24-0052-EB - Gleniffer Road BESS GMC DL
Renfrewshire Council · 28 May 2024
Back to Planning and Climate Change Policy Board — 28 May 2024 and its agenda
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Report by Chief Planning Officer Planning and Climate Change Policy Board: 28 May 2024 Reference No 24/0052/EB Application Type Electricity Undertaking Determination Proposal Section 36 application to construct and operate a 150MW battery energy storage facility together with associated infrastructure, substation, security fencing, cctv, security lighting and landscaping (Energy Consents Unit consultation request) to view plans go to https://www.energyconsents.scot/ApplicationDetails.aspx?cr=ECU00 004868 Location Neilston Battery Storage System Site, Gleniffer Road, Paisley Ward 7 - Paisley Southwest Community Council Elderslie Community Council Applicant Carolanne Brown Energy Consents Unit Scottish Government Recommendation No objection, subject to suggested conditions All plans, reports, documents and representations relating to this application can be viewed in full online at https://pl-bs.renfrewshire.gov.uk/online- applications/applicationDetails.do?activeTab=summary&keyVal=S7RAWAMW00B00 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 150MW battery energy storage system together with associated infrastructure, substation, security fencing, cctv, security lighting and landscaping on land at 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 battery energy storage system would have a maximum installed capacity of 150MW, 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 response to the ECU that would then be taken into consideration as part of the consenting process. In this regard, the Council in response to the consultation can either: - Offer no objections to the Section 36 application as submitted; - Offer no objections subject to the imposition of appropriate conditions and/or legal obligations it considered neccesary 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.
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Should Scottish Ministers be disposed to grant the Section 36 application, the applicant has requested that deemed planning consent be granted via direction under the terms of section 57 of the Town and Country Planning (Scotland) Act 1997. A separate application for planning permission would not therefore be required for the proposed development. 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 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 battery energy storage facilities. Proposal The proposed development comprises of a Battery Energy Storage Facility (BESS) with an output capacity of up to 150MW. The submission includes an indicative layout which shows four rows of the battery components arranged in a southwest to northeast orientation. The associated infrastructure which includes control rooms and transformers is located to the south east fronting Gleniffer Road. The site is served via an existing field access which will be upgraded, with an internal network of 4m wide roads providing access to the individual components. The proposal includes a landscaped buffer of approx. 30m in depth along the south east boundary, and approx. 20m in depth along the south west boundary. To the north east and north west there is an area of compensatory woodland planting associated with application 20/0793/PP which will provide some further screening when it matures. It is noted that planting in this area has commenced. It should be noted that the proposed site layout and component infrastructure is indicative of a 150MW installation. On this basis the developer has sought a micro-siting allowance of up to 25m in all directions within the red line boundary. This is to allow flexibility in procurement of the battery units and associated infrastructure, and the current advances in battery infrastructure technology. The proposed development has been the subject of an EIA screening request (ref: 23/0340/EA) from the ECU. The Councils response was that the development should be accompanied by an EIA given the cumulative visual impact of this and other consented developments along Gleniffer Road. However, Scottish Ministers concluded that the development did not require an EIA (ECU ref: ECU00004868). Site Description The application site comprises approx. 3 hectares of relatively flat grassland located on the northwestern side of Gleniffer Road. It is located approx. 600m to the south west of the Neilston substation, and approx. 3km to the south west of Paisley. The site is bound by Gleniffer Road to the south east, with rough grassland and low lying vegetation to the south west, north west and north east. The grid stability facility approved under application 20/0793/PP lies to the north of the site, with the Neilston sub station and a BESS approved under application 21/0034/PP lying to the north east. In terms of sensitive receptors in the vicinity of the application site Caplaw Farm lies approx. 250m to the south east, Lapwing Lodge is approx. 280m to the south west, and Bent Farm is approx. 550m to the west.
