E - 26-0138-EAC East Fulwood BESS FINAL
Renfrewshire Council · 26 May 2026
Back to Planning and Climate Change Policy Board — 26 May 2026 and its agenda
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Report by Chief Planning Officer Planning and Climate Change Policy Board: 26 May 2026 Reference No 26/0138/EAC Application Type Electricity Act Consultation Proposal Installation of a Battery Energy Storage System (BESS) and associated infrastructure with a generating capacity of 400MW Location Site on northwestern boundary of East Fulwood Farmhouse, Houston Road, Inchinnan Ward 12 – Erskine and Inchinnan Community Council Inchinnan Community Council Applicant Energy Consents Unit (ECU), Scottish Government Recommendation Objection for the reason(s) outlined in the foregoing assessment All plans, reports, documents, and representations relating to this application can be viewed in full online at https://www.energyconsents.scot/ApplicationDetails.aspx?cr=ECU00006230 The purpose of this report is to present for the consideration of the Planning and Climate Change Policy Board a formal consultation from the Energy Consents Unit (ECU) on an application made under Section 36 of the Electricity Act 1989 for a 400MW Battery Energy Storage System (BESS) on land at the northwestern boundary of East Fulwood Farmhouse, Houston Road, Inchinnan. The Section 36 application includes an application for deemed planning permission for the same development under Section 57(2) of The Town and Country Planning (Scotland) Act 1997. Scottish Ministers are responsible, under Section 36 of the Electricity Act 1989, for the authorisation of any new, or extensions to existing, electricity generation schemes with a generation capacity in excess of 50 Megawatts (MW). As the proposed BESS would have a maximum installed capacity of 400MW, Renfrewshire Council has been formally consulted on the proposed development by the ECU. The Council is a formal consultee in this process and not the determining or consenting authority. Scottish Ministers are the determining authority. In procedural terms the Council, as Planning Authority, requires to provide a consultation response to the ECU that would then be taken into consideration as part of the overall consenting process. The consultation request from the ECU was received on the 11th February 2026, with a response deadline of the 11th June 2026. While the consultation response would normally fall within the approved Scheme of Delegation to be determined by officers, the Scheme of Delegation allows for officers to refer applications to the Board. The application has been refered in this instance to allow the proposed development to be fully considered given the scale of the development and the potential environmental matters associated with BESS developments. Members should note that the procedures for dealing with applications made to Scottish Ministers for consents under Section 36 of the Electricity Act have been modified by the Planning and Infrastructure Act 2025. Previously, a timeous objection from a Planning Authority to an application for consent under Section 36 would require Scottish Ministers to hold a public inquiry in instances where the
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objection is not subsequently withdrawn or cannot be resolved by conditions or modifications. However, the requirement to hold a public inquiry no longer applies. Instead, a reporter led examination process will apply, where a Planning Authority objects to an application and that objection is not withdrawn, or cannot be resolved by conditions or modifications. These changes came into effect on 18th February 2026. Where a Planning Authority objects to an application on or after the 18th February, the new process under paragraph 2(2A) of schedule 8 of the 1989 Act (as amended by The Planning and Infrastructure Act 2025) shall apply and a reporter will be appointed to carry out an examination unless that objection is withdrawn or cannot be resolved by conditions or modifications. Proposal and Site Description The proposed development is for a BESS with a generating capacity of up to 400MW. The application site extends to 67.19 acres/27.19 hectares in area and is broadly rectangular in shape. The topography is flat and generally low lying. The southern half of the site is in agricultural use, while the northern half of the site is found to be scrub grassland. To the west the site is bounded by the M8 motorway. Access to the site will be taken from the B790 Houston Road which bounds the southern edge of the site. To the north and east the site is bounded by similarly flat and low-lying agricultural land. East Fulwood Farmhouse is located adjacent to the eastern boundary of the application site. Further residential properties known as East Fulwood Cottage and Carbury are located adjacent to the southeast corner of the application site on the southern side of Houston Road. The BESS development comprises of the following key elements: Up to 267 BESS enclosure units each up to 3.2m in height. Up to 89 Inverter units each up to 2.6m in height. Substation compound including several structures and buildings extending up to 12 metres in height. Up to 15 auxiliary transformers each up to 3.3 metres in height. Up to 15 back-up generators each up to 2.9 metres in height. Up to 15 spares containers each up to 2.6 metres in height. Up to 45 CCTV cameras and 534 lighting poles each up to 3.8 metres in height. Wire mesh security fence up to 2.5 metres in height. Access and tracks. Total length of internal access tracks approximately 3106 metres. Landscaping and biodiversity enhancements. The BESS development covers approximately 12.6 hectares of the total application site area. It is located within the northern half of the site. To the west there is a proposed landscape buffer between the BESS and the M8 motorway. The southern half of the site includes two access tracks and a temporary construction compound area. Following the construction phase, this area will also be landscaped. Within the BESS layout itself the enclosure units, inverter units and auxiliary transformers are positioned towards the northern end of the site, with the substation compound positioned towards the southern end of the site. The applicant has advised that the proposed development represents an indicative design and layout. It is noted that battery technology is continually advancing and becoming more efficient. On this basis, the applicant has requested a condition whereby details of the final
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site layout and design of the component infrastructure are submitted for approval before development can commence. Pre-Application Consultation with Officers The Scottish Government strongly encourages constructive pre-application discussions between prospective applicants and the planning authority. Pre-application discussions seek to identify key planning considerations at an early stage and help inform what supporting information is required to support a subsequent application. Pre-application discussions have taken place, focusing on the following key matters: The visual impact of the proposals, and the consenting process. Negotiated Improvements No changes have been negotiated. Site History (if applicable, site history will be listed here) None Consultations undertaken by the Council Glasgow Airport Safeguarding – No response at time of writing. Scottish Environmental Protection Agency (SEPA) – Refer to response provided to ECU. Note that they assume all Section 36 applications meet the criteria for exception under NPF4 Policy 22 unless advised otherwise by the ECU. Transport Scotland – No objections subject to conditions relating to abnormal loads movements on the trunk road network, additional signage and temporary control measures, and the submission of a Construction Traffic Management Plan. Network Rail – No objection subject to condition relating to the submission of a finalised Fire Risk Management Plan, Fire Emergency Response Plan, and DSEAR Compliance Statement and Fire Safety Design Note. Environmental Protection – No objection subject to condition relating to noise from plant, machinery, and equipment. National Air Traffic Services (NATS) – Object due to concerns that unmitigated, the proposed development has the potential to degrade the performance of the Brownsfield Radar System. However, advise that they believe the identified impact to be mitigatable. Chief Executive's Service Roads Development – No objection subject to conditions regarding the configuration of the site access, sightlines, and delivery of potential active travel enhancements. Scottish Power Networks (Transmission Sites) – No comments. Scottish Power Networks (Distribution Sites) – No objections. Scottish Gas Networks (SGN) – Objection pending completion of a site meeting to identify the location of the pipeline and discuss measures neccesary to safeguard the security of the pipeline.
