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Flexion Energy UK Storage: Proposal of Application Notice for Installation of a Grid Battery Energy Storage Facility (Up to 50 Mw), with Associated Development: Land West of Ardnadam Electricity Sub Station, Sandbank (Ref: 22/00998/Pan)

Argyll and Bute Council · 22 June 2022
Back to Planning, Protective Services and Licensing Committee — 22 June 2022 and its agenda

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Argyll and Bute Council 
Development and Economic Growth   
PROPOSAL OF APPLICATION NOTICE 
____________________________________________________________________________  
Reference: 22/00998/PAN
Applicant: Flexion Energy UK Storage 
Proposal: Proposal of application notice for installation of a grid battery energy storage facility
(up to 50 MW), with associated development 
Site Address:  Land West Of Ardnadam Electricity Sub Station, Sandbank
____________________________________________________________________________ 
1.0 INTRODUCTION 
Proposal of Application Notices only relate to National and Major Applications as defined
by the Government’s planning hierarchy and are a statutory requirement prior to the
submission of the planning application.  The PAN heralds the start of a minimum 12 week
period to allow for community consultation before an application can be lodged. 
In considering this item Members should restrict comments to issues relating to the
material considerations which may be relevant in the determination of the proposed
development and should refrain from expressing opinion as to the likely acceptability of
development in advance of any subsequent application being presented for determination.
Any opinions or views expressed by Councillors at the pre-application stage must be made
mindful of the overarching requirements of fairness and impartiality and of keeping an open
mind. The process provides opportunity for Officers to give feedback to the prospective
applicant on issues which Members would wish to see addressed within the planning
application submission. 
The applicant has confirmed that they intend to undertake community consultation in line
with the requirement of the Town and Country Planning (Miscellaneous Temporary
Modifications) (Scotland) Regulations 2022 which came into force as a result of the
COVID-19 Pandemic. These Regulations have suspended the requirement for a physical,
face-to-face public event with an alternative, online version.  This temporary guidance has
been extended until September 2022. 
In accordance with the above legislation the following public consultation is proposed for
the above project: 
 An online consultation event, with live chat facilities where members of the Team
are on hand to answer questions directly;
 The online consultation event will take place in June 2022 (date TBC) on a
dedicated website. Exhibition material, detailing the proposed development, will be
uploaded for viewing on the website. It will also have live chat facilities to allow the
public to ask direct questions of the Project Team about the proposed development;

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 The exhibition material will remain available online, alongside the questionnaire /
feedback form, for a minimum period of 3 weeks to allow feedback to be completed
and returned to the Project Team;
 Separate, direct engagement will be offered to Sandbank Community Council via
video or phone call. If a suitable format cannot be arranged, then they will have the
opportunity to comment through the main online consultation event or can contact
the Project Team directly via email. 
Officers are content that the proposed steps accord with the current legislation with regard
to pre-application consultation on Major applications. 
The Proposal of Application Notice took effect from the 25th May 2022 and as such no
formal Planning Application relative to this proposal can be made before 17th August 2022.   
2.0 PROPOSAL AND SITE DESCRIPTION 
A letter from the Scottish Government’s Chief Planner dated 27th August 2020 stated that
“The Scottish Government considers that a battery installation generates electricity and is
therefore to be treated as a generating station.  As a result, a battery installation should
be treated as any other generating station for the purposes of deciding whether Section
36 consent is required for its construction and operation”.  In this case, as the generating
capacity would be greater than 20MW and less than 50MW this would be a Major planning
application. 
The site which currently appears to be rough grazing land measures less than 1 hectare
and is rectangular in shape.  It is located to the west of the electricity sub station at
Ardnadam and to the south of Ardnadam Farmhouse.  It slopes from a level of
approximately 70m AOD along its south western boundary to 62m AOD on the north
eastern boundary.  It is advised that the generating capacity would be no more than 50MW. 
Access would likely be taken from the north east of the site although at this stage this is
indicative only.  The applicant has advised that a development of this type would include
the following: 
• Battery energy storage modular racks, typically with indicative size of c.2.28m high
by 1.3m wide by 1.3m long;
• MV Skids (Power Conversion System, Transformer and Ring Main Unit together)
with an indicative size of  c.2.9m high by 2.5m wide by 6.1m long;
• A switch room, control room and storage locker with an indicative height of c.3.5m
and indicative size 5x15m for the switchroom and 5x5m for the control room;
• Fencing around the site boundary, which will be “V” mesh security fence, 2.4m in
height;
• Lighting and infrared CCTV columns with an indicative height of 4.5m; and
• Associated infrastructure (access, drainage etc). 
3.0 DEVELOPMENT PLAN POLICY 
PAN submissions are not planning applications and therefore do not require to be
evaluated and determined in accordance with Section 25 of the Planning Act against the
Development Plan and its policies at this stage. In considering the merits of the PAN a

