4 - 25-0007-EAC BESS Gleniffer Road
Renfrewshire Council · 20 May 2025
Back to Planning and Climate Change Policy Board — 20 May 2025 and its agenda
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Planning and Climate Change Policy Board: 20 May 2025 Report by Chief Planning Officer Reference No 25/0007/EAC Application Type Electricity Act Consultation Proposal Formation of up to 750MW Battery Energy Storage Facility, comprising of up to 88 battery storage container blocks and associated infrastructure, storage containers, welfare facility, diesel generators, CCTV and lighting columns and associated access, internal access roads, hard and soft landscaping, SUDS Basin and perimeter fence. Location Neilston Grid Electricity Sub Station Complex, Gleniffer Road, Paisley Ward 7 Paisley Southwest Community Council Elderslie Community Council Applicant Energy Consents Unit Recommendation No Objection Subject to Conditions and/or a Planning Obligation All plans, reports, documents and representations relating to this application can be viewed in full online at https://www.energyconsents.scot/ApplicationDetails.aspx?cr=ECU00004988 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 750MW battery energy storage system (BESS) on land to the southeast of the Neilston Grid Electricity Sub Station Complex on Gleniffer Road, Paisley. 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 750MW, Renfrewshire Council has been formally consulted on the proposed development by the ECU in terms of Section 36 of the Electricity Act 1989. 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 13thJanuary 2025, with an initial response deadline of 9th May 2025. The deadline has subsequently been extended to 30th May to allow the consultation request to be considered by the Planning and Climate Change Policy Board. In response to the ECU consultation the Council can either: ▪ Offer no objections to the Section 36 application as submitted;
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▪ Offer no objections subject to the imposition of appropriate conditions and/or legal agreement or planning obligations it considered necessary to make the development acceptable (it should be noted that responsibility for discharging conditions and/or the legal obligations would fall upon the Council), or; ▪ Object to the application, stating the grounds on which the objection is made. Members should note at this point that a decision to object to the application would trigger a public local enquiry in terms of Section 62 and Schedule 8 of the Electricity Act 1989. While the consultation response would normally fall within the 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 referred 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 battery energy storage facilities. It should be noted that the development of a BESS on this site was previously proposed under planning application 21/0034/PP. This application was refused by the Council in November 2021, however, it was subsequently granted planning permission subject to conditions by the Department of Planning and Environmental Appeals (DPEA) on in April 2022. The first phase of the BESS (up to 50MW capacity) is being built out in the northwest corner of the site under approved application 21/0034/PP and associated Non-Material Variation 23/0497/NMV, and further application 23/0224/PP for a cable connection and HV yard. However, as the maximum generating capacity of the overall BESS development now proposed is in excess of 50MW, consent from the ECU is also required for the scheme. The phase 1 area is included within the S36 application so that the entirety of the site would benefit from a single consent, thereby simplifying the overall planning status. It should also be noted that the BESS under consideration now differs to that approved on appeal under application 21/0034/PP. While the extent of the application site boundary is the same, the scale of the development is reduced. Under application 21/0034/PP the footprint of the BESS covered the entire site area, and there were a number of pieces of additional transforming equipment. For the purposes of this submission the footprint of the BESS has been reduced with no development proposed underneath the transmission lines which cross the site, and the extent of transforming equipment being proposed has also reduced in number. Proposal The proposed development is for the formation of up to 750MW Battery Energy Storage Facility, comprising of up to 88 battery storage container blocks and associated infrastructure, storage containers, welfare facility, diesel generators, CCTV and lighting columns and associated access, internal access roads, hard and soft landscaping, SuDS basin and a perimeter fence. As noted above, the first phase of the BESS is already under construction in the northeastern corner of the site. This includes the site access from Gleniffer Road. For the purposes of this submission the proposed development is essentially split into three sections across the site. Further battery units will be installed along the northeastern boundary behind the existing phase 1 area. Then moving southwest there will be a break in the development to take into account the overhead electricity lines. There will be a further row of battery units before another break again due to overhead lines. Finally adjacent to the southwestern boundary there will be further battery units and a 400Kv yard in the western corner.
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The undeveloped areas under the overhead lines will be sown with a native wildflower mix. Native hedgerows, trees and woodland edge planting are proposed along the southeastern, southwestern and northwestern boundaries. The boundary treatment also includes a 3.4- metre-high palisade style fence. There are three types of battery unit being proposed. Type A units, which are located in the northwest corner, measure 26 metres in length by 16.8 metres in width by 3.8 metres in height. Type B units, which are located in the northeast corner and the central part of the site, also measure 26 metres in length by 16.8 metres in width by 3.8 metres in height. Finally type C units, which are located along the southwestern boundary, measure 38 metres in length by 15 metres in width by 3.8 metres in height. The 400Kv High Voltage yard has a footprint of 65 metres in length by 40 metres in width and is a maximum height of 10.8 metres. There are also various ancillary buildings and plant including Medium Voltage rooms which are 3.8 metres in height, substation control buildings, welfare buildings and stores. The SUDS basin is located in the southwest corner of the site. It is noted that the initial submission included the route for a connecting cable between the application site and the Neilston substation on the opposite side of Gleniffer Road to the northwest. However, the connecting cable has now been removed from the scheme and no longer forms part of the submission. Site Description The application site extends to approximately 14 hectares in area. It primarily comprises of grassland, and the topography is gently sloping uphill from the northwest to the southeast boundary. The site is directly opposite Neilston substation. A mature strip of woodland bounds the site to the northeast, with rolling agricultural land to the southeast and grassland to the southwest. 