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NatureScot – Objection pending further assessment of the implications of what would be further loss of arable agricultural land for the capacity of the local landscape to continue to support important numbers of overwintering whooper swans. West of Scotland Archaeology Service (WoSAS) – No objection subject to condition requiring submission of a programme of archaeological works. Inchinnan Community Council – Object on the following grounds - unsuitable scale and location, harm to visual amenity and local character, traffic and construction disruption, noise and impact on residential amenity, safety concerns, and better sites should be considered. Councils External Drainage Consultant (Dougall Baillie Associates (DBA)) – DBA were asked to review and provide comment on the following aspects of the submission. Flood Risk Assessment and Drainage Impact Assessment (by Neo Environmental dated 16/12/2025) - The flood risk assessment notes that the proposed development is classified as “essential infrastructure” which we are in agreement with. The assessment however is based on the flood extents from the SEPA Indicative Flood Maps to define the Flood Area and demonstrate the development is located outwith the Flood Area. The access track is located in the Flood Area, however no information on the access track has been provided or mention of any impacts this may have on the Flood Area. The SEPA maps are large scale indicative maps and we recommend that a site specific detailed Flood Risk Assessment is conditioned to ensure no development is located in the Flood Area and construction of the access track will not have a negative impact on the flood areas ability to store or convey flood flows. We are in general agreement with the principles of the high-level Drainage Impact Assessment, however the report notes surface water flows should be limited to QBar rather than Renfrewshire Councils requirement of the 1 in 2 year greenfield runoff rate. A detailed Drainage Impact Assessment including all detailed drainage layouts and supporting calculations should be conditioned to ensure a suitable and compliant drainage solution is being provided. Councils External Landscape, Ecology and Environmental Consultant (Ironside Farrar Ltd (IFL))- IFL were asked to review and provide comment on the following aspects of the submission. - Ecological Assessment by Neo Environmental (dated 16/12/2025) - The Ecological Assessment and Biodiversity Management Plan place relatively heavy emphasis on generic policy and methodological text but provide limited quantified, site specific evidence for habitat value, species importance, habitat losses and gains, or the performance of proposed mitigation and enhancement measures. The conclusion that all habitats within the development footprint are of low ecological value is not adequately substantiated. This consultee recommends that the Council requests the supplementary information outlined in the audit response, including a full habitat schedule and balance, explicit identification and valuation of Priority Habitats, a clearly articulated evaluation framework and VERs table, more detailed species-specific assessment and mitigation, an updated and quantified BMP/LEMP tied to an agreed landscape plan, and supporting photographic evidence. We further recommend that the Council reserves its final position on ecological impacts and NPF4 compliance until the requested information has been provided and reviewed.
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- Arboricultural Impact Assessment, East Fulwood (January 2026 by Bowland Tree Consultancy Ltd) – Report is clear and comprehensive, and methodologies are appropriate and in line with best practice. Tree Survey Schedule, Tree Constraints Plan and Tree Impact Plan are provided. However no Arboricultural Method Statement of Tree Protection Plan is provided. It is noted that trees, groups and hedges adjacent to the site can be adequately protected. However further details regarding tree protection fencing is required. - Landscape and Visual Impact Assessment East Fulwood BESS (December 2025 by Neo Environmental) – The assessment is largely adequate in scope and reasonable in its findings. While some of the effects would be assessed as being slightly higher, the broad conclusions are agreed with. In this regard it is considered that the proposed development would have only localised effects to landscape character of the site and immediate surrounds. This flat and relatively well enclosed farming landscape, adjacent to the M8 motorway, includes no landscape designation and is considered able to accommodate the type of development proposed. Existing woodland provides some enclosure to the proposed development, while mitigation planting should in time aid with the integration of the development into the landscape. Some notable visual effects would occur to visual receptors on the local Core Path network, the adjacent road network and to one nearby property all within 0.5km, however over time these effects will reduce as planting proposals mature. - Outline Battery Safety Management Plan (Issue 1 December 2025) - Provides a clear and structured overview of the key safety considerations associated with the proposed BESS development. The submission is at an outline stage, and while alignment with National Fire Chiefs Council (NFCC) guidance is indicated, this is often presented in principle and is dependent on further design development. As such, the Outline Battery Safety Management Plan does not fully demonstrate a site- specific safety case at this stage. The document confirms that a more detailed Battery Safety Management Plan (BSMP) will be prepared prior to construction, which will include further detail on system specification, emergency response and contingency arrangements. In the absence of this detail, it is likely that certain elements of the safety strategy, may need to be secured through planning conditions as the design progresses. However, a more detailed articulation of safety measures at this stage, particularly in relation to layout, emergency response and firewater management, would strengthen alignment with current Scottish Government guidance and emerging best practice. - Planning Statement by Neo Environmental dated 12/01/2026 - The Planning Statement presents a clear and policy-led justification for the proposed BESS development, with particular strength in its alignment with national energy and climate objectives. While local policy considerations are acknowledged, these are generally secondary to the national policy position. The document is well-structured and consistent, though it relies on supporting technical reports and future conditions to address detailed impacts. - Outline Construction Environmental Management Plan (by Neo Environmental dated 15/12/2025) (also includes review of selected sections of the Ecological Assessment) - Generally a well presented and comprehensive Outline Construction Environmental Management Plan presenting a good platform from which the final Construction Environmental Management Plan can be prepared. However, several recommendations are made with regard to changes to the plan or matters which require further consideration at the detailed stage.
