Kent Fire Rescue Service (KFRS) has no authority to approve or decline planning permission for Solar Arrays or Battery Energy Storage Systems (BESS) sites. This decision, in the majority of cases, lies with the Local Authority or National Infrastructure Planning. KFRS will endeavour to provide consultation during this process, however there is no statutory requirement to do so

This is often an ongoing process and not all information is available in the early stages of planning and design. As part of our response to planning applications, we will often request a wide range of additional information be provided to KFRS as part of the planning process. Information requested and received will be able to support our observations during the planning process. It will also provide a basis for design/build stage with the aim of developing a fire management plan (FMP) and emergency response plan (ERP) suitable for the site. 

The safe design and running of these facilities rests with the operator. KFRS will aim to provide technical advice on fire safety requirements to the relevant parties and ensure compliance with fire safety legislation throughout the planning and design phase of the project. Throughout any consultations, we use the NFCC Grid-Scale Battery Energy Storage System Planning Guidance for FRS, which serves as the basis and starting point for any discussions we have with developers regarding BESS. KFRS places safety issues associated with lithium-ion batteries, including BESS, as a high priority. We have spent significant time understanding these issues and applying that understanding to proposed BESS developments. Should a site be developed, KFRS has a dedicated Risk Information Team responsible for creating Site Specific Risk Information (SSRI), where grid-scale BESS forms part of our pre planning in accordance with the arrangements required under Section 7(2)(d) of the Fire and Rescue Services Act (2004). 

KFRS will always aim to work with developers to ensure suitable facilities for safe access to the site is provided. Access routes in rural Kent vary in width, as do the dimensions of KFRS fire appliances. However, our highly trained and experienced appliance drivers are capable of accessing a vast majority of the road network in order to reach all types of buildings and infrastructure sites. Our crews are equipped with a range of tools and trained in various tactics, enabling them to adapt to diverse situations and incident types. 

KFRS personnel conduct risk assessments, and fire crews may also carry out familiarisation visits to ensure they can safely navigate non-standard or narrow routes. This ensures vehicles can manoeuvre through rural lanes and reach a site in an emergency as part of our Site Specific Risk Information (SSRI) Process. KFRS has a dedicated Risk Information Team responsible for creating SSRI. Grid-scale BESS developments are included in our pre-planning in accordance with the arrangements required under Section 7(2)(d) of the Fire and Rescue Services Act (2004). This ensures we are aware of and prepared to respond to incidents that may occur.

For any BESS development, we work with developers to ensure that, as a minimum, water supplies for boundary cooling purposes are available to deliver no less than 1,900 litres per minute for at least two hours. This can be supplied via hydrants or above-ground water tanks. 

The available water supply forms one of the considerations for the tactics selected by the Incident Commander. If nearby water supplies are not deemed adequate for the preferred tactics, KFRS has the ability to supply water to the incident ground with bulk water carriers, high-volume pumps and hose layers.
Grid-scale BESS developments are included in our pre-planning in accordance with the arrangements required under Section 7(2)(d) of the Fire and Rescue Services Act (2004). This ensures we are aware of and prepared to respond to incidents that may occur.
 

The NFCC guidance states “Suitable environmental protection measures should be provided. This should include systems for containing and managing water runoff.” Any potential environmental damage must be mitigated against in the event of an emergency response and be supported with a robust emergency response plan. While KFRS will endeavour to provide consultation in line with this guidance, the onus of environmental containment lies solely with the site operator/owner. 

The statutory consultee best placed to advise on this is The Environment Agency. 
 

KFRS recognises the safety issues linked to lithium-ion batteries, including BESS, as a risk within our Community Risk Management Plan. We’ve dedicated considerable time to understand these challenges and applying that knowledge to proposed BESS developments.

Every site is different and comes with its own risks and challenges. We conduct our own risk assessment for each one, taking into account a variety of factors, including access arrangements. If we identify that access may be an issue, then we will work with the developer to ensure suitable arrangements are put in place. Our plans will take account of those arrangements.

As sites are developed, our Risk Information Team creates Site Specific Risk Information (SSRI) documents. SSRI documents provide detailed information about unique hazards, access points, utilities, and other relevant features of a site. They are designed to equip our operational crews with immediate, practical information to support tactical planning and emergency response. SSRIs play a vital role in enhancing preparedness and ensuring the safety of both the public and our personnel. For grid-scale BESS, developing an SSRI is a key part of our proactive planning in line with Section 7(2)(d) of the Fire and Rescue Services Act 2004.

Yes, KFRS has invested in a comprehensive range of specialised equipment and developed advanced firefighting tactics specifically for lithium-ion battery fires. This includes modern techniques like compressed air foam systems, wetting agents, and advanced tools like fog spikes and Cobra technology. This allows us to implement effective firefighting tactics, even when water supplies are limited.