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. A pre-application meeting was held on the 21st December 2023 during which the proposed development which would be the subject of the S36 application was presented by the applicants. A comparison was provided between the proposed submission and the development consented under application 21/0034/PP, and discussions were undertaken on the Councils procedures relating to S36 requests and the likely supporting information required. Negotiated Improvements Following submission, the following changes have been negotiated between officers and the applicant: No changes have been negotiated. Site History The planning history for the site is as follows; if no history is listed then planning has no record of previous applications for the site. Application No: 23/0497/NMV
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Description: Removal of HV Yard and Energy Management Buildings, and installation of 23 additional battery storage units in northwest corner of site Decision: Granted Application No: 23/0697/EA Description: Request for screening opinion for an Environmental Impact Assessment relating to the proposed construction and operation of an Battery Energy Storage System (BESS) with installed capacity in excess of 50 megawatts (MW) (Consultation request from Energy Consents Unit) Decision: Scottish Ministers determined that an Environmental Assessment was not required. Application No: 23/0224/PP Description: Installation of buried cable connection and HV yard, and repositioning of site access. Decision: Granted subject to conditions Application: 21/0034/PP Description: Installation of greener grid park including energy management and battery storage containers with associated access, landscaping and fencing. Decision; Granted subject to conditions via appeal. Application: 20/0440/EO Description: Request for screening opinion as to the requirement for an Environmental Impact Assessment relating to the erection of an Energy Management Facility Decision; Environmental Assessment not Required. Application No: 20/0353/NO Description: Erection of an Energy Management Facility Decision; Accepted. Application No: 19/0735/NO Description: Request for screening opinion as a requirement for a Environmental Impact Assessment relating to the erection of an Energy Management Facility Decision: Environmental Assessment not Required Consultations ▪ Glasgow Airport Safeguarding - No objection. ▪ Environment, Housing & Infrastructure (Env. Protection) - No objections subject to conditions relating to noise. ▪ Chief Executive's Service (Roads Development) – No objections subject to conditions relating to sightlines, forward visibility, submission of a road safety audit, construction traffic management plan, and assessment of proposed routes for construction traffic. ▪ Scottish Power Distribution Plc – No objections in principle. Advise of overhead line in the vicinity of the proposals and therefore reserve the right to protect and or deviate the apparatus at the applicant’s expense. ▪ National Air Traffic Services (NATS) - No objections. ▪ Ironside Farrar Ltd (IFL) (Council’s Independent Consultants) - IFL were initially asked to review and provide a stage 1 audit comment on the following reports submitted by the applicants in support of the development.
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Biodiversity Enhancement and Management Plan (BEMP) by Tetra Tech dated December 2024 – IFL advise that clarification is required on a number of matters including loss of habitat within the cable route area and associated compensation, appointment of Ecological Clerk of Works, turf and soil management, pollution prevention, and a timetable and ongoing maintenance plan for landscaped areas. Landscape and Visual Appraisal by TGP landscape architects dated 3rd December 2024 – IFL agree with the conclusion of the LVA that the landscape and visual effects of the proposed development would be no more than, and perhaps somewhat less than, the previously consented scheme. Preliminary Ecological Appraisal (PEA) by Tetra Tech dated December 2024– IFL note that the report is well structured and provides an adequate level of detail for a preliminary ecological appraisal. However, it incorporates aspects of a full ecological impact assessment without sufficient supporting data with limitations in survey timing, seasonal bias and data gaps. Following review of the stage 1 audit response a meeting was held on 1st April 2025 between the Council, IFL and the applicants to discuss the responses to the BEMP and the PEA. Following this meeting, an updated version of the BEMP, PEA and Landscape and Ecology Management Plan (LEMP) were submitted to the Council. These updated documents were considered to satisfactorily address the stage 1 audit comments, and it was not considered neccesary for IFL to undertake a stage 2 audit on these documents. 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. ▪ Ministry of Defence (MoD) – No objections. ▪ NatureScot – Provide advice on measures that would help ensure impacts on natural heritage interests are minimised. Do not consider that the integrity of any SSSI’s will be adversely affected. There is currently no requirement for a species licence to be obtained. Mitigation is required with regard to breeding birds. No statutory landscape designations will be impacted. ▪ Transport Scotland – No objection subject to conditions relating to routing and movement of abnormal loads, and requirement for any additional signage or temporary traffic control measures. ▪ Scottish Environmental Protection Agency (SEPA) – No site-specific comments on the application. Reference should be made to the relevant standing advice. ▪ Historic Environment Scotland (HES) – Have reviewed the submission and have no comments. ▪ BT – The project should not cause interference to BT’s current and presently planned radio network. ▪ Scottish Gas Networks (SGN) – Have reviewed the submission and have no comments.