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- Outline Soil Management Plan (by Neo Environmental dated November 2025) - Overall this is a very detailed document largely offering robust and industry approved methodologies to carry out the required works. However, some minor revisions are recommended. Consultations undertaken by the ECU The ECU consulted widely on the Section 36 application and a list of those who have responded (and who have not also been consulted by the Council), along with a summary of their comments, as shown on the ECU website, are provided below. Scottish Forestry – Have considered the information received and do not have any comments. Historic Environment Scotland (HES) – Have considered the information received and do not have any comments. Health and Safety Executive (HSE) – The proposed development, being a battery energy storage, is not a type that would store or process hazardous substances in quantities relevant to the potential for industrial major accidents. The development is located within a safeguarding zone of an explosives site, and also within the consultation zone for a major accident hazard pipeline. Health and Safety Executive (HSE)– No comment as the proposed development does not constitute a vulnerable building. BT – The project should not cause interference to BT’s current and presently planned radio network. Scottish Water – No objections. Defence Infrastructure Organisation (Ministry of Defence (MoD)) – No objection. Representations The consultation request was published on the Council’s weekly list of applications. The Council has not received any representations. The ECU, as the determining authority, publicise the application, and representations can be submitted directly to them via their website. At the time of writing there is one letters of representation objecting to the proposal. Policy Context As noted above the Council is a consultee in the consenting process and not the determining authority. To inform the Council’s consultation response an assessment against the Development Plan is required. In this instance the Development Plan consists of National Planning Framework 4 (NPF4) and the Renfrewshire Local Development Plan (2021) (LDP). The following provisions of the Development Plan are considered relevant to this submission. National Planning Framework 4 Policy 1 – Tackling the climate and nature crisis
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Policy 2 - Climate mitigation and adaptation Policy 3 – Biodiversity Policy 4 - Natural places Policy 5 - Soils Policy 6 - Forestry, woodland and trees Policy 7 - Historic assets and places Policy 8 - Green belts Policy 11 - Energy Policy 13 - Sustainable transport Policy 14 - Design, quality, and place Policy 22 - Flood risk and water management Policy 23 – Health and safety principles Full details relating to the policies of the NPF4 can be found online. Renfrewshire Local Development Plan Policy ENV1 - Green Belt Policy ENV2 - Natural Heritage Policy ENV3 - Built and Cultural Heritage Policy ENV4 - The Water Environment Policy ENV6 - Soils Policy I1 - Connecting Places Policy I3 - Flooding and Drainage Policy I4 - Renewable and Low Carbon Energy Developments Full details relating to the policies of the LDP can be found online. New Development Supplementary Guidance Delivering the Environment Strategy – Green Belt Development Criteria, Natural Heritage, Built and Cultural heritage, The water Environment and Soils Delivering the Infrastructure Strategy – Connecting Places, Flooding and Drainage and Renewable and Low carbon Energy Developments Other relevant policies and guidance Scottish Government Planning Guidance: Battery Energy Storage Systems, March 2026 Renfrewshire Councils Planning and Development Tree Policy Submitted Reports and Assessments The following reports and assessments were submitted in support of the application: Flood Risk Assessment and Drainage Impact Assessment by Neo Environmental dated 16/12/2025 – Notes that a small area along the eastern boundary of the application site is in an area of high risk of fluvial flooding. The majority of the application site, and the infrastructure associated with the BESS, is in an area of little or no risk. Some areas are at risk of pluvial flooding, however these areas have been avoided. The development is classed as essential infrastructure and deemed to have no constraints. The drainage strategy consists of piped system which leads to a SuDS pond at the southern end of the site. The pond has been designed using infiltration only. However should this not be suitable, a discharge point to Lin Burn will be formed. Arboricultural Impact Assessment, East Fulwood, January 2026 by Bowland Tree Consultancy Ltd – Notes that construction of the development will require the removal and realignment of one low quality hedge to form the visibility splay. This hedge will be
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replanted in one with the visibility splay. There is no loss of trees. The trees noted in the survey are positioned on the boundaries of the site. Noted that the proposed layout includes sufficient space for extensive new tree planting. Site specific details should be submitted via planning condition. Landscape and Visual Impact Assessment East Fulwood BESS, December 2025 by Neo Environmental – States that the design has been informed by a landscape-led approach, with considered mitigation measures including new woodland, hedgerows, and meadows. Mitigation planting will reduce the visibility of the development over time. It is noted that visual effects are limited and primarily localised to the area within 1km of the site. Beyond this, visibility is restricted due to landform, vegetation and built development. Outline Battery Safety Management Plan, Issue 1 December 2025 – The aim of the document is to define the proposed safety strategy, requirements and processes neccesary to meet safety objectives and performance. It is noted that the BESS units to be deployed at the site are not yet known. However currently foreseeable hazards associated with the technology likely to be proposed have been identified. These will form the basis of the initial safety management. At this stage, likely safety measures include procurement and design safety, testing, maintenance, emergency plans, siting and site security. A Battery Safety Management Plan will be developed prior to the commencement of construction. Community Benefit Statement – Applicant has committed to a community benefit fund of £1,000 per MW of installed capacity as a one-off payment. Notes that initial discussions have taken place with Inchinnan Community Council and other stakeholders on the need to define criteria for projects to be funded. This fund is not a material consideration in the determination of the application. Planning Statement by Neo Environmental dated 12th January 2026 – Provides a description of the site and its context, and the proposed development. There is also a planning assessment against the relevant legislative and planning policy context. The benefits of the development are noted as a reduction in greenhouse gas emissions, allowing the best use of renewable energy resources, clean energy benefit, legacy benefits in terms of improved biodiversity and landscape value and retention of new habitats, and other socio economic benefits including job generation during installation, maintenance and decommissioning of the development. Outline Soil Management Plan by Neo Environmental dated November 2025 – Sets out mitigation measures to protect the soil resource relative to soil stripping and handling, long term storage and stockpiling, site restoration and stop conditions for adverse weather. A detailed Soil Management Plan will be prepared prior to construction commencing. It is assumed that all stripped soils will be retained on site and available for use to restore the site back to agricultural land. Agricultural Land Classification, Soils and Peat Assessment by Neo Environmental dated October 2025 – Notes that most of the site is used for arable crop production and has been classed as LCA Class 4.1. The area of improved grassland in the northwestern part of the site is mapped as LCA Class 5.3. The site is therefore entirely comprised of non- prime quality agricultural land. There is no peat occurring within the site. Cumulative Study by Neo Environmental dated 16th December 2025 – Inchinnan Solar Farm (approved under planning application 23/0431/PP) forms the basis of the cumulative study. Two other developments (Glasgow Airport solar farm granted under
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22/0746/PP and Scottish water solar farm granted under 25/0232/PP) were discounted from the assessment as there is limited intervisibility between the sites. Concludes that the proposals would give rise to minimal landscape or visual cumulative effects. Considers that the proposed development is visually contained and could reasonably be regarded as a logical infill. Within the context of the local character area, the proposal would not introduce an overbearing presence, and consequently the overall landscape character would largely be retained. Outline Construction Environmental Management Plan by Neo Environmental dated 15th December 2025 – Sets out best practice design measures and recommended measures to mitigate potential impacts related to ecology, water and soils during the construction phase. A detailed Construction Environmental Management Plan that adheres to these measures will be submitted prior to construction commencing. Construction Traffic Management Plan by Neo Environmental dated 4th November 2025 – Outlines the framework for managing the movement of construction and delivery traffic to and from the development. Routing for construction vehicles will be via the M8 motorway Junction 29. Overall volumes of traffic generated by the construction phase are considered to be low. Impacts during the operational phase are also not considered to be significant. Notes that a pre and post construction survey will be undertaken on Houston Road between the site access and its junction with the A726, with the applicant liable to repair any damage attributed to the development. Noise Impact Assessment by Neo Environmental dated 15th December 2025 – Objective of the assessment is to for a baseline and identify and describe any likely significant noise effects on key receptors during construction, operation and decommissioning. Construction noise is predicted to be below the daytime threshold level. Operational noise, both individually and cumulatively along with the Inchinnan Solar Farm, will have a negligible impact at all residential noise sensitive receptors. Pre Application Consultation Report – Advises that two in person public events were held at Inchinnan Church Hall. 1,161 households and businesses located near the site received an information pack. An introductory email was also sent to elected members. A dedicated project webpage was made live in July, and adverts were placed in the local press. Across both public events there were 37 people in attendance, with six feedback forms completed. It is also noted that the applicants met with a resident living in close proximity to the eastern boundary of the site to discuss the proposal in more detail. The most commonly raised questions related to fire risk and impact on nearby properties. Ecological Assessment by Neo Environmental dated 16th December 2025 – Sets out the ecological survey work undertaken, and the ecological value of the site. Cultural Heritage Impact Assessment by Neo Environmental dated 16th December 2025 – Notes that there are no designated or non-designated archaeology or heritage assets present within the application site. While multiple possible features were highlighted during the geophysical survey, no further pre-consent archaeological investigation or mitigation is considered to be neccesary. Scottish Ministers Direction
