The Scottish Government has published new planning guidance to help applicants, decision makers and others involved in the implementation of battery energy storage systems (BESS) projects.
The new guidance specifically refers to the planning process of network-scale BESS projects under the Town and Country Planning (Scotland) Act 1997, and the Electricity Act 1989 in relevant cases.
The guidance will prepare applicants for the planning process to ensure a BESS site is appropriately sited and designed in the early stages of development. To assist Scotland’s BESS industry, the guidance also summarizes the relevant legal requirements.
“Battery energy storage systems will play a role in Scotland’s transition to a low-carbon, resilient and efficient energy system by supporting the stability of the electricity grid,” said Ivan McKee, Chancellor of the Exchequer.
“This new planning guidance will support all parties in the planning process. It recognizes that BESS remains an evolving sector, with few operational sites and the potential for battery technologies to change in the future.”
The guidance does not change existing planning policy or regulations in Scotland and does not serve as a list or overview of all potential issues that may arise when planning a BESS site.
The government’s announcement states that applications for energy infrastructure will be assessed on a case-by-case basis. Applications are assessed based on relevant policy and existing legislation, the individual context of the location, consultation and public input.
In accordance with UK NSIP guidelines
The guidance addresses several features of the policy framework and decision-making considerations that BESS planners may consider noteworthy.
For proposals of 50 MW or less, the guidelines refer to the already existing document Planning Circular 3/2022: Development Management Procedures, which goes into more detail about the procedures behind a processed application. These depend on whether the regulations consider a proposal to be a ‘national’, ‘major’ or ‘local’ development.
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National developments, found in National Planning Framework 4 (NPF4), indicate major developments “of national importance” for Scotland. NPF4’s National Development 3 includes the storage of renewable electricity with a capacity of more than 50 MW
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Major developments are defined in Schedule 1 of the Regulations and include BESS of 20 MW or greater
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Local developments include all other developments not classified as National or Major
The guidelines bring Scottish policy in line with Great Britain’s Nationally Significant Infrastructure Projects (NSIP), which focus specifically on England and Wales.
Promoting cooperation
The Scottish Government’s announcement highlights that the guidelines are intended to promote collaboration between BESS planners, consultants and the public.
Best practice dictates that applicants should liaise with the Scottish Fire and Rescue Service (SFRS) at an early stage in the development of the proposal; however, they are not a mandatory consultation. If a site proposal is not in accordance with the SFRS proposed NFCC guidelines and other relevant requirements, a decision maker may review the application accordingly.
The guidelines note that some project information may be immutable depending on technology and operational details. Nevertheless, BESS applicants are encouraged to be transparent about the project’s location, scale, appearance and impact on the environment and local features.
Applicants are further discouraged from finalizing the layout of the BESS site before permission has been granted. If they need to adjust expectations, best practice recommends transparency in communicating the change and its cause, and collaboration with the decision maker on the terms.
Environmental planning
The guidelines encourage applicants to consider the environmental impacts of their project, taking the natural landscape into account when designing a project and during site selection. Best practice includes selecting sites with minimal visibility, such as brownfield sites, and avoiding open, exposed spaces where development will mask the landscape.
Applicants must also consider the aquatic environment from the initial stages. This includes considering local water bodies, flood risks, drainage, groundwater, wetlands, peat and carbon-rich soils and any pre-existing infrastructure.
In addition, applicants must take into account the noise emissions that BESS sites produce due to the systems and equipment, especially as they operate 24/7. It identifies common noises as a “tonal hum” or a “buzz” that can cause ambient noise pollution in quiet, rural areas or contribute to noise pollution in industrial areas.
The National Planning Hub, a Scottish Government-led initiative to support planning authorities with decision-making, commissioned the new guidance. It was prepared by Ironside Farrar, an independent environmental consultancy, with input from others including:
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The Scottish Environmental Protection Agency (SEPA)
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The Scottish Fire and Rescue Service (SFRS)
You can find the full guidance here.