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number of Development Plan Policies will inform the assessment of any future detailed
application as set out below: 
‘Argyll and Bute Local Development Plan’ Adopted March 2015 
LDP STRAT 1 – Sustainable Development
LDP DM 1 – Development within the Development Management Zones
LDP 3 – Supporting the Protection Conservation and Enhancement of our Environment
LDP 5 –Supporting the Sustainable Growth of our Economy
LDP 6 – Supporting the Sustainable Growth of Renewables
LDP 8 – Supporting the Strength of our Communities
LDP 9 – Development Setting, Layout and Design
LDP 10 – Maximising our Resources and Reducing our Consumption
LDP 11 – Improving our Connectivity and Infrastructure 
‘Supplementary Guidance to the Argyll and Bute Local Plan 2015’ (Adopted March
2016)  
Natural Environment
SG LDP ENV 1 – Impact on Habitats, Species and our Biodiversity
SG LDP ENV 5 – Development Impact on Local Nature Conservation Sites (LNCS) 
Landscape and Design
SG LDP ENV 14 – Landscape 
Historic Environment and Archaeology
SG LDP ENV 19 - Development Impact on Scheduled Ancient Monuments
SG LDP ENV 20 - Development Impact on Sites of Archaeological Importance 
Support for Business & Industry: General
SG LDP BUS 2 – Business & Industry Proposals in the Countryside Zones 
Sustainable Siting and Design
SG LDP Sustainable – Sustainable Siting and Design Principles 
Resources and Consumption
SG LDP SERV 2 – Incorporation of Natural Features / SuDS
SG LDP SERV 3 – Drainage Impact Assessment
SG LDP SERV 5(b) – Provision of Waste Storage & Collection Facilities within New
Development
SG LDP SERV 9 – Safeguarding Better Quality Agricultural Land 
Addressing Climate Change
SG LDP Sust Check – Sustainability Checklist 
Transport (Including Core Paths)
SG LDP TRAN 4 – New & Existing, Public Roads & Private Access Regimes
SG LDP TRAN 6 – Vehicle Parking Provision 
4.0 POTENTIAL MATERIAL CONSIDERATIONS

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One of the main determining issues in terms of this development will be the consideration
of the likely landscape and visual effects of this development within the countryside zone. 
5.0 CONCLUSION 
This report sets out the information submitted to date as part of the PAN. The policy
considerations against which any future planning application is likely to be judged against
and potential material considerations are noted above. The list is not exhaustive and
further matters may arise as and when any planning application is received, and in the
light of public representations and consultation responses. 
6.0  RECOMMENDATION 
It is recommended that Members have regard to the content of the report and submissions
and provide such feedback as they consider appropriate in respect of the PAN to allow
any matters to be considered by the applicant in finalising any future planning application. 
Author of Report: Sandra Davies    Date: 27th May 2022 
Reviewing Officer: Peter Bain     Date: 7th June 2022