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▪ Health and Safety Executive (HSE) Land Use Planning Team - Have reviewed the submission and have no comments. ▪ Scottish Water – No objections. Representations The application has been publicised in line with the requirements of the relevant legislation. The ECU, as the determining authority, publicise the consent application, and representations can be submitted directly to them via their website. At the time of writing there are no letters of representation. Policy Context In making any determination under the Planning Acts, regard is to be had to the development plan unless material considerations indicate otherwise. 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 the determination of this application: National Planning Framework 4 ▪ Policy 1 – Tackling the climate and nature crisis ▪ Policy 2 - Climate mitigation and adaptation ▪ Policy 3 – Biodiversity ▪ Policy 4 - Natural places ▪ 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 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 I1 - Connecting Places ▪ Policy I3 - Flooding and Drainage ▪ Policy I4 - Renewable and Low Carbon Energy Developments New Development Supplementary Guidance ▪ Renfrewshire New Development Supplementary Guidance 2022 ▪ Delivering the Environment Strategy: Green Belt Development Criteria ▪ Delivering the Infrastructure Strategy: Renewable and Low Carbon Energy Developments Full details relating to the policies of the LDP can be found online. Submitted Reports and Assessments The following reports and assessments were submitted in support of the application:
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▪ Landscape and Ecology Management Plan (LEMP) by Tetra Tech revision V2 dated 15th April 2025 – Report has been updated following feedback from the Council and IFL. The aims of the LEMP are to reduce impacts on retained habitats on site and to detail post- construction habitat creation measures to secure biodiversity enhancement. The report notes that a Biodiversity Champion will be appointed to ensure activities during the construction and operational phase are in line with the recommendations of the LEMP. The recommendations relate to pre and mid construction habitat management strategy with regard to habitats and watercourses, and post construction habitat creation and management strategy with regard to general maintenance, hedgerows, trees, woodland scrub mix, wildflower grassland, SUDS and Monitoring. ▪ Preliminary Ecological Appraisal (PEA) by Tetra Tech revision V2 dated 15th April 2025 – Report has been updated following feedback from the Council and IFL. It is considered unlikely that the proposed development will lead to adverse impacts on designated sites. However, the site has potential to support several protected species including nesting birds, badger and reptiles. A suite of recommendations are made with regard to further survey and assessment, mitigation and enhancement. ▪ Biodiversity Enhancement and Management Plan (BEMP) by Tetra Tech revision V2 dated 15th April - Report has been updated following feedback from the Council and IFL – Summarises the baseline information at the site including habitats and protected or notable species. Several pre and mid construction enhancements are recommended with regard to bats, nesting birds, red squirrels, amphibians, invertebrates, and hedgehogs. A strategy for post construction monitoring is also included. ▪ Landscape and Visual Appraisal by TGP Landscape Architects dated 3rd December 2024 – Proposed development would be located on an area of undulating farmland which is substantially influenced by existing electricity infrastructure. The proposed scheme shares many similarities to the previously consented scheme. However previously consented synchronous condenser units have been removed from the scheme, and there are greater areas of open space within the site layout. In comparison to the consented scheme, the proposed layout would not result in any increase to the level of effect upon the landscape character, Gleniffer Braes Country Park, or the green belt. The influence would also steadily soften over time as the landscape planting matures. The proposed development could be accommodated at the site with relatively limited and localised effects on landscape character and visual amenity. ▪ Breeding Bird Survey Report by Tetra Tech version V1 dated 2nd December 2024 – Swallows were confirmed to be breeding on the site, and several other species were considered to possibly be breeding on the site. The proposed development is considered to be of low impact to breeding bird population due to the abundance of similar habitat nearby and provided mitigations are incorporated. This includes timing of vegetation clearance, noise and lighting. Enhancements in the form of landscape planting and bird boxes are also recommended. ▪ Pre-Application Consultation Report by Statkraft revision R3 dated 27th November 2024 – Summarises the pre-application consultation measures undertaken in line with the ECU document titled Good Practice Guidance for Applications under Section 36 and 37 of the Electricity Act 1989. In this instance the consultation comprised of 2 public exhibitions, 1 virtual public exhibition, 1 newspaper and resident letters. Councillors for ward 7, George Adam and Tom Arthur MSP and Foxbar and Elderslie CC were also
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notified of the public events. A project website was also established. Public events were held at Foxbar Community centre on 1st February and 7th March 2024. A summary of consultation responses is also provided. ▪ Outline Construction Environment Management Plan by Statkraft revision R1 dated 27th November 2024 – Outlines a suite of outline construction environmental issues including management of site waste, sewage disposal, car parking, lighting, noise, dust, pollution control and traffic management and the associated procedures t ensure these issues are appropriately controlled. ▪ Noise Impact Assessment by Statkraft revision R0 dated 20th August 2024 – Noise impact has been modelled based on all plant and colling equipment operating concurrently and at 100% capacity. However, in reality this will not occur. There is only one residential receptor close to the development. The assessment concludes that due to the difference between the rating level and the background noise level and the context of the development it is concluded that the development is not expected to have an adverse impact in terms of noise. ▪ Planning, Design and Access Statement by Statkraft revision R2 dated 27th November 2024 – The development would result in an improvement to the reliability and stability of the electrical network, and allow increasing levels of renewable energy generation to be more fully integrated into the electrical system. A summary of the planning history on the site is provided, noting the previous scheme consented on appeal. The various components of the scheme and the associated layout are also set out. A review of the development against the relevant renewable energy policy and the development plan is also undertaken. ▪ Planning Guidance Note by Statkraft revision R2 dated 27th November 2024 – Primarily provides a review of the planning history and a comparison between the proposed scheme and the previously consented scheme. The main differences notes are the omission of the synchronous condensers which were due to be houses in 6m high buildings, removal of battery units from underneath the overhead cables, provision of a secondary access for emergency purposes, provision of a SUDS pond, and provision of additional landscaping. ▪ Transport Statement and Construction Traffic Management Plan by Pell Frishmann Revision 04 dated 3rd December 2024 – Considered the likely impact of traffic generated by the proposed development on the local road network. Traffic management procedures have been proposed to ensure the safe operation of the approach route to the site during construction. Operational traffic is expected to be minimal as the site will not be manned. The impact of operational traffic is expected to be negligible. ▪ Lighting Plan Review Technical Note by Tetra Tech – Summarises the review of the proposed lighting scheme and its compliance the Institute of Lighting Professionals/Bat Conservation Trust guidance on bats and artificial lighting at night with the view to limiting the risk of adverse impacts to ecological receptors. The lighting scheme is inward facing with low levels of light spill. PIR sensors are used to lighting is only triggered by people, and would only be switched on occasionally and on a small section of the site during night time maintenance. The effect on bats or nesting birds is expected to be minimised to within the accepted levels stipulated in the guidance.
