We have created a draft objection to the BESS application 2024/0501 which we hope will help people to send in their own objections to this planning application.

Objection to Cubico’s Rossendale BESS Planning Application

The Proposed Development by the Applicant is designed to deliver a storage capacity of 85MW. However there are no details of batteries to be used. This is supposedly to allow developers flexibility in selecting the most appropriate equipment based on technical, commercial, and market factors during the procurement phase. This however significantly clouds some of the major issues and risks of the proposal. For a battery energy storage system to be intelligently designed, both power in megawatt (MW) or kilowatt (kW) and energy in megawatt-hour (MWh) or kilowatt-hour (kWh) ratings need to be specified. The charging and discharging speed denoted by its C-rate, which relates the current to the battery’s capacity, is also not specified. The C-rate is a critical factor influencing how quickly a battery can be charged or discharged without compromising its performance or lifespan. It is clear without this information the effectiveness of this proposal cannot be determined

Planning Statement

Executive Summary

From their own statement

The Site is located within the Green Belt and the proposals would comprise inappropriate development. There would be definitional harm by reason of inappropriateness and harm to the openness of the Green Belt. The proposal would also cause harm to the Green Belt through encroachment. This harm to the Green Belt attracts significant weight. There would also be harm to landscape character and visual amenity and a low level of less than substantial harm caused in respect of the setting of grade II listed Fecit Farmhouse with attached stable and shippon

No further comment required!

They then attempt to justify the harm that would be caused saying there are a range of other important considerations which carry substantial weight and which, in combination, significantly outweigh the identified harm

However:

• Battery energy storage is mistakenly promoted as being green energy and even generating energy. This is simply not true. What battery energy storage systems do is store energy that has already been generated from a mixture of sources including coal, gas and nuclear. So clearly it does not enhance the storage capabilities of clean, renewable energy, thereby enabling more effective integration of intermittent renewable energy sources. Also the energy is bought from the National Grid when prices are low, eg at night, and is then sold back when prices are high. In other words, a simple trading operation, akin to buying and selling shares on the stock market.
• The energy supplied back to the grid is limited to only few hours, typically up to 4 hours, unfortunately with this proposal the information is not available
• Battery technology is high carbon in manufacture. So far from reducing GHG emissions, the scheme will result in a net increase in CO2 per KW hour of electricity delivered to the grid.
• This method of storing energy is inherently wasteful as a proportion of it is lost in the process of charging and discharging.

Further they say The limited harm would be temporary and entirely reversible upon decommissioning. 40 years is certainly not temporary and entirely reversible is questionable when it comes to disposing of the batteries!

Context and Need for Development

This section attempts to justify the project on information which is superfluous to this project. BESS systems are neither low carbon nor renewable energy and therefore should not be considered in this context.

Stakeholder Engagement

There appears to have been no consultation whatsoever.

The Application Site

Green Belt – see above in their own statement. Also the proposed site is alarmingly close to several Sites of Special Scientific Interest (SSSIs), ref 2.10, yet the application appears to inadequately assess or address these sensitive areas. This oversight is unacceptable in a development of this scale.

Site Selection and Consideration of Alternative Locations

Cubico has secured the agreement of the Distribution Network Operator (DNO) to  connect the Proposed Development to the Croston Close Road substation, currently scheduled for 2029. The existing Scout Moor Wind Farm is also connected to this substation. Unfortunately The Clean Power 2030 Action Plan (Dec 2024) replaces the “first come, first served” system with a “ready first, connected first” approach. This prioritises projects that demonstrate readiness, such as securing planning permissions and technical designs, thereby discouraging speculative applications and reducing delays. Projects will now be categorised by their planning and site readiness, and new applications must include detailed technical documentation, including Single Line Diagrams (SLDs) and site layout plans. Which clearly makes this project outside that category and therefore at risk to future priority connection to the grid. It is also questionable as to why they consider the connection of Scout Moor 1 wind farm to the sub station as an advantage when it will be decommissioned around 2033.

To state the following is a nonsense:

The Proposed Development will store electricity (that circulating within the network generally and that being generated by Scout Moor Wind Farm specifically) when levels of generation exceed consumer demand and will release it back to the network when required.

3.8 The Proposed Development will, therefore, allow the utilisation of electricity from Scout Moor Wind Farm and other forms of renewable generation more generally to be maximised.

3.9 In order to accommodate a development of the scale and type proposed and to
support the operation of the existing Scout Moor Wind Farm / the electricity grid
Cubico require a site to be located within 2km of the Croston Close Road substation;

The electricity will come from the grid, from a mixture of supplies, not specifically Scout Moor and therefore the need to be near Croston substation is not necessary whatsoever. It could be built near any substation with the same result.

Proposed Development Parameters – The Rochdale Envelope

Giving the excuse that technology is rapidly evolving and applications for consent are commonly made by a developer some time before the procurement of equipment commences, makes a nonsense of the time line of the application and makes the Site Layout plan pure guess work.

Fire Water Infrastructure

The following plan is totally inadequate. Not only is a based on unknown battery specifications, but only provides possible prevention measures and makes no provision for the control thermal runaway occurrence.

3.25 An Outline Fire Prevention Plan (dated March 2025), prepared by Hydrock, accompanies the application. This report details the fire engineering measures and safety protocols that will be incorporated into the design of the proposed BESS development. The plan outlines both preventive and control strategies to mitigate fire
and blast hazards.