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The site is 230m to the south west of the Gleniffer Braes Country Park boundary. The Bardrain Glen, Sergeantlaw Moss and Gleniffer Braes West Site of Importance for Nature Conservation (SINC) is also 230m to the north east and 250m to the north of the site. 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. No pre-application discussions have taken place. Negotiated Improvements Following submission, no changes have been negotiated. Site History Application No: 23/0340/EA Description: Construction and operation of 150MW battery energy storage facility together with associated infrastructure, substation, security fencing, CCTV, security lighting and landscaping (Consultation request from Energy Consent Decision: Scottish Ministers decided that an EIA was not required. Consultations Glasgow Airport Safeguarding - No objections. Advisory note required with respect to the use of cranes. Environment, Housing & Infrastructure (Env. Protection) - No objection subject to condition relating to noise associated with the design, installation and operation of any plant, machinery or equipment. NATS - No comments. Chief Executive's Service (Roads Development) – raise concerns regarding the safety of the access to the site given the dip in the road, local speeds and impact of cumulative accesses being formed as new developments come forward. Roads Development have requested the following conditions in order to ensure the safety of this section of the road is protected, 1. Reserve a 7m width of frontage for use as a future pedestrian and cycle link along the frontage of the site. 2. Achieve 9x120m x 600mm high sightlines in both directions, removing all obstructions (fences, shrubs, scrub and dykes) within it. 3. Carry out a Road Safety Audit including 7-day speed survey to establish the 85percentile speeds in normal traffic situations and implement the recommendations. 4. Agree with Planning Authority and introduce measures to differentiate between the proposed access and Hartfield Road junction to prevent wrong turning. 5. Agree with Planning Authority temporary construction measures to reduce speeds locally and ensure site traffic doesn't need to cross into traffic coming from Paisley when exiting left. 6. Agree a joint routing agreement including East Renfrewshire's Road Authority should fill originate from there. Note, routes other than the B775 are not considered suitable for prolonged construction traffic deliveries. Scottish Power Networks (Transmission Sites) - No response.
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Scottish Power Networks (Distribution Sites) - No response. West of Scotland Archaeology Service - Condition required with respect to an archaeological watching brief and implementation plan. S.E.P.A - No objections. Nature Scot - Proposal will not give rise to any adverse impacts on any natural heritage interests of local or national importance. Broad range of proposed mitigations are welcomed. Ironside Farrar Ltd (IFL) (Councils Independent Consultants) - IFL were asked to review and provide comment on the following aspects of the project. Landscape and Visual Assessment - The assessment is largely adequate in scope and reasonable in its findings. There is sufficient detail to allow the main issues to be understood. There are some minor inconsistencies and some of the effects should be assessed as slightly higher although none would be extensive or major. It is recommended that landscape mitigation is undertaken at 1.5m to 2m centres (as opposed to the 5m centres set out) to ensure that the screening visualisations are more likely to be achieved at the 15-year period. Preliminary Ecological Appraisal - The site looks to be of low interest, but the report provided, and survey data presented is not considered adequate e.g. report does not conform to Chartered Institute of Ecology and Environmental Management (CIEEM) guidance, habitat baseline does not include a table of habitat areas, and species baseline is weak as it does not include survey data. There may be information that can be included, and the report revised. Land Capability for Agriculture - The site is not located on prime agricultural land or peatland. However additional information is still required regarding the protection of soils under National Planning Framework 4 (NPF4). The reporting should be updated to include references to relevant planning guidance/soil specific policy, review of the carbon and peatland map, and further details regarding construction and decommissioning and the management of previously undisturbed soils. Decommissioning, Restoration and Aftercare - Provides advice on the key considerations relevant to the decommissioning and restoration phase of the development as follows ▪ 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 above ground infrastructure extending to substations, PV panels and mountings, inverters/ inverter containers, fencing, lighting masts, internal tracks, equipment and hard standings ▪ Cable removal including around heritage features ▪ 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
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▪ 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 It is indicated that these matters can be suitably addressed via condition. 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. BT – No objections. Scottish Water – No objections. Transport Scotland – No objections subject to conditions relating to the proposed route for any abnormal loads and the installation of temporary traffic control measures. Scottish Gas Networks – No objections. Historic Environment Scotland – No comments. Representations The consultation request was published on the Councils weekly list of applications. No representations have been submitted to the Council. The ECU also publicise the consent application, and representations can be submitted directly to them via their website. At the time of writing there are no representations available to view on the ECU website. Policy Context As noted above the Council is a consultee in the consenting process and not the determining authority. To infer the Councils 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 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
