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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

Page 13

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

Page 14

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.

Page 15

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

Page 16

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.

Page 17

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.

Page 18

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.

Page 19

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

Page 20

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

Page 21

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:

Page 22

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.