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▪ Detailed Drainage Strategy by Vazquez Besada Consulting revision 02 dated 21st August 2024 - Surface water treatment will be provided via filter drains and a new proposed SUDS basin. The SUDS basin will provide attenuation volume for all new impermeable areas. No flooding water is expected to leave the site boundary for any of the storm events considered. Safe access and egress is provided at all times. No proposed foul water connection is required. ▪ Landscape Specification by TGP Landscape Architects dated 10th June 2024 – Provides a specification for the ground preparation, panting and ongoing maintenance of the landscaping scheme. ▪ Landscape Management Plan by TGP Landscape Architects dated 9th December 2024 – Sets out a management and maintenance schedule for the landscaped areas. Scottish Ministers Direction 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 application for the battery energy storage system 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 to the 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). A key material consideration in the Councils assessment is also the planning history associated with the site. As noted above and in the applicants Planning Guidance Note, a BESS has previously been granted consent on this site via appeal under planning application 21/0034/PP. For the previous consented application and this S36 application, the application site is the same. However, for the purposes of the S36 proposal the footprint of the development has been reduced as battery units are no longer proposed underneath the overhead lines. Additionally, some of the ancillary infrastructure associated with the previous consented scheme has also been omitted. On balance it is considered that the visual impact of the proposed S36 scheme would be no more than, and perhaps somewhat less than, the previously consented scheme. Turning to the development plan, the application site is located within the green belt. Policies ENV1 of the LDP and 8 of NPF4 both consider essential infrastructure to be an acceptable form of development within the green belt in principle.
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Battery storage systems are a key component in the decarbonisation of the electricity grid, and the transition towards greater electricity generation from renewable sources. The battery systems will store excess energy during times of surplus generation. This is then fed back into the grid during times of demand. This provides for a more resilient and stable energy supply. It is considered that the proposal does constitute essential infrastructure and complies in principle with policies ENV1 of the LDP and 8 of NPF4 relating to the green belt. The development is also considered to comply with policies 1 and 2 of NPF4 relating to climate mitigation and tackling the climate crisis. 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 in turn as follows. The development will not result in the loss of prime quality agricultural land or agricultural land of lesser quality that is locally important. The development does not have any implications for areas of wild land. The Roads Development officer has not objected to the development. They have listed several matters that would need to be considered by the developer to ensure that the site can be accessed safely. This includes matters relating to sightlines, construction traffic, and forward visibility. Conditions relating to these matters can be recommended to the ECU. There is no anticipated effect on public water supply or water courses from pollution risk. A detailed Construction Environmental Management Plan (CEMP) can be requested through condition which would ensure pollution control measures are implemented during the construction phase. The submission also includes a drainage strategy which will ensure all surface water is managed appropriately. The development does not impinge upon any existing active travel routes. Regarding visual impact and landscape character, IFL agree with the conclusion of the LVA that the landscape and visual effects of the proposed development would be no more than, and perhaps somewhat less than, the previously consented scheme. It is noted that the scheme includes planting of a mixed hedge and trees along the northwestern, southwestern and south eastern boundaries. The southwest boundary includes provision for a buffer strip approximately 25 metres wide which will be planted with a native woodland edge mix. The tallest element of the scheme, the HV yard, is located in the western corner of the site which is the lowest part of the site in terms of ground levels and is also screened by existing vegetation which is adjacent to Gleniffer Road. The HV yard is also set back from the road, with provision for additional hedge and tree planting adjacent to the proposed emergency access. The submission also indicates that the battery units will be finished in green. This will help mitigate the visual impact of the battery units. It is acknowledged that the battery units within the 1st phase are finished in white. However, these units will be partly screened by the later phases of the development and the associated landscaping. The submission indicates that the site would also be bound by a 3.4-metre-high perimeter fence. The grouping of the batteries and the siting of the HV yard is considered to be
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acceptable. The incorporation of two strips of grassland under the overhead lines will help to break up the footprint of the site and reduce its visual impact in comparison to the previously consented scheme. It is considered that the development will not have a significant impact on local landscape character and on balance the impact will be less than that associated with the previously consented scheme. With respect to cumulative visual impact, the development would be adding to an extensive energy landscape. The additional effects of the development would not be significant against this baseline and would be less than that associated with the previously consented scheme. Visual impact would be further reduced by the mitigation planting. It is considered that the development is acceptable with regard to cumulative visual impact. There is no requirement to incorporate access to open space, and the development does not impinge upon any existing areas of accessible open space. It is anticipated that the development will require a second cable connection to the Neilston substation in addition to that approved under application 23/0224/PP. While a cable route originally formed part of the S36 submission, it has now been omitted, and the applicants advise that the cable route would be the subject of a standalone planning application once a suitable routing option has been identified. With regard to ecology, IFL note that the PEA report is well structured and provides an adequate level of detail for a preliminary ecological appraisal. The PEA has been updated in response to the consultation from IFL, and notes that the site has the potential to support several protected species however detrimental impacts on designated sites is not anticipated. It is considered that potential impacts on protected species can be mitigated via the recommendations within the PEA. The BEMP recommends a number of enhancements which can be undertaken at the site with regard to biodiversity. This document has also been updated in response to the consultation from IFL, namely the appointment of a biodiversity champion to monitor the implementation of the measures set out within the BEMP, LEMP and PEA. The updates to these documents and the discussions undertaken between the Council, the applicants and IFL are considered to constitute a level of assessment that is proportionate to the development being proposed again noting that a larger scheme can be implemented under the previous planning permission without further assessment of ecological matters. A condition can be recommended to ensure the mitigations and enhancements set out within the BEMP, LEMP and PEA are implemented on the site. The development does not include proposals to convert any existing buildings. In view of the above it is considered that the development complies with the green belt development criteria set out within the supplementary guidance. The criteria set out within Policy 8 of NPF4 which have not already been discussed above, are as follows. The green belt location is neccesary in this instance given its proximity to the Neilston substation to which a connection to the grid network can be made. Proximity to a substation where a grid connection is available is critical for BESS developments. BESS schemes are considered to constitute essential infrastructure, and the acceptability of a BESS scheme at this location has been established under application 21/0034/PP.