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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 Full details relating to the policies of the LDP can be found online. Other relevant policies and 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 Submitted Reports and Assessments In assessing and reporting on a planning application the Council is required to provide details of any report or assessment submitted as set out in Regulation 16, Schedule 2, para 4(c) (i) to (iv) of the Development Management Regulations The following reports have been submitted in support of the application, and can be summarised as follows: Flood Risk Assessment – The report notes that the application site is not within an area at risk of flooding from surface water, fluvial or coastal sources. The development is not predicted to increase surface water run off to the surrounding catchment. Site topography will not be materially altered, and SUDS features such as permeable access roads will be implemented. Design and Access Statement and Planning Statement – This statement advises that BESS developments will play an important role in reducing carbon emissions and increasing electricity consumption from renewable resources. Batteries provide stability and foundation to renewable led electricity production which is fluctuating. The site is considered to be free of environmental constraints that would preclude development, and appropriate mitigation can be provided where neccesary. Noise Assessment - An assessment has been undertaken using assumed noise emissions of the proposed plant as a final specification of the plant has not been provided. The assessment demonstrates that there are no exceedance of the environmental sound criteria during daytime and evening, and internal noise levels at night time. Assuming the development includes plant with noise emissions not more than those assumed within the assessment, then the impact of sound from the proposal is likely to be low. Landscape and Visual Assessment – The assessment acknowledges that the baseline landscape character would be altered as a result of the development, however, during the residual phase and with established landscape mitigation the effects on the landscape
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receptors would be reduced. The site is well contained and effects on the identified landscape character areas would be limited. The development provides an opportunity to enhance existing woodland and contribute to tree cover. Views of the site predominantly have a low or low to medium value, having limited local value, and already contain visual detractors. The set back of the development would soften views, and once mitigation has established views of the development would be very limited. The development is unlikely to incur any significant cumulative landscape and visual effects due to intervening landform. Preliminary Ecological Appraisal – This appraisal concludes that the development is unlikely to have a detrimental impact on Gleniffer Braes Country Park. The improved grassland within the site is of low ecological value. A root protection zone is required along the north west boundary. Recommendations are made with regard to protected species and biodiversity enhancements. Transport Statement – It is noted that a simple priority T junction will replace the existing field access. Trip generation associated with the operational phase is limited to between 10 and 20 vehicle trips per annum. It is estimated there will be 1,536 two-way vehicle trips associated with the construction phase. Parking for workers will be accommodated on site, and a suitable construction traffic route has been identified. The statements notes that any damage to the local road network can be rectified, while the development is not anticipated to have a severe impact on the operation of the local road network. Statement of Community Involvement and Pre-Application Consultation Report – This reports advises that the applicants have undertaken two community events which were held in Neilston on the 2nd and 23rd August 2023. This was supplemented by a website. The events were advertised in the press, with direct notification issued to neighbouring properties, community councils, local councillors, MP's, and MSP's. Issues of most prevalence were noise, light pollution, potential fire risk, harm to local scenery, flooding/drainage and health concerns. It is noted that while there are no statutory pre- application consultation procedures for section 36 applications, the ECU Good Practice for Applications Guidance (July 2022) states that applicants are expected to hold at least two public events prior to submitting an application. Archaeological Walkover Survey and Historic Environment Assessment – This report notes that there are no sites of interest visible at the site or within 500m of the study area. There are two sites of interest 1km to the north of the study area. There may be buried archaeological deposits within the area, and archaeological trial trenching may be required. West of Scotland Archaeology Service would provide advice on this. 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 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
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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. To inform the Councils consultation response to the ECU, the development plan represents the appropriate document against which to base the Councils assessment of the application. The development plan comprises of the National Planning Framework 4 (NPF4) and the adopted Renfrewshire Local Development Plan 2022 (LDP). 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. 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. IFL have advised that the site is not located on prime quality agricultural land or peatland. In response to the feedback from IFL the applicant has further advised that the Carbon and Peatland Map (2016) established the soil as Class 0 mineral soil which is not a carbon-rich type soil. Details relating to the management strategy for soil on the site, cut and fill operations, retention and re-use of site won material, and the reinstatement of the site in terms of decommissioning can be addressed via condition. 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 management of construction traffic at the site access and associated routing of construction vehicles, provision of sight lines, and undertaking a road safety audit. Conditions relating to these matters will be recommended to the ECU. It is noted that conditions are also requested with respect to reserving a 7m wide strip along the frontage of the site, agreeing measures to differentiate between the site access and the Hartfield Road junction to prevent wrong turning, and measures to reduce speeds locally and ensure site traffic doesn’t need to cross into oncoming traffic when exiting left. It is considered that these matters can be suitably addressed as part of the assessment associated with the above conditions, and separate conditions related to these matters are not required.