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In determining a planning application, the Council is required to provide details of any Direction made by Scottish Ministers under Regulation 30 (Directions requiring consultation), Regulation 31 (Directions requiring information), Regulation 32 (Directions restricting the grant of planning permission) and Regulation 33 (Directions requiring consideration of condition) of The Town and Country Planning (Development Management Procedure) (Scotland) Regulations 2013, or under Regulation 50 (that development is EIA development) of The Town and Country Planning (Environmental Impact Assessment) (Scotland) Regulations 2017. None. Planning Assessment The Scottish Governments Planning Guidance Note on BESS was issued in March 2026 and provides context on the role of BESS in the energy system. The guidance notes the following - “Battery Energy Storage Systems (BESS) will play an important role in Scotland’s transition towards a low-carbon, resilient, and efficient energy system. Through enabling the integration of renewable energy and supporting grid stability, BESS development can contribute to achieving national ambitions for renewable energy deployment and addressing climate change. Our planning and consenting systems have an important role in facilitating the delivery of appropriately sited BESS projects while delivering wider policy and placemaking objectives”. The Planning Guidance and NPF4 both consider BESS development to constitute essential infrastructure. The application for the BESS has been submitted to the ECU under Section 36 of the Electricity Act 1989. Unlike a planning application, there is no requirement that the application be determined in accordance with the development plan. Instead, the development plan is one of a number of material considerations which require to be taken into account by the ECU in their determination of the application. The Council is one of a number of consultees in this process. To inform the Council’s consultation response to the ECU, the development plan represents the appropriate document against which to base the Council’s assessment of the application. The development plan comprises of the National Planning Framework 4 (NPF4) and the adopted Renfrewshire Local Development Plan 2022 (LDP). It is noted again that the applicant has advised in the Planning Statement that the proposed design and layout of the BESS is indicative and “is based on informed assumptions of the most likely option for the BESS enclosures and their positioning”. This is due to the continued advance in technology and efficiency associated with BESS, and technology available now may differ to that available when construction commences. As such, the applicant is seeking conditions to be attached to allow for details on the final design and layout to be approved prior to the commencement of development. The applicant’s two proposed conditions are as follows. “There shall be no commencement of the development unless and until details of the energy storage technology, associated infrastructure and approved layout to be implemented, have been submitted to and approved in writing by the Scottish Ministers in consultation with the Planning Authority. The storage technology details and infrastructure, including the battery energy storage system enclosures to be deployed, shall be consistent with the Application. Thereafter, the Development shall be installed and maintained in accordance with the approved details, unless otherwise agreed in writing by the Scottish Ministers in consultation with the Planning Authority.” And
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“No development shall commence unless and until full details of the proposed battery energy storage system enclosures (and ancillary infrastructure) hereby permitted, have been submitted to and approved in writing by the Planning Authority. These details shall include: a) the make, model, design, power rating, sound power level and dimensions of the battery energy storage system enclosures (and ancillary infrastructure) to be installed, and b) the specific external colour and/or finish of the battery energy storage system enclosures (and ancillary infrastructure) and the control building, site office and store buildings to be used which shall have a non-reflective, semi-matte finish and are to be of a dark green colour. Thereafter, the battery storage containers and buildings shall be installed and operated in accordance with these approved details and, with reference to part (b) above, the battery storage containers (and ancillary infrastructure) and the buildings shall all be maintained in the approved colour until such time as the development is decommissioned.” The Council has reservations over the use of the above conditions due to the potential for differences between the proposal under consideration and subject to this detailed consenting process, and the final design which could come forward via the discharge of condition process. Ultimately it is for the ECU as determining authority to consider if the above approach is appropriate. If the ECU does adopt the above approach, it is considered vital that they include provision for parameters to ensure the development that comes forward to discharge the conditions is not substantially different to that currently presented. This could include reference within the condition to the indicative drawings and a maximum allowance for divergence from the drawings, maximum allowed heights, fixed location for specific elements such as the substation compound, and adherence to the application red line boundary. If a proposal were eventually submitted which is substantially different to that currently presented, the Council would reserve the right to decline assessment via discharge of condition. In such instances a development that is substantially different would require to be subject to a new consent application. However, for the purposes of the Councils involvement in the Section 36 process, the submitted indicative layout and accompanying suite of supporting information is sufficient to allow the Council to consider and provide a formal consultation response. The application site is located within the green belt. Policies ENV1 of the LDP and 8 of NPF4 both consider renewable energy developments to be an acceptable form of development within the green belt in principle. The proposal must thereafter be assessed against the detailed development criteria set out within the green belt policies. This includes the green belt development criteria set out within the New Development Supplementary Guidance which will be assessed as follows. There will be no loss of prime quality agricultural land or agricultural land of lesser quality that is locally important in line with Scottish Government Policy No part of the application site is classed as prime quality agricultural land. The Agricultural Land Classification, Soils and Peat Assessment submitted by the applicant notes the site falls within classes 4.1 and 5.3 of the Macaulay land capability classification. NPF4 defines prime quality agricultural land as that identified within Class 1, 2 or 3.1. The LDP does not identify the site as being of cultural or local importance. Any adverse impacts on the qualities of wild land are overcome by siting, design or other mitigation
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There is no impact on wild land. Traffic and access infrastructure can be sensitively accommodated Transport Scotland and Network Rail have both offered no objections to the development. Conditions relating to fire safety and management of abnormal load movements and construction traffic could be recommended in line with these consultation responses. Roads Development have offered no objections to the development. However, it is noted that a single point of access would be supported in lieu of the proposed two points of access unless the applicant can demonstrate that two points of access can be accommodated safely. Associated sight lines for the single point of access are also provided. The design of the access should also accord with Cycling by Design to support active travel, and it is noted that the B790 Houston Road is allocated within the Local Transport Strategy as a proposed active travel route. It is noted that there are no objections to the principle of the development. Ultimately therefore it is considered that the final design of the site access could be managed via an appropriately worded planning condition. It is also noted that the formation of the access and the sightlines will result in the loss of the hedgerow which bounds the site to the south. However, the proposed development makes provision for replanting this hedgerow in a new alignment which accommodates the access. It is considered that the access infrastructure required to accommodate the development can be accommodated sensitively and without