Representation by Christoph Widmer
- Date submitted
- 16 March 2022
- Submitted by
- Members of the public/businesses
I object to the application as presented. Representations 1. Failure to demonstrate relevant experience/track record The proposed project would constitute the largest BESS in the world. BESS are a high risk technology due to risk of explosion and poisonous gas emissions lethal to human life. Applicant is a developer. Applicant has failed to demonstrate any relevant experience/track record of developer or of EPC provider or of O&M provider to design, construct, operate BESS. Applicant has advised its interest in selling the project to third parties in Q2 2022 - before the outcome of the planning process i.e. has no intention of seeing this project to completion. 2. Failure to provide relevant information Applicant has acted in bad faith in relation to disclosure - failing to provide relevant information and/or swamping interested parties with irrelevant information to hide the relevant information as a needle in a haystack. Critically, Applicant has failed to provide (a) relevant information on battery energy storage compounds ("BESS") and when asked at town hall meetings has refused to answer reasonable questions (b) technical information on BESS and solar technology (c) linkage of BESS to grid (d) linkage of BESS to solar. I believe disclosure would prove that these are in fact two projects not one which would require two planning applications not one and which would make the application impermissable under NSIP rules. 3. Abuse of process The application constitutes an abuse of the applicable planning/NSIP rules. Technically, these are two projects - not one; a battery project and a solar project which happen to be co-located. Each project requires a separate planning application/consent. Economically, this is a battery project masquerading as a solar project. As a battery project only, the project would not meet NSIP hurdles. The applicant has added a solar project as window dressing to obtain consent for the BESS under NSIP rules and thereby circumvent local planning rules under which planning would not be obtained as all local and district councils are not supportive of the BESS. The battery project is geared at power trading from/to the grid and power price arbitrage which is not permitted under applicable planning rules which require the BESS to be geared at storing power generated on site - not from the grid. Approval would create a poor precedent. 4. Incentives, costs and benefits The benefits of the proposed project inure almost exclusively to the applicant/developer. The applicant's rationale for the application is to support the UK's transition to net zero. The real rationale is greed - the desire to monetise the project in 2022 for an expected upfront gain of > GBP 50 million for a 2-3 people's time over a few years with no material capital investment/no capital at risk. The costs are borne exclusively by the local population - via the irreversible destruction and industrialisation of greenfield land and the resulting negative impact on property values and quality of life. Approval of the application in its current form represents the privatisation of profit and the socialisation of costs by government fiat. It presents government sanctioning the applicant to take a free ride on the local communities and to retain vast profits without compensation for local communities' costs/losses. It represents government sanctioning a vast transfer of value from one group of private individuals (the local communities) to another (the applicant). That is patently unfair on the local communities.