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There is no anticipated effect on public water supply or water courses from pollution risk. A condition is recommended with respect to the sustainable drainage of surface water. The development does not impinge upon any existing active travel routes. Regarding visual impact and landscape character, IFL advise that the landscape and visual assessment undertaken by the applicant is adequate in scope and reasonable in its findings. IFL advise that while some of the effects could be classified as slightly higher, this would not change the overall conclusions which are accepted. It is noted that the existing landscape character is heavily influenced by existing electricity infrastructure. This includes the well established Neilston sub station and the network of pylons, and also the recently approved greener grid park (ref: 21/0034/PP) and grid stability facility (ref: 20/0793/PP). The development site sits slightly remote from these existing developments, namely approx. 600m from the substation. However, the development includes mitigation in the form of the landscaped buffers which will screen the development over time. The planting mix can be controlled to ensure adequate coverage and density to ensure mitigation in winter months when leaves are not present. In the short term and prior to the landscaping maturing aspects such as boundary treatments and colour of the component infrastructure can be controlled again to ensure visual impact is mitigated. It is considered that the development will not have a significant impact on local landscape character. With respect to cumulative visual impact, IFL note that the development would be adding to an extensive energy landscape. The additional effects of the development would be relatively minor against this baseline and 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. As the development footprint is set back from the site boundaries it is anticipated that all existing boundary treatments will be retained. The submission indicates that a 2.4m high wire mesh fence will enclose the site. Further details regarding the retention of existing boundary treatments and the colour and final design of proposed boundary treatments can be submitted via condition. The batteries and associated infrastructure are grouped together in the centre of the site, with landscaped buffers provided on all sides. I am satisfied that the grouping and positioning of the batteries and associated infrastructure is acceptable. Provision of the landscaped buffer is critical in ensuring the site can be suitably screened. This comprises of buffer zones along the south west and south east boundaries which will be planted out by the developer, and a zone along the north east and north west boundaries which has already been planted out in association with the neighbouring grid stability application. The buffer zones will ensure that over time the development is screened on all sides by planting. A detailed specification of the species and maturity of the planting to be undertaken within the landscaped buffer zones can be submitted via condition. IFL have advised that planting should be undertaken at 1.5m to 2m centres as opposed to the 5m centres set out in the supporting information to ensure that an appropriate density of planting is undertaken to screen the site effectively and in line with the year 15 visualisations provided by the applicant.
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The development will require a cable connection to the Neilston substation. The applicant has submitted a Preliminary Ecological Assessment (PEA) which concludes that the site currently is of low ecological and biodiversity value. The site primarily comprises of improved grassland habitat in this regard. While IFL ultimately agree with the conclusions set out within the PEA, they have advised that the report is light and poorly structured in the way that it reaches its conclusions. In response to the comments from IFL the applicants have provided an updated version of the PEA which contains further discussion around the baseline conditions, field survey work and overall recommendations. It is recommended that a landscape plan and biodiversity enhancement plan is produced and agreed with the local planning authority prior to the commencement of works. There is considered to be an opportunity to enhance the habitat and biodiversity value of the site. The site in its current condition primarily comprises of a single habitat type. The development provides an opportunity to create a woodland habitat within the landscape buffers, and also to improve the species diversity of the grassland in and around the batteries and the component infrastructure. The PEA also recommends the creation of hedgerows and the installation of bat boxes, bug hotels and log and stone piles. The enhancement of the site can be managed through an appropriately worded planning condition relating to the submission of a landscape scheme and biodiversity enhancement plan however it should be noted at this stage that the scheme should cover the site as a whole and not just the landscape buffers identified on the site layout. With regard to designated sites and protected species, the PEA concludes that the development is unlikely to have a detrimental impact on the closest designated receptor (Gleniffer Braes Country Park and the Bardrain Glen, Sergeantlaw Moss and Gleniffer Braes West Site of Importance for Nature Conservation (SINC)) given the separation distance. As noted above the PEA has been updated to include additional analysis of protected species, and recommendations are made with respect to safeguarding invertebrates, amphibians and reptiles, birds, badgers, otters, and bats. A condition can be applied to ensure the recommendations within the PEA are implemented on 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. It is noted that a large proportion of the land on the north west side of Gleniffer Road that is in proximity of the substation is designated within the SINC and the Country Park boundary. Parcels of land outweigh these boundaries are restricted by topography and ground conditions, and other consented development (namely the grid stability facility to the north). The development site is outwith these designated areas, is of lower ecological value, and is close enough to the substation to form a connection. It has therefore been proposed as a suitable site in this regard.