When it comes to BESS incidents, our preferred response will be to conduct a ‘controlled burn’ and allow the affected BESS unit to burn out under control, whilst using our water to prevent fire spread. We do this to reduce the impact on the environment from fire water runoff, and because lithium-ion batteries are extremely difficult to extinguish. These tactics are not unique to BESS, they are part of our normal operating procedures and are proven to work well.

KFRS support the requirement for on-site firefighting water (either via storage or hydrants) in line with the NFCC guidance. In terms of suppression systems, this depends on the type of suppression system and how it effects the firefighting strategy. There are some designs where a suppression system may not be necessary and, equally, occasions where one may be integral to the safety of the site. We take a risk-based approach to these systems.

The NFCC guidance emphasises the importance of appropriate fire safety measures, including water supplies or fixed suppression systems, when site-specific risk assessments identify them as necessary. While it doesn’t universally mandate these, it encourages early engagement with fire and rescue services to ensure suitable strategies are in place, particularly in remote locations.

Therefore, KFRS considers such requirements to be appropriate where justified by the risk. We support their inclusion as minimum standards in policy, provided they are applied proportionately and reflect each BESS site’s unique characteristics. The NFCC currently recommends that hydrant supplies for boundary cooling should be located close to BESS containers (while ensuring safe access during a fire) and be capable of delivering at least 1,900 litres per minute for a minimum of 2 hours.

In line with NFCC Guidance, the recommended minimum distance between BESS units and occupied buildings or site boundaries is 25 metres. This applies before any mitigation measures, like blast walls, are considered. This initial safety distance is a precaution to address risks from thermal runaway, fire, or explosion, including heat, toxic gas release, and projectiles.

In terms of an exclusion zone around a facility, this will depend on the extent of the fire, weather conditions such as wind direction, and the level of risk to communities (e.g. higher vulnerability locations such as hospitals or care homes). KFRS considers such risks as part of its input under planning and will highlight any concerns.

As the size of an exclusion zone may vary depending on the nature of the incident, KFRS does not define a standard exclusion zone but instead we use our specially trained hazardous materials advisors to make an assessment on a case-by-case basis.

Yes, as per NFCC guidance, during the planning consultation stage, the FRS and the Environment Agency review proposals to assess the risks of toxic smoke and contaminated runoff from battery fires, especially in environmentally sensitive areas. Since each BESS site is unique, these assessments are done case-by-case. We consider factors like battery chemistry, site location, system configuration, and proximity to watercourses or protected land. Our main focus is identifying potential impacts on air quality, surface and groundwater, and soil, while ensuring effective safety, containment, and mitigation measures are in place.

Developers are also required to provide appropriate environmental protection systems, including containment infrastructure to manage fire water runoff. The design and capacity of these systems should account for the expected volume of water used during an incident, including from any fixed suppression systems. Additionally, site operators must prepare a comprehensive Risk Management Plan and Emergency Response Plan, that thoroughly address environmental hazards and demonstrate appropriate control measures for a coordinated multi-agency response.

As a non-statutory consultee on BESS developments, KFRS has not issued any formal, standalone advice specific to siting BESS in Kent and Medway. Instead, we use the NFCC Grid-Scale Battery Energy Storage System (BESS) Guidance to inform our responses during the planning consultation process. This nationally recognised guidance provides a risk-based framework for assessing the fire safety, environmental, and operational considerations. It helps us make consistent, evidence-based decisions for all proposed sites in our area.

Yes, our crews are receiving specialist training in battery fire response as part of our ongoing preparedness for emerging risks like energy storage systems. KFRS has been actively involved in shaping national best practices in this area. For example, our Director of Response and Resilience, Matt Deadman, supported the development of the NFCC Grid-Scale Battery Energy Storage System Guidance in his role as the Alternative Fuels and Energy Lead Officer for the NFCC. We believe the current national guidance is both robust and fit for purpose, offering a comprehensive, risk-based framework for planning, operational response, and multi- agency coordination. It continues to evolve with industry developments, and we remain committed to ensuring our crews are trained and equipped according to this guidance.

KFRS supports a risk-based approach to siting BESS developments. We would not take a position of resistance to siting BESS in rural areas as a standard approach, as it is possible to safely site BESS in the right rural locations. Our approach is focused on the unique nature of each site, and we will provide comments under planning with those unique factors in mind. If we feel that arrangements for minimising risk and facilitating an effective response are not suitable, then we will raise such concerns and request suitable mitigations are put in place or advise that the site location is unsuitable.

In addition to the current arrangements under planning, we would also like to see:

The creation of an overarching framework and UK standard for the safe deployment and operation of BESS. This should be supported by technical standards and include clear guidance on the design and suitable locations for BESS, taking into account potential impacts of BESS on Critical National Infrastructure, any sensitive environmental receptors, local communities, and the need to ensure effective FRS preplanning and operational response in the event of a fire.

BESS included in the Environmental Permitting Regulations 2016 at the earliest opportunity.

FRS concerns and advice taken into account and responded to when they are engaged about fire safety risks in BESS planning applications. There is currently no statutory requirement for developers to demonstrate how they have addressed FRS comments. We would like to see this addressed.