significant detriment to the character of the area. No significant effects on public water supply and water environment from any pollution risk It is not anticipated that the development would give rise to significant effects on public water supply or water courses from pollution risk. It is noted that SEPA, Scottish Water and Environmental Protection have not objected to the development on these grounds. A condition relating to the submission of a Construction Environmental Management Plan (CEMP) to mitigate pollution risk during the construction phase could be recommended to the ECU. Conditions could also be recommended regarding a drainage strategy to mitigate risk to the water environment during the operational phase of the development. It is noted that the Drainage Impact Assessment makes provision for containment of potentially contaminated water associated with a fire event. The development links to the existing green network and active travel routes or provides new enhanced routes, where appropriate There are no designated core paths within or on the edge of the application site. There is a farm access track adjacent to the eastern boundary of the site. This track is outwith the development red line boundary and will not be significantly impacted by the development. Proposals to protect and provide access to open space have been incorporated There is no requirement to incorporate access to open space given the nature of the development. Development will not have a significant detrimental impact on the local landscape character. Development layout, design and siting must reflect local landscape character and respect and incorporate important landscape features such as traditional field enclosures, water courses, woodlands and skyline; It can be demonstrated that there is careful consideration of the siting, design, scale and grouping of any buildings and infrastructure; and Appropriate landscaping proposals have been incorporated including the provision of boundary treatment The application site comprises of flat relatively open agricultural land located alongside the M8 motorway which bounds the site to the west. Views of the site from the west would be limited to the M8 and the adjacent railway line, with the motorway itself and woodland
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beyond forming a buffer and providing enclosure along the western boundary of the site. To the north, east and south the landscape comprises of flat low-lying agricultural land which extends to Greenock Road and Barnsford Road. The agricultural land features hedgerow boundaries and pockets of trees and other vegetation however there are no existing landscape or woodland features of a scale that would significantly mitigate views of the development from external vantage points to the north, east and south. The Landscape and Visual Impact Assessment (LVIA) submitted in support of the application concludes that the visual effect of the development is limited and primarily localised to an area within 1km of the site. Ironside Farrar as the Councils external landscape consultant have advised that while they would consider some of the effects to be slightly higher than that set out in the LVIA, the broad conclusions are agreed with. In this regard it is acknowledged that while the development will be visible its impact on landscape character will not be significant. However, it is noted that both the LVIA and the Councils external landscape consultant note the proposals for mitigation planting which will reduce the visual impact of the development over time. The LVIA states that the design has been informed by a landscape-led approach, with considered mitigation measures including new woodland, hedgerows, and meadows. A proposed strategy for the new woodland, hedgerows and meadows is set out in a Landscape and Ecology Management Plan which accompanies the submission. The proposed hedgerow will be planted around the full perimeter of the BESS, and the existing hedgerow along the edge of Houston Road will be replanted in an alignment that accommodates the required sight lines at the access points. However, the meadow and woodland planting is concentred to the west and south of the BESS. The suitability of this strategy to adequately screen the development is limited as views of the site from the west are already screened as noted above. Additional landscaping along the eastern boundary of the site, where the development will be more visible, would be desirable. Additionally, the density of tree planting as indicated in the plan is very low and there is very little tree planting shown in the area to the south of the BESS. A much higher density of woodland planting would be desirable both in terms of mitigating visual impact and promoting biodiversity and ecological gain. In addition to the above, it is noted that the applicants have also considered the cumulative impact of the development with the Inchinnan Solar Farm (planning reference: 23/0431/PP) which is located to the northeast of the proposed BESS. Again, it is accepted that the cumulative visual impact of the development is acceptable regarding landscape character, and there is capacity within the landscape to accommodate both developments. The applicant’s cumulative assessment notes that the proposed BESS is “visually contained” and could be regarded as a “logical infill”. However, the lack of provision for landscaping along the eastern boundary of the BESS undermines the assertion that the site would be visually contained. It is possible that the landscape strategy which forms part of the Inchinnan Solar Farm would also act to mitigate the visual impact of the proposed BESS. However, this is a separate scheme which may not be developed, and the BESS could not rely on this as mitigation. On balance it is accepted that the visual impact of the BESS on landscape character will not be significant. However, this is contingent on a landscape strategy being developed which would suitably mitigate the visual impact of the development over time. It is noted that the Scottish Government Planning Guidance on BESS refers to both landscaping and site layout/design measures to mitigate visual impact. In this regard the current strategy set out within the Landscape and Ecology Management Plan is deficient both in terms of the density and location of tree planting and the areas where landscaping can be accommodated. The development has not demonstrated careful consideration over the siting and grouping of the
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BESS, and appropriate landscaping proposals have not been incorporated. Modifications to the scheme which would provide a higher density of planting and provision for landscaping along the eastern boundary should be sought. It is acknowledged that making provision for landscaping along the eastern boundary would entail a revision to the site layout. However, the applicant notes in the Planning Statement that the proposed development represents an indicative design and layout, with conditions recommended whereby a final design and layout would be agreed prior to development commencing. On this basis there would be scope to seek changes to the layout to accommodate a more effective landscape buffer along the northern and eastern boundaries. While this would entail a reduction in the width of the buffer on the western boundary, this is accepted as a more balanced approach as views from the west are already mitigated by existing features. It is also noted that matters relating to the final design of the component infrastructure and its associated finish would also be conditioned. Natural colours and tones would be sought in this regard. On balance, the response from the Councils external landscape consultant is noted with regard to the impact of the development on landscape character. The landscape character of the area will not be significantly impacted by a BESS development of this nature. However, the submission, the Councils landscape consultant, and the Scottish Government Guidance all make reference to the importance of a landscape led approach and making provision for screening to reduce the visual impact of the development over time. The landscape strategy submitted with the application is not considered to suitably mitigate the visual impact of the development both in respect of the areas which will be planted, and the density of planting. This deficiency is considered to constitute grounds to object to the proposal. As noted above, the applicant has advised that the proposed layout is indicative. They have recommended conditions requiring the submission of a final design and layout for agreement prior to development commencing. It would ultimately be for the ECU as determining authority to consider if this approach is appropriate. For the purposes of the Councils consultation response, the indicative layout provides an indication as to how the BESS would be laid out. In principle it is considered that a BESS commensurate with the indicative layout can be accommodated at this location without significant detriment to landscape character. However, an objection to the development on visual impact grounds is appropriate at this stage as it reinforces the Councils concern over the inadequacy of the current layout and associated landscape strategy. It should be noted that this objection could be overcome should an enhanced landscape strategy be developed. Again, as the layout is indicative, there would be scope to consider changes in order to accommodate an enhanced strategy. There are adequate services available for the development, or this can be provided The proposal does not include details of how the BESS would be connected to the electricity grid. The potential implications of the Raeshaw Farms Limited v Scottish Ministers [2026] case with regard to the requirement to consider the cumulative impact of offsite works is noted. However ultimately it would be a matter for the ECU to consider if they have sufficient information to determine the application. There is no significant detrimental effect on identified nature conservation interests, including species and habitat It is noted that there are no local or national natural heritage designations within the site boundary. It is also acknowledged that the natural heritage value of the site is not likely to be significant given its part use as agricultural land and scrub grassland. There are also no trees within the site.
