In this post on BESS fire safety, we examine key differences between a planning consultation letter from Kent Fire and Rescue Service (KFRS) in relation to a solar farm near Sacketts Hill, Kent and Hereford and Worcester Fire and Rescue Service’s (HWFRS) consultation response to the Monksfield Solar Farm in Worcestershire.
Summary
The key difference is that KFRS actually appear to have read the planning application and tailored their response accordingly, rather than doing a vanilla cut and paste job of National Fire Chief Council’s (NFCC) guidelines!!!
This is important because as it stands, a planning application could be approved which leaves local fire fighters and the local population exposed to unnecessary fire safety risks.
In our view, MHDC planning officers should request that HWFRS responds to this specific planning application. If appropriate, they should then request that RWE submits plans that align with NFCC guidance as recommended by HWFRS.
MHDC councillors and planning officers may also wish to consider the arrogance of multi-billion euro Rheinisch-Westfälisches Elektrizitätswerk Aktiengesellschaft (RWE) in assuming that they know better than UK Chief Fire Officers when it comes to managing fire risk.
In the meantime, local residents may wish to raise these concerns with HFWRS. Contact details for commenting online or via a letter are provided here.
The letters
Examining the letters one can see that there is a very similar structure and use of wording (see links at the bottom of this post). Clearly a standard response has been developed by the UK FRS to such planning applications.
However, some key differences emerge in the Kent response, in that they relate specifically to the site in hand. For example, the following are extracted from their letter to the local planning department:
- “I note two alternative access points provided to the site, to account for opposite wind conditions.”
- “I note there is little separation between the proposed BESS containers. Current guidance from the NFCC requests…”
- “I note the fire water storage and pumphouse. Please confirm the volume of water storage meets the requirements given in the NFCC grid scale guidance document…”
No such specific reference to the site in question is made in the HWFRS response. As lay persons, these all appear to be significant omissions given the draft BESS safety plan submitted by RWE:
- RWE appears to try and disguise the limited number of access points via (not) clever wording – in reality each BESS compound does not have two access points
- RWE seeks to justify less than 6m separation between BESS containers
- There appears to be no water storage in the safety plan. Indeed, in a public meeting at Powick Village Hall, RWE’s representative stated that fire engines could carry the water with them! Well a fire appliance carries about 1 minute’s worth of water based on the flow rate required according to NFCC guidance, so good luck to HWFRS with that!
Why is this important?
Our understanding, confirmed by speaking to a representative from HWFRS, is that HWFRS would have to live the whatever is approved. They have no power to refused a planning application. It seems unreasonable to expect a Planning Officer, let alone a Councillor, to have read the NFCC guidance, interpreted it and compared it to RWE’s BESS safety plan. So there is no mechanism that we can see to avoid this development being approved without these risks being addressed.
This means that for the three points raised:
- If the wind is blowing the wrong way, fire fighters won’t be able to approach the fire anyway due to toxic fumes
- Delays in fighting the fire effectively will be compounded (no pun intended) by the BESS containers being too close together, increasing the likelihood of the fire spreading and becoming more serious
- Firefighters won’t have access to the required amount of water to fight a fire or cool the BESS containers
In his briefing note to the Planning Inspectorate, Professor Dobson OBE highlights the potential consequences from Thermal Runaway in a BESS fire, which include toxic vapour clouds very harmful to local population.
The problem
We are seeking to provide advice to Planning Officers and Councillors through this page. Whilst it may be tempting to suggest that the planning application should be rejected on these grounds alone, we are aware of a precedents where a local council has tried to do just this and have lost on appeal – with the planning inspectorate deciding that because the NFCC guidance is just “guidance”, then it is insufficient grounds to reject a planning application on its own.
Mad, we know, but RWE has deep pockets – sufficient to sue national governments for loss of revenue when those governments’ climate change policies conflict with RWE’s fossil-fuel based power generation business.
Conclusion
The misleading information produced by RWE in its safety management plan, along with its flagrant disregard for NFCC guidance should be a warning note to anyone seeking to form a view on whether this planning application should be accepted or rejected. What other misleading information is in their planning application and the supporting guidance?
We shall be pointing out what we’ve uncovered as this website evolves. In the meantime, we urge planners, councillors and residents to pressure RWE to close the gap between their BESS safety plan and the NFCC guidelines in case the application is successful – so that the very real risk to residents and fire fighters is at least reduced.