What is particularly concerning is the closeness of the special education school, Rossendale School. If fire was to break out the resulting toxic vapour could have a serious hazardous impact on the school pupils.

Batteries constitute a significant fire hazard. While the probability of a fire is relatively low, the hazard can be very significant!

Fire Fighting and Tactical Response

Below is part of the objection to a similar proposal by West Yorkshire Fire and Rescue service, which indicates quite clearly the danger of a BESS. Cubico are, quite clearly, not able to mitigate this risk sufficiently. The provision that has been made for a water tank of 240,000L, pales into insignificance when compared to the requirement of 5,472,000L below!

The risks of vapour cloud, thermal runaway and explosion are unfortunately very real and are becoming more common as we see an increase in the number of BESS installations rise.

There is currently no definitive or ‘preferred’ way of putting out a lithium ion/lithium iron fire. There are in effect two main options, one being to let it burn, the other being to use significant amounts of water for a protracted period.

In this case, should the ‘let it burn’ approach be taken, it may create a chain reaction from one unit to the next. Therefore, even in this case, there is a high possibility that attending crews will require large amounts of water to protect the exposure risks and disperse the vapour cloud (to ensure it remains below the explosive thresholds). This is likely to continue for the period of multiple hours whilst the unit(s) burns itself out.

If we were to let it burn, there would be a significant impact on the highly populated suburbs which would all be significantly impacted from the vapour/smoke plume. It is likely that we require, as a minimum that Kirkthorpe Lane be closed for a minimum of 24 Hours and would suggest that the planning Authority consider this in the application.

To provide a suitable water supply, it would require a water relay from the hydrants in the area, this could impact more roads in the local area once the water relay was in place. There are minimal alternative options for water, however due to the significant amounts we would use, the Environment Agency and Yorkshire Water may need to consider the impact of run off in to the local water courses and Oakenshaw Beck.

Due to the risk involved in these types of energy storage systems, we would deploy minimum staff into the risk area for the shortest amount of time to place ground monitors, with a view that two or three of these would be used to apply water from multiple sides (where possible). Guidance suggests that lithium ion/lithium iron batteries should be doused with significant amounts of water, and ideally subject to full submersion of the batteries for a period of 24 hours.

Taking a two-ground monitor attack for 24 hours, would apply 5,472,000 litres of water (to confirm that is approx. 5.5 million litres). The runoff of these tactics would likely have a significant impact on the surrounding area, we recommend the Environment Agency consider this impact.

Further to this the EA would also need to consider the impact of any ground water seepage and any potential for impact on Yorkshire Water from the contaminated run off filtering through into drinking water.

As previously highlighted, any incident at the site is likely to create a significant Vapour cloud and it may be necessary for us to request that transport routes in the vicinity are closed for a period of 24 hours whilst the incident is dealt with. We recommend that the Planning Authority consider impact this may have.

Yours sincerely, Chris Kemp, Senior Fire Protection Manager

Planning Policy Considerations

Rossendale Local Plan (RLP)

When considering compliance with the RLP, they appear to regard the proposal as a sustainable development. That is debateable. The definition of a sustainable development is a development that meets the needs of the present, without compromising the ability of future generations to meet their own needs. The effect on the land, the fire risk and the disposal of the batteries, both during and after the life cycle, leave a lot to be desired.

Quoting out of context sections from the RLP, the National Planning Policy Framework and other such reports, covering 12 pages, in an attempt to influence the LPA, does not justify this proposal and detracts what should be a transparent and evidence based report.

Green Belt Assessment

Another lengthy (20 pages) attempt to do the work of the LPA, in justifying building on green belt land. The length is probably proportional to the difficulty of the justification!

However there is no compelling reason for this installation to be located on this site, especially when considering the industrial nature of the project, the fact that it could be built near any sub station and its placement in a rural environment immediately adjacent to the main arterial A680 Edenfield to Rochdale Road. While recognising the importance of supporting a low-carbon future, the trade-off between benefits and the significant loss to the greenbelt is weighted against the development.

Technical/Environmental Considerations

This section is based on the numerous lengthy reports, quoted in the conclusion below, which makes the section difficult to assess without constant reference to these superfluous reports. In the time available it is almost impossible to provide detailed constructive comments on this section. Needless to say this may be their objective!

However it can be noted that the proposed site is alarmingly close to several Sites of Special Scientific Interest (SSSIs), yet the application appears to inadequately assess or address these sensitive areas. This oversight is unacceptable in a development of this scale.

Apparently the location is in an area of groundwater vulnerability and is in a Drinking Water Safeguard Zone for surface and ground water.

Also the chosen location will negatively affect key vistas and landmarks, including Peel Tower, Knowl Hill, and the historic Cheesden Valley. These areas are of significant cultural and environmental importance, and the industrial character of the BESS would mar these cherished landscapes. The proposed BESS is not in keeping with the surroundings and more appropriate place for the facility would be an industrial estate or similar.

Conclusion

This is a woeful attempt by Cubico to add another capital project to their portfolio to enhance their sale to new owners. They have dressed the application with excessively long, mainly irrelevant, reports on flooding, ecological, mineral resource assessment, archaeological assessment, air quality, drainage, environmental noise impact assessment, biodiversity net gain, transport statement, and heritage.

This planning application is nothing more than an attempt to promote a project using the government’s net zero policy, without providing adequate technical or environmental impact details and as such should be rejected.