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The development is for essential infrastructure in an area already characterised by electricity infrastructure. It is considered that the purpose of the green belt at this location (which is to maintain identity of settlements, protect landscape setting, and promote access opportunities to open space) will not be undermined. There will not be any significant long-term impact on the environmental quality of the green belt. It should be noted at this stage that a condition would be recommended to restrict the time period of consent to 40 years at which point the development will be decommissioned and the site restored (unless otherwise agreed in writing with the Council). However, the landscape planting and biodiversity enhancements will be retained, and on balance the long- term environmental quality of the green belt will be safeguarded. In view of the above assessment, it is considered that the development is fully compliant with the green belt policies ENV1 of the LDP and 8 of NPF4 and should be considered as a suitable development at this green belt location. 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 energy storage. Policy I4 includes several detailed assessment criteria which will be considered in turn as follows. The potential impact of the development with respect to local environment, landscape character and the natural environment has been discussed above. There are no above ground-built heritage designations in or in close proximity of the site. The presence of a WW2 bunker is noted however this feature is not listed or covered by any statutory designation. Nevertheless, the proposed site plan indicates that it will be safeguarded as part of the development layout. Potential impact on the water environment can be mitigated through the incorporation of a strategy to manage surface water and pollution control during the construction phase. A condition is recommended with respect to the implementation of the surface water drainage strategy. With regard to amenity of neighbouring residential receptors, the Environmental Protection Team have offered no objections to the development however a condition is recommended with respect to limiting noise levels associated with the plant and machinery at the site. There are no implications with regard to air quality, glare or shadow flicker and visual impact has already been discussed above. It is considered that the amenity of neighbouring residential receptors will not be detrimentally impacted in this regard and again the impacts are likely to be less than that associated with the previously consented scheme. The development will not have a detrimental impact on outdoor sport or recreation interest. Matters relating to transport infrastructure and road safety have been discussed above. There have been no objections from Roads Development Officer or Transport Scotland with regard to potential impact on the local and trunk road network. Glasgow Airport Safeguarding and NATS have also offered no objections to the development with regard to the safe and efficient use of Glasgow Airport. The site is not within a potential heat network opportunity area.
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The relevant criteria within the new development supplementary guidance on renewable and low carbon energy developments (not already discussed above) are assessed as follows. Conditions can be used to ensure arrangements are in place to restore the site to an acceptable standard after the operation of the BESS has ceased. This includes the submission of decommissioning and restoration strategies, and also 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. This application is welcomed as it is noted the previous consent 21/0034/PP does not include provision for a financial guarantee to ensure decommissioning works are undertaken. The development will contribute to renewable energy generation and carbon emission reduction targets by providing 750MW of storage capacity. This will allow energy from renewable sources to be stored at times where supply exceeds demand, and then fed back into the grid at times when demand exceeds supply. This will contribute to the further decarbonisation of the electricity supply, and also provide stability to the electricity grid. The criteria set out within Policy 11 of NPF4 which have not already been discussed above, are as follows. The applicant identifies the following socio-economic benefits associated with the development: - Direct effects on employment levels during construction, operation and decommissioning. - Indirect effects on economic activity such as the supply chain and economic stimulus from expenditure of additional employment income. - Induced effects including additional employment created by the spend of additional employment income. The planning statement also notes that the scheme could have an economic impact through the potential to significantly reduce energy bills. The development will make an important contribution to decarbonising the electricity supply and provide stability to the grid system. There will be no detrimental impact on international or national designated sites. It is not anticipated that there will be any detrimental impacts on telecommunications and broadcasting installations. There are no trees within the site which would be removed to accommodate the development. A condition can be used to ensure appropriate measures are put in place to protect trees on the edge of the site during the construction phase. The site is not at risk of flooding. Appropriate management of surface water will ensure that flood risk does not increase elsewhere. In view of the above, it is considered that the development complies with Policies I4 of the LDP and 11 of NPF4. The above assessment broadly demonstrates compliance with the other relevant development plan policies as follows. The development will contribute to the enhancement of biodiversity at the site in accordance with the requirements of Policy 3 of NPF4. The proposed appointment of a biodiversity champion is noted in this regard.
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The development will not have an unacceptable impact on the natural environment and will not have a significant impact on any national or local designated sites in accordance with Policy 4 of NPF4 and ENV2 of the LDP. There are no trees which will be removed to accommodate the development, and measures will be put in place to protect existing trees on the periphery of the site boundary. The development accords with Policy 6 of NPF4 and ENV2 of the LDP. There are no above ground designated historic environment assets within or on the boundary of the site that would be impacted by the development. The development complies with policy 7 of NPF4 and ENV3 of the LDP. Recommended conditions in respect of construction traffic management, sight lines and road safety audit will ensure that the site can be accessed safely, and that the operation of the local road network will be safeguarded during the construction and operational phases of the development. The development has a low trip generation during its operational phase and does not require accessibility via public transport or active travel routes. The development complies with policy 13 of NPF4 and I1 of the LDP. The proposed landscape planting that will form part of the scheme will contribute to screening the development over time. It is acknowledged that in the short term and before the landscaping matures the development will be visible. However, this impact can be mitigated via the external colour associated with the component infrastructure. The development complies with policy 14 of NPF4. The application site is not at risk of flooding, and the implementation of a sustainable drainage strategy for the management of surface water will not increase flood risk elsewhere. The development complies with policy 22 of NPF4 and I3 of the LDP. The Council is required to provide a summary of the terms of any planning obligation which is required to be entered into under Section 75 of the Town and Country Planning (Scotland) Act in relation to the grant of permission for the proposed development: A legal agreement or other form of planning obligation (potentially a suitably worded planning condition(s)) is required to secure decommissioning of the development and the restoration of the site. Conclusion The approach to the assessment and recommendations within this report reflect the fact that the Council is a consultee under the Electricity Act 1989 and that the ECU are the determining authority. In conclusion, the proposed development is considered to be compliant with the development plan subject to planning conditions and/or a planning obligation to secure decommissioning of the development and the restoration of the site. All other consultation responses noted to date indicate that the proposed development would be acceptable. It is therefore recommended that the Council raises no objections to the development. The position of the Council as a statutory consultee to this Section 36 application of no objections is subject to and reliant upon the matters and topics set out in the conditions listed in this report and also the requirements for the matters associated with decommissioning of the development and the restoration of the site being appropriately secured. For clarity, should conditions and/or a planning obligation covering each of these matters and topics not be imposed by the Energy Consent Units (ECU), then the Council’s position as a statutory consultee would be one of objection.