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However, the Councils external ecology consultant notes that the conclusion that all habitats within the development footprint are of low ecological value is not substantiated, with limited quantified, site specific evidence for habitat value, species importance, and habitat losses and gains being presented. The Councils external ecology consultant recommends that the Council request further information outlined in the consultation response, namely a full habitat schedule and balance, explicit identification and valuation of Priority Habitats, a clearly articulated evaluation framework and the Valued Ecological Receptors (VER’s) table, more detailed species-specific assessment and mitigation, an updated and quantified Biodiversity Management Plan (BMP) and Landscape and Ecology Management Plan (LEMP)tied to an agreed landscape plan, and supporting photographic evidence. It is also recommended that the Council reserves its view on compliance with the development plan until this information has been submitted and reviewed. In view of the Councils external ecology consultants response and the deficiencies identified in the Ecology Report, it has not been demonstrated that the proposed development complies with the development plan policies and guidance relating to safeguarding natural heritage. It is not considered that this deficiency can be resolved via planning conditions. The deficiencies in the Ecology Report and the associated uncertainties over the ecological impact of the development would be a sustainable ground on which to object to the application. Regarding potential impact on natural heritage designations outwith the site, it is noted that NatureScot have objected to the development pending further assessment of the implications of what would be further loss of arable agricultural land for the capacity of the local landscape to continue to support important numbers of overwintering whooper swans. The swans overwinter at the Black Cat Special Protection Area (SPA) which is located approximately 860 metres to the southeast of the site. However, the area within which the swans feed extends well beyond the boundaries of the SPA and includes the application site. It is noted that the Landscape and Ecology Management Plan includes provision for an area which would be planted out with a farmland and wintering bird seed mix. However as advised by NatureScot, an Appropriate Assessment is required to fully assess the potential impact of the development on the qualifying interests of the Black Cart SPA. The ECU as the competent authority is required to undertake this assessment. As such, it is not considered that this constitutes grounds on which the Council could object to the proposal. All buildings for conversion are to be structurally sound and capable of conversion without substantial rebuilding The development does not include the conversion of any buildings. As noted above, both policies ENV1 of the LDP and 8 of NPF4 support renewable energy developments and essential infrastructure within the green belt in principle. Notwithstanding this, policy 8 of NPF4 also provides a list of requirements which must be met. These will be considered in turn as follows. Reasons are provided as to why a green belt location is essential and why it cannot be located on an alternative site out with the green belt. The Scottish Government Planning Guidance on BESS notes that appropriate site selection is important for effective planning of BESS, and specific site selection can directly influence the range and complexity of planning issues to be addressed. The guidance states that applicants will wish to have close regard to the policy principles set out in NPF4 which should be considered in the round. The Planning Statement advises that a range of factors have been considered when assessing the suitability of the site for proposed BESS development. This includes proximity
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to grid connection, proximity to dwellings, topography, size, access, any landscape, archaeological and conservation designations, and landowner agreement. The applicant advises that the suite of environmental reports that accompany the submission illustrate that the Site is suitable and that potential associated environmental impacts are within acceptable parameters. These reasons demonstrate why this green belt location has been selected, and why a green belt location is essential. However as noted above the Councils external ecology and landscape consultants have identified deficiencies within the ecology assessment. Furthermore, the potential effect of the development on the Black Cart SPA has also not been fully addressed. The proposal also does not benefit from an appropriate landscape strategy to mitigate visual impact. These matters undermine the applicant’s assertion that a green belt location is essential and that the proposed green belt location is suitable for this development. It is not considered that compliance with policy 8 has been fully demonstrated in this regard. The purpose of the green belt at that location is not undermined. The LDP states that the purpose of the green belt in Renfrewshire is to maintain the identity of settlements, protect and enhance the landscape setting of an area, and protect and promote access opportunities to open space. As noted above, the development is not considered to raise significant issues relating to landscape setting (subject to implementation of a robust landscaping strategy) or access opportunities. Given the nature and location of the development it also will not have a detrimental impact on the identity of settlements. The development would not undermine the purpose of the green belt in this regard. The proposal is compatible with the surrounding established countryside and landscape character. Landscape character and visual impact have been assessed above. The proposal has been designed to ensure it is of an appropriate scale, massing and external appearance, and uses materials that minimise visual impact on the green belt as far as possible. Landscape character and visual impact have been assessed above. It is noted again that the layout presented by the applicant is indicative, and a final design would be submitted for approval prior to development commencing. In general terms the indicative scale, massing and external appearance of the BESS is accepted, and the visual impact of the BESS at this location is also accepted subject to the implementation of a robust landscaping scheme which will mitigate the visual impact of the development over time. As noted in the above assessment, the landscape strategy presented as part of the submission is deficient and the Council would seek amendments to ensure it provides a more effective screen to the development. Conditions would also be used to control finishing materials There will be no significant long-term impacts on the environmental quality of the green belt. The proposed development would have a lifespan of 40 years, at which point the site would be decommissioned and the land restored. It is considered that there will be no significant long-term impact on environmental quality of the green belt in this regard. Additionally, it is noted that elements of the landscaping could be retained post decommissioning, and this may in turn bring about some long-term enhancements to the quality of the green belt. In view of the above assessment, the development is found to comply with most of the criteria related to green belt development. However, the submission has not demonstrated acceptability regarding ecological impact on the site itself, the potential detrimental effect on designated sites, and the effectiveness of the scheme of landscaping. On this basis it is also not considered that there is site specific justification at present for the development within the green belt. The development is therefore considered to be contrary to policies 3, 4 and 8 of NPF4 and ENV1 and ENV2 of the LDP.
