Dear Sir or Madam I am writing in relation to the further consultations on this application and the very significant changes to the original presentation. National Grid SeaLink proposal raises serious concerns. I know the area well but anyone considering the topology will see that the development is on land prone to flooding, it's not known as Minster Marshes for no reason. It is waterlogged all year round and most of the land is only 1 or 2 metres above sea level. National Grids own documentation states that marshland or boggy land is not suitable for these types of projects, as a result this development will raise the height of all structures by 2 metres. The following applications submitted to Thanet District Council in relation to the BESS Plant: F/TH/20/1467, F/TH/21/0305 and F/TH/24/0034, the last of which is still to be determined, demonstrates how difficult the land is for many types of developments where water could create serious concerns. This development has also had to be raised by 2m across the entire site. The initial plans were to use a system of SUDs to manage rainwater which was obviously not possible given the shallow nature of water across the entire area. This demonstrates extremely poor planning and preparation which, I believe, is a thread throughout the project. Raising the ground level for the SeaLink project will require many thousands of tons of aggregate, raising the following concerns: 1. How will this be brought to site? 2. Where will this aggregate be sourced? 3. Will the aggregate be free of all forms of contamination? 4. How will the run off through and over this imported material, not native to the area, impact on the hydrology of ground water and the hydrology of the Marshes, the SSSI, Minster Stream and River Stour? During the members briefing to TDC Councillors the SeaLink Team were asked how the run off will be managed. Initially they said pools or ponds would be created but, when it was explained to them about the water table height their response was that the pools/ponds would be built above ground. The conclusion is that the base of the pools/pond will have to be raised. This, off the cuff, thinking gave no clarity or detail about how much run-off was expected or how the system would cope with climate change - a very low-lying area, already saturated. When pressed about excess run-off Council were told it would be released into the Minster Stream despite the well-known presence of the critically endangered European Eel. Again, no consideration was given to negative impacts from large amounts of run-off or changes in water course pH due to the aggregates upon land and water-based biodiversity. In order to make this marsh-land viable the project has to use 'pile drivers' in attempts to find or create a stable platform to build on. This is flat land where noise and vibrations will carry, not only through the air but through the saturated marsh land. No concern has been expressed for the existing biodiversity or the residents and businesses of Cliffsend and Minster. This proposal will require 1000's of lorry trips to and from the site that will create excessive disruption and require further damage to existing environments. Besides the flooding risks and the range and extent of greatly protected marine and land based environments on and close to the site, SeaLink have no measures to address the very wide range of wildlife and habitat on site and in the area, in particular those with high levels of protection; Grey Herons, Little Egrets and Nightingale for example. The updated plans also seem to mean the cutting of a road through the woodland at the top of Jutes Lane but sadly there seems to be absolutely no mention of how the loss of this valuable mature woodland will be mitigated. Tree coverage in Thanet is 4.4%, one of the lowest in the world and as such the loss of mature woodland needs to be prevented. Given the significance of the area much data is available and continues to be collected by statutory bodies as well as locals with nationally recognised expertise and interest in the area. However, SeaLink has made no efforts to reach out to these organisations/people and so gain a more accurate understanding of the wildlife that exists. The proposed converter site appears to cover a dyke and scrub hedgerow an important area where the ringing of birds takes place on a regular basis, where Brown Hare and Badgers feed, all of which needs to be appropriately mitigated for and prior to any serious work begins, if the DCO is successful. Key areas have been identified but Council members were told this is farmland and an existing strip along the river that will be "enhanced". The implication being that this is not a new area needing mitigation. There was no mention of impacts on the loss of farmland or how the loss of farmland might make the farm unviable. I was relieved to see that TDC's CEO had ruled out the use of the Pegwell Hoverport site due to its proximity and exceptional wildlife, I have observed both Lizard orchids, one of the rarest in the UK and Pyramid Orchids on the site this year. SeaLinks