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In wording the conditions it is noted that phase 1 of the development has already commenced and is managed via conditions attached to the other consents listed above. For the purposes of the S36 response the conditions shall therefore refer to commencement of development within phase 2 (development of the remainder of the site) with respect to the substantive matters still to be addressed. Recommendation No objection subject to the conditions listed below being applied to any decision should the ECU be minded to approve the Section 36 application. The position of the Council as a statutory consultee to this Section 36 application of no objections is subject to and reliant upon the matters and topics set out in the conditions listed in this report and also the requirements for the matters associated with decommissioning of the development and the restoration of the site being appropriately secured. For clarity, should conditions and/or a planning obligation covering each of these matters and topics not be imposed by the Energy Consent Units (ECU), then the Council’s position as a statutory consultee would be one of objection. Reason(s) for Recommendation 1. The proposed development is compliant with the development plan subject to planning conditions and a form of planning obligation (condition and/or legal agreement) to secure appropriate funding for the decommissioning of the development and the restoration of the site. All other consultation responses noted to date indicate that the proposed development would be acceptable. Condition(s) 1. The development to which this permission relates must be begun not later than the expiration of three years from the date of its grant. Reason: This condition is for the purpose of the good planning of the area, to ensure that the permission will lapse if it is not implemented within three years. 2. The development is hereby approved for a temporary period of 40 years from the date of final commissioning of the development. Written confirmation of the date of first commissioning shall be provided to the Planning Authority no later than one calendar month after that date. Reason: In order to retain effective planning control. 3. That within 3 months of the date of the consent the developer shall submit a phasing plan for the written approval of the Planning Authority. The plan shall include phase 1 of the project which is defined as the area currently under construction in the northwest corner of the application site, and all subsequent phases of development thereafter. Reason: In the interests of retaining effective planning control. 4. Prior to the commencement of any development within phase 2 of the BESS as defined within the phasing plan approved under condition 3 above, an outline decommissioning, site restoration and aftercare strategy shall be submitted to and
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approved in writing by the Planning Authority. The strategy shall, without limitation, detail proposals for: (a) The removal of all above and below ground elements of the development; (b) The treatment of all ground surfaces, including any sub surface areas, hard standing and access tracks which would restore the site to its former condition or other such condition as agreed by the Council as Planning Authority; (c) The phasing and timing of the works, including any environmental management provisions; (d) Details relating to how and when the strategy will be reviewed. Reason: To ensure the decommissioning and removal of the development is in an appropriate and environmentally acceptable manner and the restoration and aftercare of the site, in the interests of safety, amenity and environmental protection. 5. No later than 3 years prior to decommissioning of the development or the expiration of this consent (whichever is the earlier) a detailed decommissioning, restoration, and aftercare plan, based upon the principles of the approved outline decommissioning, restoration, and aftercare strategy, shall be submitted to the Planning Authority for written approval. The detailed decommissioning, restoration and aftercare plan shall include (but not be limited to the) provisions in respect of the following matters: ▪ Decommissioning and removal of the battery energy storage system units including treatment of liquid bearing components ▪ Removal of any in-situ foundations including removal to a depth of at least 1m underground ▪ Removal of all above ground infrastructure and buildings including but not limited to substations, HV Yard and associated buildings, containers, fencing, lighting masts, internal tracks, equipment and hard standings ▪ Cable removal ▪ Provision of Decommissioning Environmental Management Plan (DEMP) to be based on relevant elements of the Construction Environmental Management Plan (CEMP) ▪ A Traffic Management Plan (TMP) related to activities for decommissioning, demolition, and removal of infrastructure ▪ Locations of temporary stockpiles for decommissioned materials and equipment ▪ Treatment of disturbed ground surfaces resulting from decommissioning of infrastructure including cable removal and any sub-surface elements to restore the land to its pre-construction status or such condition as agreed in writing with the LPA ▪ Restoration proposals including ecological and biodiversity enhancement works such as (but not limited to) provision of bird boxes, insect refuge and use of native seed mixes to deliver biodiversity gains and measures to safeguard all landscaping on the site which for the avoidance of doubt shall be retained. ▪ An aftercare plan to monitor success of restoration measures with scope for interventions if required ▪ A Decommissioning Timetable
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Thereafter the detailed decommissioning, site restoration and aftercare plan shall be undertaken in accordance with the approved plan, unless otherwise agreed in writing by the Planning Authority. Reason: To ensure the decommissioning and removal of the development in an appropriate and environmentally acceptable manner and the restoration and aftercare of the site, in the interests of safety, amenity and environmental protection. 6. Prior to the commencement of any development within phase 2 of the BESS as defined within the phasing plan approved under condition 3 above, a bond to cover the costs of decommissioning, site restoration and aftercare, as required by conditions 4 and 5 of this consent, shall be submitted for the written approval of the Planning Authority. The acceptability of such bond shall be at the sole discretion of the Planning Authority. The bond must: A) be granted in favour of the Planning Authority and shall be maintained in favour of the Planning Authority throughout the duration of this consent and until the completion of all decommissioning, site restoration and aftercare obligations as required by conditions 4 and 5 of this consent; B) be granted by a bank or insurance company (whose identity and covenant strength shall firstly have been approved by the Council and shall have at least an A - rating) and who shall be capable of fulfilling the obligations under the guarantee; C) be for an amount which covers the value of all decommissioning, site restoration and aftercare liabilities, such amount to be determined by the Planning Authority at the commencement of Development; D) be subject to a review every five years from the date of this consent, or other such intervals as agreed by the Planning Authority. Each review shall be undertaken by a suitably qualified independent professional who has relevant experience in such matters and who has been agreed in writing beforehand by the Planning Authority. The review shall be submitted no later than three months prior to the expiry of the existing bond, for the written approval of the Planning Authority. Thereafter and at least 28 days prior to the expiry of the existing bond, a replacement bond in favour of and in terms acceptable to the Planning Authority and for the value advised by the review noted above, shall be submitted for the written approval of the Planning Authority. E) come into effect on or before the date of commencement of Development, and expire no earlier than 24 months after the end of the aftercare period. No work shall begin at the site until both: written approval of the Planning Authority has been given to the terms of such bond and; the validly executed guarantee has been delivered to the Planning Authority. In the event that the bond becomes invalid for any reason, no operations will be carried out on site until a replacement bond completed in accordance with the terms of this condition is lodged with the Planning Authority.