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Policies I4 of the LDP and 11 of NPF4 seek to support development proposals for renewable and low carbon energy developments in principle. This includes BESS. Policy I4 includes several detailed assessment criteria. The criteria which have not already been assessed above will be considered in turn as follows. It is noted that Historic Environment Scotland have not objected to the development regarding its potential impact on above ground, built heritage assets. The West of Scotland Archaeology Service have recommended a condition with respect to the implementation of a programme of archaeological works. Regarding the amenity of neighbouring residential properties, Environmental Protection have recommended a condition to limit noise from plant and machinery. There are no concerns raised from any consultees regarding air quality or pollution control. Shadow flicker is not relevant to the proposed development. The indicative layout includes provision for lighting and CCTV. Further details can be requested via condition to ensure the lighting scheme does not have a detrimental impact on residential amenity or nature conservation interests. The development will not have a detrimental impact on outdoor sport or recreation interest. There will not be a significant impact on the national or local transport network. Regarding safeguarding the operations of Glasgow Airport, Glasgow Airport Safeguarding have not provided a consultation response at the time of writing. It is noted that NATS have objected to the proposal on the grounds that it may have an impact on the Brownsfield Radar installation. It is noted that NATS consider this objection can be overcome. However, this would be a matter for the ECU to address as the determining authority. The site is not within a potential heat network opportunity area. Regarding the relevant criteria within the New Development Supplementary Guidance on renewable and low carbon energy developments (not already discussed above), conditions will be recommended to ensure arrangements are in place to restore the site to an acceptable standard after the operation of the BESS has ceased. This would include removal of all above and below ground elements. A decommissioning and restoration strategy, and a bond or other financial guarantee to ensure funds are set aside for decommissioning and that the Council can call upon these funds to undertake the work if neccesary, would be negotiated via planning conditions and/or an alternative legal arrangement Regarding future decommissioning and site restoration, it should be noted that the proposals are to retain stripped topsoil at the site. The soil would be bunded and would form part of the landscape strategy. The soil would then be spread over the site following decommissioning to reinstate the ground to its previous use. However, consideration should be given as to whether the bunding should be retained in situ, particularly if it is to be planted out. In this scenario, the decommissioning strategy would have to make provision for importing soil to the site to ensure the land is returned to its previous use. The New Development Supplementary Guidance also requires the scale of contribution from the development to renewable energy generation targets and the effect on greenhouse gas and carbon emissions to be fully demonstrated. This is an important consideration as the scale of the contribution could be weighed against the nature and extent of any impacts associated with the development.
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The proposed BESS has a capacity of 400MW. While there is no associated analysis of the greenhouse gas and carbon emission reduction associated with a BESS of this scale, it is accepted that a BESS of this scale will make a significant contribution to renewable energy generation targets by enabling the integration of renewable energy and supporting grid stability. Policy 11 subsection a) of NPF4 states that development proposals for all forms of renewable, low carbon and zero emissions technologies will be supported. This includes energy storage. Policy 11 subsection b) is not relevant as it relates to windfarm development. Policy 11 subsection c) states that development proposals will only be supported where they maximise net economic impact. In terms of maximising net economic benefit, the contribution to renewable energy generation targets and support for grid stability noted above will in turn contribute to a secure renewables based electricity system which brings economic benefits in itself. The planning statement also advises that the development will result in the creation of 3 full time equivalent jobs during the operational period and 42 full time equivalent jobs during the construction phase. It is also noted that the applicant has committed to a community benefit fund of £1,000 per MW of installed capacity as a one-off payment, and that initial discussions have taken place with Inchinnan Community Council and other stakeholders on the need to define criteria for projects to be funded. It is noted that this fund is not a material consideration in the determination of the application. It is also noted that Inchinnan Community Council have objected to the proposal. Policy 11 subsection d) states that development proposals that impact on international or national designations will be assessed in relation to Policy 4. This assessment has been in undertaken and set out in earlier sub-sections above, and the proposal is found to be contrary to Policy 4. Policy 11 subsection e) states that project design and mitigation will demonstrate how a range of potential impacts have been addressed. These potential impacts are listed in turn below however it is noted that most of them have already been addressed in the preceding assessment. Impacts on communities and individual dwellings, including, residential amenity, visual impact, noise and shadow flicker Matters relating to residential amenity have been addressed above. Significant landscape and visual impacts Regarding visual impact, it is noted that policy 11 recognises that landscape and visual impact are to be expected for some forms of renewable energy. Where impacts are localised and/or appropriate design mitigations have been applied, they will generally be considered to be acceptable. While it is agreed that some form of visual impact is to be expected, the landscape strategy and site layout proposed are not considered to be appropriate in the interests of mitigating visual impact. It is considered that the site layout could be reconfigured and the landscape strategy amended to better mitigate the visual impact of the development. Public access, including impact on long distance walking and cycling routes and scenic routes Public access has been addressed above. It is not anticipated that the development will have a detrimental impact on existing walking and cycling routes.
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Impacts on aviation and defence interests including seismological recording Matters relating to the safeguarding of operations at Glasgow Airport have been discussed above. It is noted that the Ministry of Defence have not objected to the development. Impacts on telecommunications and broadcasting installations, particularly ensuring that transmission links are not compromised It is noted that BT have not objected to the development. Impacts on road traffic and on adjacent trunk roads including during construction Transport Scotland have offered no objections to the development subject to conditions as discussed above. Impacts on historic environment Matters relating to impact on the historic environment have been discussed above. Effects on hydrology, the water environment and flood risk The Councils external drainage consultant has reviewed the Flood Risk Assessment and Drainage Impact Assessment submitted with the application. While no objections have been raised, it is noted that further detailed submissions would be required via planning condition. There have also been no objections from SEPA. On this basis the development does not raise any significant risk or concern with regard to flood risk and the water environment. A detailed Flood Risk Assessment and Drainage Impact Assessment would be requested via condition. Biodiversity including impacts on birds The deficiencies related to the ecology submission have been discussed above. The Councils external ecology consultant has made several recommendations with regard to the ecology assessment including submission of a full habitat schedule and balance, and provision of a Biodiversity Management Plan. At present therefore it is not considered that impact on biodiversity and birds (or any other protected species) has been fully demonstrated. Impacts on trees, woods and forests The Councils external ecology consultants have advised that the Arboricultural Impact Assessment is clear and comprehensive. The assessment notes that there are no trees within the footprint of the proposed BESS, with the trees and hedgerows survey located on the boundaries of the site. The proposals require the realignment of the hedge along Houston Road to accommodate the site access. A suite of management recommendations have been made for the surveyed trees. However, none of the trees surveyed are projected to be impacted by the development, and the development will not require the removal of any trees in this regard. The Councils external ecology consultant has recommended that further detail is submitted in relation to tree protection during the construction phase. This matter could be addressed via condition. It is noted that Scottish Forestry have not objected to the development. Both the Arboricultural Impact Assessment and the Councils external ecology consultants note the scope within the layout of the development to deliver extensive areas of new tree planting. New tree planting, including densities and locations, has been discussed above with respect to mitigating the visual impact of the development. The proposals for new tree planting currently presented are deficient, and an amended layout and landscape strategy will be sought. Proposals for the decommissioning of developments, including ancillary infrastructure, and site restoration