poor planning, preparation and lack of consultation is further demonstrated in their view that the Hoverport site was a brownfield 'post-industrial wasteland' instead of a rich area of increasing biodiversity. The plans have also doubled the marine area, covering almost the whole of Pegwell Bay, a national and international site of marine importance. The reason given was to 'anchor ships', but there was no answer suggesting this expansion was necessary. Of more concern is that any ships entering Pegwell Bay will cause significant damage to the sea beds with obvious pollution from fuel and other waste materials. Though not stated by SeaLink the obvious conclusion is that they intend to dredge the Bay to allow medium and large vessels to navigate the very shallow waters. This form of disruption will cause massive damage to habitats and biosystems as well as marine protection areas. Further damage will be done to Pegwell businesses and those further afield who rely on visitors and tourists, the protected marine and land sites being of particular interest. This said, the SeaLink Team gave no consideration to the thousands of residents who will be prevented from the quiet enjoyment of their home areas. The SeaLink team proposals pay no attention to the 'cumulative impact' of the various developments already operating, approved yet to be built or submitted to Dover District Council, Thanet District Council or Kent Country Council. These are many and varied with some presenting a considerable fire risk. The 249 MWh Bess Plant that is close by represents was approved, the first 2 phases which are now operational and built partly on land with a flood risk level of 2/3 where the base was raised 2m to address this. Lithium battery BESS are an emerging technology. The international BESS trade conference in 2021 reported over 30 significant BESS fires/explosions and we have seen many more since, particularly the Liverpool incident of 2023. The Liverpool site was a 20MWh while ours is far bigger. Therefore one would expect National Grid to be taking account of the various laws and regulations in planning and operating their BESS. Reading their plans it is clear that much of their submission is superficial while a lot is also misleading. I attach guidance published by UK Government earlier this year relating to BESS, one can easily see that National Grid's operation and intentions are far from being legally compliant; I attach my list of questions (sent to the Secretary of State on 8th April 2024 and again on 25th July 2024 following the General Election changes), based on their planning applications, that illustrate how far from compliance, and basic safety, the operation is. BESS fires do not need oxygen to burn making fire fighting extremely difficult for Fire Brigades. Lithium fire experience shows batteries can ignite with no apparent fault in their manufacture making any and all BESS sites a foreseeable risk. The size of the Richborough BESS makes it imperative that robust fire management is in place, but it is not. My attached question document details the following points but I have put them here for ease of reference: o no lithium cell chemical reaction heating detection o no cell cooling system o no fire-fighting arrangements specific to battery failure fires and thermal run-aways o a long and fragile communication chain before Kent F&R are informed of an incident o a many stepped and unclear process before of fire fighters can access the site safely o wind taking toxic smoke over the fire-fighting water tank and access points o the inadequate quantity of water in the fire fighting tank for this site size o no plan for a failed battery cell explosion at the centre of the battery array o no plan for heating from a fire/explosion causing a runaway chain reaction in battery cells in neighbouring containers o no major incident plan to manage population centres, environments and transport at threat from toxic plumes and contaminated fire-fighting water run-off? o no details of UK regulatory compliance o failure to acknowledge BESS industry best practice in planning site operations and emergencies o failure to demonstrate any learning from recent BESS fire and explosion events. The nearby BESS Plant, the Solar Farm, Grid Stability Plant and any future developments require an overall fire management plan. How will fire risk be minimised, how will fire spread be addressed, how are owners and operators of the various developments involved in a shared Fire Risk management plan for the entire Richborough site and beyond. The environment and nearby residential and business properties, towns and villages have to be protected from fire, toxic fumes and toxic water. The proposed site is an area of increased flood risk, to date the land has acted as a large 'sponge', naturally soaking up water in periods of heavy rain and exceptional high tides. The KCC Sandwich Town Tidal Defences document of August 2016 describes this, 'the biggest tidal surge in 60 years hit the east coast on Friday 6 December 2013'.This affected the entire area but water was