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The development is for essential infrastructure in an area already characterised by electricity infrastructure. The inclusion of substantial landscape buffers on all sides of the site will screen the development over time. The woodland within these buffers will complement the newer planting to the north and west of the site and the established High Bardrain woodland further to the north. 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 the applicant is seeking a 40 year time period for the consent 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 recommendations from the West of Scotland Archaeology Society regarding the requirement for an archaeological watching brief are noted. This can be managed via an appropriately worded planning condition. Potential impact on the water environment can be mitigated through the incorporation of a strategy to manage surface water and pollution control. A condition is recommended with respect to the sustainable drainage of surface water. 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. Visual impact can be mitigated by landscape planting, boundary treatments and the appearance of the component infrastructure as noted above. It is considered that the amenity of neighbouring residential receptors will not be detrimentally impacted in this regard. Matters relating to visual amenity and noise have been discussed above. There are no implications with regard to air quality, glare or shadow flicker. 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. Glasgow Airport Safeguarding and NATS have offered no objections to the development with regard to the safe and efficient use of Glasgow Airport.
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The site is not within a potential heat network opportunity area. 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. The advice from IFL is noted with regard to the key considerations associated with the decommissioning and restoration of the development which are listed in the consultations section of the report. These considerations will be built into the recommended conditions. The development will contribute to renewable energy generation and carbon emission reduction targets by providing 150MW 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 employment in the construction phase. ▪ Direct employment through operational and decommissioning phases. ▪ Job creation in the supply chain and related services. ▪ Stable energy prices leading to reduced energy costs. ▪ Increased energy security and stability. These are likely to constitute the maximum socio-economic benefits associated with a BESS development. 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 (including those recently planted to the north east and north west) 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.
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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. New woodland planting will be incorporated into the landscape buffer areas. 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. An archaeological watching brief will be required to ensure the potential for non-designated buried archaeological remains is investigated. 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 depth of additional landscape planting that will form part of the scheme will over time improve the quality and environment of the area. 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 boundary treatments, and the positioning and 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. It is noted that the applicant has suggested a condition in relation to the micro siting of the component infrastructure. The condition would allow the developer to adjust the position of the component infrastructure by up to 25m (however not outwith the red line) from the position as shown on the submitted layout drawing without requiring a further written permission from the Council. This is to allow flexibility in procurement and design. The Council would have no objection to the imposition of this condition subject to confirmation within the wording of the condition that the infrastructure could not be located within the landscape buffers. Recommended wording for this condition is set out in the list of recommended conditions below. Section 75 Obligations 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 to secure decommissioning and restoration of the site is required, and the ECU may wish to consider whether a S75 is the mechanism required to secure the agreement. Conclusion
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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 compliant with the development plan subject to planning conditions and a legal agreement to secure decommissioning. 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 subject to the suggested planning conditions listed below and to the conclusion of a legal agreement to secure appropriate funding for the decommissioning of the development and the restoration of the site. Recommendation No objection. Reason(s) for Recommendation 1. The proposed development is compliant with the development plan subject to planning conditions and a 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. The output capacity of the BESS hereby approved shall not exceed 150MW. Reason: To define the consent in order to retain effective planning control. 4. Prior to the commencement of the development hereby approved, an outline decommissioning, site restoration and aftercare strategy shall be submitted to and 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.
