Grey Belt definition excludes land that strongly contributes to purposes (a), (b), or (d). The applicant’s assessment that this site does not contribute strongly is subjective and self-serving. Open, undeveloped land inherently provides a strong check on sprawl and protects the character of the countryside.
• Council’s Pre-Application Stance: It is noted from the applicant’s own documents (PDAS para 1.16; GB Assessment para 3.52 quoting Pre-App Advice) that Council officers indicated only the potential for a Grey Belt argument, stating it must be robustly justified and that alternative sites must still be explored. This clearly indicates the applicant’s Grey Belt classification is not accepted as fact and requires rigorous scrutiny, which it fails.
• Conclusion on Grey Belt: Given the site is greenfield, contributes to Green Belt purposes (particularly preventing encroachment), and its development would cause encroachment, it fails to meet the definition of Grey Belt. It should be treated as standard Green Belt land, meaning the development is inappropriate.

3. Significant Harm to Green Belt Openness, Character, and Visual Amenity

• Harm Acknowledged by Applicant: As the development constitutes inappropriate development, the harm identified by the applicant must be given substantial weight. The applicant explicitly accepts the development “would result in a reduction in openness” (GB Assessment Report para 4.6), a “spatial reduction to openness” (para 4.7), “some visual impact and perception of loss of openness” (para 4.19) and “some harm to the Green Belt” (para 4.7). They admit it causes “a degree of encroachment” into the countryside (para 3.35) and impacts the “semi-rural character” (para 4.12).
• Understated Harm: While the applicant attempts to minimise this harm as “limited” or “negligible adverse”, this is a significant understatement and contradicts the physical reality of the proposal. Any reduction in openness is direct harm to a fundamental characteristic of the Green Belt.
• Scale of Development: The erection of up to 200 industrial container units (each approx. 7.8m L x 2.7m H), a 132kV Substation (up to 6.8m high), associated transformers, control rooms, welfare units, 2.4m high security fencing, access tracks, and water tanks (Table 3.1, PDAS) on approximately 7.0 ha of open fields constitutes a major industrialisation of the landscape. This cannot credibly be described as having a “limited” impact on spatial or visual openness.
• Visual Harm: The development will be a significant visual intrusion. The applicant acknowledges it would be visible from various receptors (GB Assessment Report para 4.12), cause temporary “major adverse” visual effects during construction for some receptors (para 4.15), and have adverse landscape and visual effects (para 5.4). Views from nearby residential properties, public footpaths (like FP141, FP171), and North Cray Road itself will be negatively impacted, changing the character of the area from open countryside to one dominated by industrial infrastructure.
• Harm to Character & Encroachment: The development erodes the distinction between urban and rural areas that the Green Belt exists to maintain. It is harmful encroachment into the countryside.

4. Failure to Demonstrate Very Special Circumstances (VSC)

• High Bar Not Met: As inappropriate development, permission can only be granted if the applicant demonstrates Very Special Circumstances (VSC) that clearly outweigh the harm by inappropriateness and any other harm (NPPF para 153). The applicant’s case for VSC (GB Assessment Report, Section 6 & Table 6.1) is insufficient and fails to meet this high bar.
• National Need vs. Local Harm: While the national need for renewable energy infrastructure and energy storage is acknowledged, this does not constitute an automatic override of Green Belt protection or automatic VSC status. NPPF Para 160 allows this need to contribute to VSC, but it doesn’t guarantee approval, especially on undeveloped greenfield sites where significant harm occurs. National need is a general circumstance, not one specific to this sensitive Green Belt site that justifies the specific, substantial local harm caused here. The applicant’s assignment of “Very Substantial” weight to this single factor (Table 6.1) is subjective and must be balanced against the inherent “Substantial Harm” of inappropriate development plus other harms.
• Inadequate Alternative Site Assessment: The applicant claims (Para 6.91, GB Assessment) no viable alternatives exist outside the Green Belt, relying heavily on their Site Selection Report (SSR) and proximity (within 3km) to the Hurst Grid Substation and commercial viability (GB Assessment paras 6.78-6.80). This site selection process appears overly constrained by developer convenience (grid connection cost/ease) rather than a robust assessment demonstrating Green Belt development is unavoidable. The 3km search radius seems arbitrary. Were brownfield sites, even if slightly further from the substation or requiring higher connection costs, properly evaluated against the high bar of Green Belt protection? Prioritising grid connection convenience over fundamental Green Belt policy undermines the latter’s protective status. The assertion that there are “no additional viable and available locations… outside of the Green Belt” (GB Assessment 6.91) is a strong claim requiring irrefutable proof, which seems unlikely and has not been provided. Rigorous independent scrutiny of this process is required.
• Overstated ‘Other Benefits’: The applicant assigns only “Moderate Weight” to economic benefits, biodiversity net gain (BNG), and the temporary/reversible nature (Table 6.1). BNG is increasingly a standard requirement, not ‘very special’. Economic benefits appear limited and localised. The ‘Swift Grid Connection’ (Significant Weight, Table 6.1) is primarily a project/developer benefit, not a public benefit constituting VSC.
• ‘Temporary’ Nature (Permanence): The applicant emphasizes the 40-year operational life makes the development “temporary” and “reversible” (GB Assessment Report paras 6.104-6.107). Forty years is not temporary in any meaningful sense; it represents almost two generations. Claiming reversibility minimises the fundamental harm caused to the Green Belt’s characteristic of permanence during this extensive period. Full restoration to previous high-quality agricultural and ecological function after such intensive industrial use over four decades is highly questionable and likely improbable. This significantly impacts permanence for a generation.
• Overall VSC Assessment: The cumulative weight of the claimed benefits (mostly moderate or significant, heavily reliant on national need and developer convenience) does not clearly outweigh the substantial harm by definition from inappropriate development, plus the additional harms to openness, character, visual amenity, agriculture, and biodiversity identified by the applicant and residents. The VSC test is not met.