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Reason: In the interests of amenity and in order to retain effective planning control. 7. In the event that the financial guarantee becomes invalid, has expired, or is terminated for any reason following the commencement of operations at the site, all operations at the site shall cease no later than three months from the date the financial guarantee became invalid, expired or terminated. If a replacement financial guarantee, which meets the requirements of condition 6, is approved by the Planning authority and duly executed before the end of the three-month period, the operations may continue. If the operations have ceased due to this clause, they may recommence only upon the approval and execution of a replacement financial guarantee. Reason: In the interests of amenity and in order to retain effective planning control. 8. Prior to the commencement of any development within phase 2 of the BESS as defined within the phasing plan approved under condition 3 above, the developer shall submit a Construction Traffic Management Plan (CTMP) for the written approval of the Planning Authority. The CTMP shall include (but not be limited to) details in respect of; - Details of the design, layout, geometry, surface finish and sight lines of the access including geometry for the construction and post construction phase of the development and swept path to demonstrate that the largest expected vehicle can access the site. - The additional signage on both public roads where access will be taken to inform drivers of the construction vehicles. - Details of proposed temporary site compound for storage of materials, machinery, and designated car parking. - Details of construction traffic routing, vehicle types and number of journeys, taking into account the axle weights/amounts as a model against the type of road and its age. The details set out within the approved CTMP shall thereafter be implemented on site during the construction phase. Reason: To ensure traffic impacts are mitigated during the construction phase, and that the construction phase is undertaken safely. 9. Prior to the commencement of any development within phase 2 of the BESS as defined within the phasing plan approved under condition 3 above, either enabling works or construction works, a Construction Environmental Management Plan (CEMP) shall be submitted to and approved in writing by the Planning Authority. The CEMP shall include (but not be limited to) provisions in respect of: ▪ Project Title Page – Defines the project and applicant details ▪ Distribution List – Includes external recipients chiefly LPA and internal distribution such as contractors; to ensure familiarity with the consented requirements ▪ Introduction – Project overview, site description, scope of proposed works, programme of works, details of any previous environmental assessments
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▪ Roles and Responsibilities – Organisational Chart of project personnel and key contacts plus training and competencies and communication procedures ▪ Environmental Management Policy Statement – To include any accreditations or EM Systems followed ▪ Regulations and Requirements – Legislation, Regulations and Technical Guidance applicable to the nature and scope of the development ▪ Identification of Environmental Assets and Impacts: ▪ Emissions to air – dust, noise, vibration, traffic/ vehicle movements on site and to/ from site ▪ Land and Water (extends to surface and ground water) – discharges from construction activities, i.e. pollution, substance contamination, damage, waste management ▪ Archaeology and heritage features ▪ Ecological features including habitats and species ▪ Environmental Mitigation Measures and control plans with regard to identified environmental assets and the potential impacts arising from construction; to take cognisance of relevant Legislation and Regulations and follow appropriate Technical Guidance/ best practice ▪ Inclusion of an Emergency/ Incident Response Plan ▪ Monitoring and Auditing – Procedures for audits (internal and external), monitoring and inspections, environmental performance monitoring e.g. KPIs, monitoring/ inspection reporting ▪ The measures set out within the approved CEMP shall thereafter be implemented on site during the construction phase. Reason: To ensure environmental impacts are mitigated during the construction phase, and that the construction phase is undertaken safely. 10. The design, installation and operation of any plant, machinery or equipment shall be such that noise associated with the development does not exceed Noise Rating Curve NR25 between the hours of 2300 to 0700 hours and NR 35 at all other times, when measured within any dwelling in the vicinity of the development. Structure borne vibration from the proposed development shall be imperceptible within any dwelling in the vicinity of the development. For an explanation of noise rating curves, refer to BS 8233:2014 Sound insulation and noise reduction in buildings- code of practice, Annex B Reason: To mitigate potential noise impact on sensitive receptors within the vicinity of the site boundary. 11. In the event that the Council receives a complaint relating to noise emissions from the development, the operator shall at its own expense and at the Councils request
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employ an independent noise consultant to undertake a noise impact assessment to determine the level of noise emissions at any noise sensitive receptor in the vicinity of the development. Prior to undertaking the noise impact assessment, the parameters, methodology and acceptable noise limits shall first be agreed in writing with the Planning Authority. The noise impact assessment shall provide, if required, mitigation measures and an associated timetable for their implementation to be implemented to ensure noise emissions do not exceed the agreed noise limits. The mitigation measures shall thereafter be implemented in accordance with the agreed timetable. Reason: To mitigate potential noise impact on sensitive receptors within the vicinity of the site boundary. 12. Prior to the commencement of any development within phase 2 of the BESS as defined within the phasing plan approved under condition 3 above, the developer shall submit a site plan and section drawing(s) and associated specification for the written approval of the Planning Authority detailing the existing and proposed ground levels within the site including the requirement for any associated wall retention, cut and fill, earth moving and mounding. Only the approved details shall thereafter be implemented on site. Reason: In the interests of visual amenity. 13. That prior to the facility hereby approved being brought into use, the developer shall submit a road safety audit and traffic management plan and for the written approval of the Planning Authority. The management plan shall identify measures to reduce the speed of vehicles along the stretch of Gleniffer Road conterminous with the visibility splay area, and a timetable for the installation of the measures. The measures shall thereafter be implemented in accordance with the agreed upon timetable. Reason: To reduce traffic speeds in the interests of traffic safety. 14. All works associated with the construction of the vehicular access hereby approved shall ensure a visibility splay measuring 4.5m x 215m x 1.05m is provided prior to the facility being brought into use and forward visibility of 215m shall be provided for vehicles turning right into the site. The splay shall thereafter be maintained throughout the life of the development to ensure that no features within the splay shall exceed 1.05m in height. Reason: To ensure the site can be accessed safely. 15. That the drainage strategy set out in the Detailed Drainage Strategy by Vazquez Besada Consulting revision 02 dated 21st August 2024 shall be implemented on site and made operational prior to phase 2 of the BESS as defined within the phasing plan approved under condition 3 above is energised. The drainage strategy shall be maintained thereafter for the life of the development in accordance with section 5.7 and appendix H of the Detailed Drainage Strategy by Vazquez Besada Consulting revision 02 dated 21st August 2024. Reason: To ensure the drainage strategy is implemented in the interests of the sustainable management of surface water.