able to sit and drain naturally with Minster Marshes playing a vital part in avoiding a catastrophic event. The Environment Agency deployed flood defences preventing serious flooding over the course of 3 exceptional high tide and the storm surges. SeaLink covering large parts of the Minster Marshes as well as Richborough with aggregate to raise the land, buildings and other infrastructure which is not porous will prevent the land’s ability to soak contain and drain the water naturally. The excess rain run-off due to the buildings and non-porous aggregates will simply add to this scenario. Add to this a warmer and wetter climate, rising sea levels and associated rise in ground water levels and one sees the combined effects of these developments. The likely outcome of the cumulative impact will be increased flooding on site and adjacent areas putting Minster Village and the Weatherless Sewage Treatment site at greater risk than they already are. In addition, Minster Stream and River Stour will be overwhelmed as these elements discharge into them. This development will result in 4-years of constant disturbance, in what is presently a quiet tranquil place of great biodiversity, close to greatly protected land-based and marine environments as well as Richborough Fort a site of significant heritage and the villages of Cliffsend, Pegwell and Minster. The size and scope of the buildings, above surface pools/ponds, pylons, the existing ones of which have already resulted in the death of over 170 mute swans in a single event, is simply negligent. The structures, sitting in such a low-lying area, will be clear for miles around creating a massive blot on our landscapes. The Sealink Team mentioned the port of Ramsgate and, with their need for considerable amounts of aggregate, this undertaking will have impacts on the people, buildings, roads and businesses of the town, as lorries make their way from the port to the Minster Marshes. The impact on tourism a key economic driver for the area has not been explored at all. 4-years of blocked roads, construction work, restricted areas, footpaths closed, loss of environment to explore will be appalling. In summing up, the Sealink Team could not have picked a more inappropriate place due to its environmental importance, land-based and marine biodiversity, access, potential on site and off site flooding, cumulative impact of a number of development close by, noise, visual impact, migrating bird strikes on pylons, proximity of villages/towns as well as the lack of opportunities for meaningful and appropriate mitigation. Their failure to consider fire safety, chemical management, fire safety and civil contingencies could not have been worse. I am a supporter of the drive for clean energy but this project is a shocking example of the disregard shown for the our delicate environments and communities in a profit led rush by National Grid. Every aspect of this project demonstrates their aim to maximise financial gain over every other consideration. Yours faithfully Garry Saunders FIOSH Ramsgate, Kent.

Dear Garry Thank you for your email. The proposed application for the Sea Link Project is currently at the Pre-application stage of the Planning Act 2008 process. Further information about the process can be found in the link below to the National Infrastructure Planning website: The stages of the NSIP process and how you can have your say. The Planning Inspectorate is unable to consider representations about the merits of any application until it has been submitted and accepted for Examination. We note that you have also sent your email to the developer of the proposed project (National Grid). As the application has not yet been formally submitted to the Planning Inspectorate any comments concerning the merits of the proposed development should be submitted directly to them: Email: [email protected] Telephone: 0808 134 9569 Post: Freepost SEA LINK It is important that the developer is made aware of your comments at the Pre-application stage to enable them to consider the points raised before finalising their proposals and submitting the application. Should the application be accepted for Examination you will be able to register as an Interested Party by submitting a relevant representation. This must be submitted on the ‘Registration and Relevant Representation form’ which will be made available on the project webpage of the National Infrastructure Planning website at the appropriate time. Further information about registering as an Interested Party can be found in the Planning Inspectorate’s ‘Advice Note: Nationally Significant Infrastructure Projects: How to register to have your say and make a relevant representation - GOV.UK (www.gov.uk) You may also find it helpful to subscribe to us to receive email notifications for key events that occur after an application has been submitted to the Planning Inspectorate. This can be done by selecting ‘Get Updates’ on the Planning Inspectorate’s project webpage and then entering your email address: Sea Link - Project information (planninginspectorate.gov.uk). Kind regards