5. Loss of Valuable Agricultural Land

• BMV Land: The applicant’s own documents acknowledge that the site comprises Best and Most Versatile (BMV) agricultural land (Grades 2 and 3a).
• Unacceptable Loss: The permanent loss of productive farmland is unacceptable, particularly when national food security is a growing concern. As noted above, the claim of reversibility after 40 years of industrial use is highly questionable in practice.
• Brownfield Preference: Industrial energy infrastructure should be sited on previously developed (brownfield) land, not high-quality agricultural land within the Green Belt.

6. Negative Impact on Biodiversity and Landscape Character

• Wildlife Value: This area, while agricultural, supports local wildlife and contributes significantly to the semi-rural character valued by residents.
• Inadequate Compensation: The BNG report, while claiming a net gain on paper, cannot adequately compensate for the disruption during the 12-month+ construction phase, the operational impacts (including potential noise and light pollution), and the fundamental change from open fields to an industrial site. The claimed biodiversity gain does not compensate for the fundamental policy breach and landscape harm.
• Specific Impacts: The impact on existing important hedgerows (acknowledged in the BNG report) and the potential disturbance to wildlife corridors and species mentioned in the ecological surveys (such as badgers, bats, birds, potentially reptiles and hedgehogs) are serious concerns.
• Mitigation Failure: The proposed landscaping cannot fully mitigate the introduction of such a large-scale industrial facility into this sensitive countryside setting.

7. Traffic, Access, and Safety Concerns

• Construction Traffic: The introduction of Heavy Goods Vehicles (HGVs) and significant contractor traffic onto North Cray Road and the existing narrow farm access track raises serious safety concerns, particularly given the existing road constraints, the proximity of the access to residential areas, and potentially a locally listed building (Manor Farm Farmhouse).
• Operational Safety: Lithium-ion battery storage facilities carry inherent fire risks, acknowledged implicitly by the need for detailed safety management plans and liaison with the Fire Brigade. The proximity of such a large-scale facility to residential properties and sensitive environments like woodlands is a major concern for local residents.
• Cable Route Disruption: While underground, the laying of the extensive cable route along North Cray Road, A223, A2018 and Stable Lane will inevitably cause significant disruption to local traffic and potentially impact adjacent properties and infrastructure during the construction phase.

8. Noise and Disturbance

• Both the construction phase and the potential operational noise from equipment such as cooling systems (mentioned in the consultation feedback) will negatively impact the amenity of nearby residents, disturbing the current quiet enjoyment of our homes and the surrounding area.

9. Lack of Direct Local Benefit and Precedent

• While the need for energy storage is understood at a national level, this specific location in the Green Belt imposes significant local harm for a facility that primarily serves the wider grid. There is little direct benefit to the immediate community to outweigh the negative impacts.
• Furthermore, approving this industrial development in the Green Belt could set a dangerous precedent for further inappropriate development in the area, undermining the long-term protection of the Green Belt in Bexley.

Conclusion

In summary, this proposal represents inappropriate industrial development within the Metropolitan Green Belt. The applicant’s attempt to classify the site as ‘Grey Belt’ is unconvincing and contradicts the fundamental roles of open countryside in preventing sprawl and encroachment.

The development would result in significant and demonstrable harm to the openness, landscape character, visual amenity, biodiversity, and valuable agricultural land of the Green Belt. It also raises serious concerns regarding traffic impact, noise, and safety for local residents.

Crucially, the applicant has failed to demonstrate the Very Special Circumstances required by national and local policy that would clearly outweigh this substantial and multi-faceted harm. The claimed national need and other applicant benefits, largely based on developer convenience, do not meet this stringent test, particularly regarding the inadequate assessment of alternative sites outside the Green Belt.

Protecting the Green Belt is a fundamental planning aim. Granting permission would undermine the integrity of Green Belt policy in Bexley. Convenience for energy infrastructure development does not automatically override this protection, particularly on undeveloped greenfield land.

I therefore urge the London Borough of Bexley Planning Department to uphold its commitment to protecting the Green Belt and refuse this application.

Yours faithfully,