Back to list Sunnica Energy Farm

Representation by Dr Edmund John Fordham

Date submitted
12 March 2022
Submitted by
Members of the public/businesses
  1. Since 2014 I reside locally. I am a Chartered Physicist, Chartered Engineer, registered European Engineer and Fellow of the Institute of Physics, with over 40 years’ experience in applied research in the energy industries, since graduating from Cambridge with a double First in Natural Sciences. My experience includes nuclear reactor safety engineering, a doctorate on wind energy, and 33 years in the oil and gas sector. I object to the Sunnica proposal, for the following reasons. 2. Sunnica is described as a 500 MW electricity generator. But expected generation implies an annual average power of about 67 MW, less than 1/7 of rated power. A conventional power station of this output would occupy only about 1.8 ha, 450 times more efficient in use of land than Sunnica. 3. The environmental destruction in loss of: (i) agricultural land, (ii) wildlife habitat, (iii) biodiversity, and (iv) the inability to plant trees (v) the local microclimate warming, caused by most solar energy just heating the panels, (vi) the threat to local Nature Reserves and SSSIs – are all unacceptable, and not offset by the claimed CO2 savings. These are almost certainly nugatory when the “embedded carbon” footprint of the proposed batteries is included. 4. The Battery Energy Storage System (BESS) compounds remain under-specified both as to extent and technology. Since 2019 Sunnica have refused to answer even basic questions as to energy storage capacity, number of cabins, spacing of cabins, electrochemical technology, safety engineering and fire precautions. They are asking for a “blank cheque”. Parties have been reduced to guesswork regarding what could be the largest BESS in the world, with major hazard potential. Lacking even outline specifications, the Outline Battery Fire Safety Management Plan and air quality assessments have no rational foundation. 5. The energy capacity of the BESS is inconsistent with the claimed function. Energy Institute guidance implies a planned capacity of up to 3000 MWh of battery storage, more than can credibly be used by the relatively small output of the solar panels. Presenting as a “power station” (output only) what is really an energy trading plant (import and export) is dishonest. BESS at this scale would not be Associated Development i.e. the BESS are an installation in their own right rather than associated with, and proportional to, the expected photovoltaic generation. Such use would fall outside the scope of the Planning Act 2008. 6. The only BESS technology with the maturity to be deployed at scale is Lithium-ion. Li-ion BESS accidents (major fires and explosions, including one in Liverpool in 2020) are matters of record. “Thermal runaway” accidents are a known failure mode but no engineering standards address their prevention. Wrongly called “battery fires” they require no oxygen so cannot be stopped by conventional means except extravagant water cooling. The major accident potential of the BESS is considerable. 3000 MWh is about 5 times the energy of the 2020 Beirut explosion. Highly toxic gases (principally Hydrogen Fluoride) are released in thermal runaway presenting a major hazard to neighbouring housing, schools, workplaces and bloodstock centres. 7. In respect of BESS, though presenting major accident hazard, the HSE currently refuses to enforce the public protection provided by the Control Of Major Accident Hazards (COMAH) Regulations. HSE has been unable to cite any legal basis for this exemption, which appears to be ultra vires, and unlawful. The parallel requirement for Hazardous Substances Consents under the Planning (Hazardous Substances) Act 1990 should however be within the scope of the Examination and must not be evaded.