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16. That all recommendations set out in section 4 of the Preliminary Ecological Appraisal (PEA) by Tetra Tech revision V2 dated 15th April 2025 shall be implemented on site during the construction phase. Reason: In the interests of safeguarding protected species. 17. That any lighting scheme to be installed at the BESS shall be designed in accordance with the specification set out within the Lighting Plan Review Technical Note by Tetra Tech Revision V2 dated 5th December 2024. Reason: To ensure the lighting scheme is sensitive to ecological receptors at the site. 18. Prior to the commencement of any development within phase 2 of the BESS as defined within the phasing plan approved under condition 3 above, the developer shall first submit for the written approval of the Planning Authority a detailed phasing plan for the implementation of all landscaping as detailed in drawing L01 revision C titled Landscape Planting Plan – Main Compound. The landscaping shall thereafter be implemented in accordance with the approved phasing plan and the Landscape Specification by TGP Landscape Architects dated 10th June 2024, and maintained for the life of the development in accordance with the Landscape Management Plan by TGP Landscape Architects dated 9th December 2024, the Landscape and Ecology Management Plan (LEMP) by Tetra Tech revision V2 dated 15th April 2025, and the Biodiversity Enhancement and Management Plan (BEMP) by Tetra Tech revision V2 dated 15th April. Reason: To ensure the approved landscaping is implemented and maintained appropriately for the life of the development. 19. That the external finish colour of all above ground elements of the development (with the exception of the HV Yard) including (but not limited to) all battery units, buildings, containers, plant, and other component infrastructure, and all boundary fencing and gates to be developed at the site shall be RAL 6003 Olive Green unless otherwise agreed in writing with the Planning Authority. Reason: To ensure the components are of an appropriate external finishing colour in the interests of visual amenity. Schedule of Plans Determined Drawing Number Revision Drawing/Document Title V2 Landscape and Ecology Management Plan (LEMP) by Tetra Tech dated 15th April 2025 V2 Preliminary Ecological Appraisal (PEA) by Tetra Tech dated 15th April 2025 V2 Biodiversity Enhancement and Management Plan (BEMP) by Tetra Tech dated 15th April Landscape and Visual Appraisal by TGP Landscape Architects dated 3rd December 2024 V1 Breeding Bird Survey Report by Tetra Tech
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dated 2nd December 2024 Pre-Application Consultation Report by Statkraft revision R3 dated 27th November 2024 R1 Outline Construction Environment Management Plan by Statkraft dated 27th November 2024 R0 Noise Impact Assessment by Statkraft dated 20th August 2024 R2 Planning, Design and Access Statement by Statkraft dated 27th November 2024 R2 Planning Guidance Note by Statkraft dated 27th November 2024 04 Transport Statement and Construction Traffic Management Plan by Pell Frishmann dated 3rd December 2024 V2 Lighting Plan Review Technical Note by Tetra Tech dated 5th December 2024 02 Detailed Drainage Strategy by Vazquez Besada Consulting dated 21st August 2024 Landscape Specification by TGP Landscape Architects dated 10th June 2024 Landscape Management Plan by TGP Landscape Architects dated 9th December 2024 15957-024 0 Site Location Plan 15957-025 11 Proposed Site Layout 15957-026 6 Existing Site Layout Plan 500 scale 15957-026 6 Existing Site Layout Plan 1250 scale 1597-008 0 Diesel Generator 15957-009 0 Auxillary Transformer 15957-010 0 Control and Switchgear Buildings 15957-011 0 HV Yard 15957-012 0 Type B BESS 15957-013 0 Type C BESS 15957-014 0 Stores and Welfare Buildings 15957-015 0 MV Room 15957-016 0 External Fence 15957-021 0 Underground Water Tank 15957-027 0 Type A BESS 15957-028 0 Genset 15957-033 0 CCTV Pole 0900 P02 Artic SPA 0100 P07 Overall Site Layout 0101 P07 Compound Layout Sheet 1 of 2 0102 P07 Compound Layout Sheet 2 of 2 0200 P07 Site Sections 1 of 6 0201 P07 Site Sections 2 of 6 0202 P07 Site Sections 3 of 6 0203 P07 Site Sections 4 of 6 0204 P07 Site Sections 5 of 6
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0205 P07 Site Sections 6 of 6 0206 P05 Access Road Under Over Headline sheet 1 0207 P03 Access Road Under Over Headline Sheet 2 For further information please contact James Weir, Development Standards Team, Email: james.weir@renfrewshire.gov.uk