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The Planning Statement advises that the applicant is committed to the appropriate decommissioning and removal of plant from the site once the development ceases to store and supply power to the grid. The applicant recommends that a suitably worded condition is attached to any planning permission to secure the decommissioning of the development and restoration of the Site. Conditions are appropriate to address matters relating to decommissioning. The quality of site restoration plans including the measures in place to safeguard or guarantee availability of finances to effectively implement those plans The Planning Statement advises that the applicant is committed to the appropriate decommissioning and removal of plant from the site once the development ceases to store and supply power to the grid. The applicant recommends that a suitably worded condition is attached to any planning permission to secure the decommissioning of the development and restoration of the Site. Conditions are appropriate to address matters relating to site restoration and the guarantee of available finance to effectively implement the decommissioning and restoration plans. Cumulative impacts Matters relating to cumulative impact have been discussed above. Regarding consultation responses not already discussed above, it is noted that Scottish Gas Networks (SGN) and Inchinnan Community Council (ICC) have both objected to the development. The objection from SGN is pending completion of a site meeting to identify the location of the pipeline and discuss measures neccesary to safeguard the security of the pipeline. This would be a matter for the ECU to resolve as the consenting authority. Inchinnan Community Council (ICC) have objected on six grounds. Matters relating to scale and location, visual amenity and landscape character, traffic and construction disruption, noise and impact on residential amenity, and site selection have been discussed above. ICC also object on the grounds of safety concerns associated with the BESS. The Scottish Government Planning Guidance on BESS advises that there are a range of other regulatory regimes and requirements which also apply to the construction and operation of BESS, in particular around health and safety, fire risk and pollution control. It is an established principle that the planning system does not seek to duplicate other regulatory regimes. Notwithstanding the above, it is noted that the application includes an outline battery safety management plan which sets out the likely safety measures that will be associated with the BESS including procurement and design safety, testing, maintenance, emergency plans, siting and site security. The Councils external environmental consultant advises that the outline plan provides a clear and structure overview of key safety considerations. However, it is acknowledged that the document does not fully demonstrate a site-specific safety case, and as such a detailed safety plan should be sought via condition. It is also noted that other consultees such as Network Rail have also sought the submission of further safety related information. It is considered that safety related matters can be addressed via condition, and concerns related to the safe operation of BESS would not constitute a sustainable ground of objection. Planning Obligations The Council is required to provide a summary of the terms of any planning obligation(s) and any associated legal agreement(s) and/or mechanism(s) required to secure them including
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those provisions under The Town and Country Planning (Scotland) Act in relation to the grant of permission for the proposed development. A legal agreement and/or conditions to secure decommissioning and restoration of the site would be required if this application was to be granted. Conclusion On balance it is acknowledged that NPF4 policy 11 provides strong support for BESS development in principle. Policy 1 of NPF4 would also attach significant weight to developments that address the global climate emergency and nature crisis. However, the Scottish Government Guidance advises that NPF4 should be read and applied as a whole and that some conflict between different policies is to be expected. Where a policy states that a development will be supported, it is in principle. All other relevant policies must be considered. In this regard it is noted in the above assessment that the submission is found to be deficient in two key areas as follows. The ecological impact of the development has not been fully demonstrated both in respect of the impact of the development on the application site, and the impact of the development on the Black Cart Special Protection Area. The site layout and landscape strategy is not sufficient to suitably mitigate the visual impact of the development. In view of the above deficiencies, it has also not been fully demonstrated that there is site specific justification for the development within the green belt. The development is therefore currently considered to be contrary to policies 3, 4 and 8 of NPF4 and ENV1 and ENV2 of the LDP. Noncompliance with these policies is considered to constitute grounds for the Council to object to the development. It has previously been noted that the procedures relating to an objection from a Local Authority to an application for Section 36 consent have recently changed. An objection from a Local Authority no longer triggers a requirement to hold a public enquiry. Instead, a reporter led examination process will apply, where a planning authority objects to an application and that objection is not withdrawn, or cannot be resolved by conditions or modifications. It has also been noted above that the deadline for the Council to issue a consultation response to the ECU is the 11th of June 2026. It is considered that the Council should issue a response within this period to avoid uncertainties associated with extensions of time and the associated timescales for the submission of updated information, and the risk that the Council may miss the opportunity to provide comment on the proposal. In this regard the Council would welcome re-consultation on the development once the points of objection have been adequately addressed and further details provided. It should be noted on this basis that it is considered possible for the applicants to overcome the points of objection via submission of an updated ecological assessment which addresses the points raised by the Councils external consultants, and submission of an updated site layout and landscape strategy which addresses concerns over the visual impact of the development particularly taking into consideration views from the north, east and south. Recommendation Objection on the following grounds:
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1. The ecological impact of the development has not been fully demonstrated both in respect of the impact of the development on the application site, and the impact of the development on the Black Cart Special Protection Area. The ecological submission requires to be updated to address the matters raised by the Councils external ecological consultant as set out in detail in this consultation response. 2. The site layout and landscape strategy submitted is not sufficient to suitably mitigate the visual impact of the development as presented through this application. The site layout and landscape strategy require to be amended to include provision for landscape buffers along the northern and eastern boundaries of the site which can be planted with trees, and a higher density of tree planting within the landscape buffers along the western and southern boundaries of the site. Reason(s) for Recommendation Due to the grounds of objection noted above, the development is considered to be contrary to policies 3 (Biodiversity), 4 (Natural Places) and 8 (Green Belt) of NPF4 and ENV1 (Green Belt) and ENV2 (Natural heritage) of the LDP. Schedule of Plans Reviewed Drawing Number Revision Drawing/Document Title Figure 1 Site location plan Figure 2 Redline boundary Figure 3 Preliminary design layout Figure 4 Substation layout plan Figure 5 Substation elevation plan sheet 1 Figure 6 Substation elevation plan sheet 2 Figure 7 Substation site elevation plan Figure 8 BESS enclosures plan Figure 9 Auxiliary transformer plan Figure 10 Backup generator plan Figure 11 CCTV elevation plan Figure 12 BESS gate elevation Figure 13 Lighting details plan Figure 14 Security fence plan Figure 15 GRP plan Figure 16 Inverter (MV Skid) elevation plan Figure 17 Storage container plan Figure 18 Monitoring house plan Figure 19 Composting toilet Figure 20 Water tank Figure 21 BESS intake substation Figure 22 Track cross section Flood Risk Assessment and Drainage Impact Assessment by Neo Environmental dated 16/12/2025 Arboricultural Impact Assessment, East Fulwood, January 2026 by Bowland Tree Consultancy Ltd Landscape and Visual Impact Assessment East Fulwood BESS, December 2025 by Neo Environmental Outline Battery Safety Management Plan,
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Issue 1 December 2025 Community Benefit Statement Planning Statement by Neo Environmental dated 12th January 2026 Outline Soil Management Plan by Neo Environmental dated November 2025 Agricultural Land Classification, Soils and Peat Assessment by Neo Environmental dated October 2025 Cumulative Study by Neo Environmental dated 16th December 2025 Outline Construction Environmental Management Plan by Neo Environmental dated 15th December 2025 Construction Traffic Management Plan by Neo Environmental dated 4th November 2025 Noise Impact Assessment by Neo Environmental dated 15th December 2025 Pre Application Consultation Report Ecological Assessment by Neo Environmental dated 16th December 2025 Cultural Heritage Impact Assessment by Neo Environmental dated 16th December 2025 For further information please contact James Weir, Development Standards Team, Email: james.weir@renfrewshire.gov.uk.