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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 above ground infrastructure extending to Substations, PV panels and mountings, inverters/ inverter containers, fencing, lighting masts, internal tracks, equipment and hard standings ▪ Cable removal including around heritage features ▪ 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 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 the Development hereby approved, 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
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completion of all decommissioning, site restoration and aftercare obligations as required by conditions 1 and 2 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. Reason: In the interests of amenity and in order to retain effective planning control. 7. That no development shall take place within the development site until the developer has secured the implementation of a programme of archaeological works in accordance with a written scheme of investigation which has been submitted by the applicant, agreed by the West of Scotland Archaeology Service, and approved by the Planning Authority. Thereafter the developer shall ensure that the programme of archaeological works is fully implemented and that all recording and recovery of archaeological resources within the development site is undertaken to the satisfaction of the Planning Authority in agreement with the West of Scotland Archaeology Service. Reason: To ensure suitable investigations are undertaken in the interests of safeguarding archaeological heritage. 8. That prior to the commencement of construction works on site, the developer shall submit for the written approval of the Planning Authority a specification detailing the pre and post construction road condition survey to be undertaken on the local road network
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identified as part of the construction traffic route set out in figure 1 of the CAP (Construction and Access Plan). The specification shall detail the survey scope and methodology, the timings of the survey, provision for selection of an alternative construction traffic route and notification to the Council of an alternative construction traffic route, provision for survey of the alternative construction traffic route, the methodology for identifying any extraordinary damage to the road (damage to the construction traffic route attributable to construction vehicles serving the development between the pre and post construction condition surveys but excluding fair wear and tear attributable to general vehicle use of the route over the same period) and the means by which any extraordinary damage will be repaired including timescales for completion of the works. The pre and post construction road condition survey shall thereafter be undertaken in accordance with the approved specification, and all extraordinary damage repaired to the satisfaction of the Planning Authority. Reason: To ensure any damage to the local road network arising from the construction of the development is repaired. 9. That prior to the commencement of development on site, full details of all landscaping works shall be submitted as part of a landscape strategy for the written approval of the Planning Authority. The landscape strategy shall include (but not be limited to) provisions in respect of: ▪ all existing trees, hedgerows, and boundary treatments both within and on the edge of the site to be retained including the management of these features and protection measures to be implemented during the construction phase (particularly in relation to a protection zone for all new and existing planting to the north east and north west of the site), ▪ confirmation of any hedgerows or trees that need to be removed including any to form the visibility splays associated with the access sightlines, ▪ all proposed trees, shrubs, hedgerows, areas of grass/wildflower seeding, turfing including size, species, spacing and location noting that all planting shall be a maximum of 2m centres. ▪ all areas of hard standing including location and materials (including the initial 5m of any access track taken from the public road which shall be finished in a bituminous material), ▪ all areas of surface water including ponds, and measures for the sustainable management and drainage of surface water where applicable, ▪ the implementation of all biodiversity and habitat enhancements including (but not limited to) those set out within sections 6.25 and 6.26 of the Preliminary Ecological Appraisal by R & D Ecology Ltd dated 28.04.2024 to ensure biodiversity net gain is achieved, ▪ a timetable for the implementation of the landscape strategy,
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▪ a strategy for the future management and maintenance of all landscaped areas including provision for replacement of trees, shrubs, hedgerows and areas of grass/wildflower seeding and turfing if they were to become diseased, die, become seriously damaged or are removed within 5 years of being planted. The approved landscape strategy shall thereafter be implemented on site in accordance with the approved timetable and shall be managed and maintained thereafter for the duration that the solar park is operational. Reason: To ensure a robust landscaping strategy is implemented in the interests of visual amenity, landscape character and biodiversity. 10. That prior to the commencement of development on site, the developer shall submit for the written approval of the Planning Authority a detailed drainage strategy for the site. The strategy shall set out the SUDS measures to be implemented at the site to ensure that surface water is managed sustainably and shall include a maintenance plan for all SUDS features. The drainage strategy as approved in writing by the Planning Authority shall thereafter be implemented on site and maintained thereafter for the life of the development. Reason: To ensure effective drainage infrastructure is installed on site and maintained appropriately in the interests of effective surface water management. 11. That prior to the commencement of development on site, the developer shall submit for the written approval of the Planning Authority a detailed lighting strategy for the site. The lighting strategy shall be developed in accordance with the Bat Conservation Trust’s Guidance Note 08/23 Bats and Artificial Lighting at Night. Only the approved lighting strategy shall thereafter be implemented on the site. Reason: To ensure a sympathetic lighting strategy is developed in the interests of natural heritage and visual amenity. 12. That prior to the commencement of development on site, 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 and surface finish of the access at Gleniffer Road including geometry for the construction and post construction phase of the development. ▪ 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. ▪ A timetable for the construction phase including confirmation of site operating times on each day of the week. The details set out within the approved CTMP shall thereafter be implemented on site during the construction phase.
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Reason: To ensure traffic impacts are mitigated during the construction phase, and that the construction phase is undertaken safely. 13. That prior to the commencement of cabling works between the battery energy storage system hereby approved and any location or premises to which energy from the battery energy storage system will be transferred, an additional Construction Traffic Management Plan (CTMP) will be submitted for the written approval of the Planning Authority. The additional CTMP will specify the location of the proposed new cable connection, all enabling works required to install the cable including those within and out with the limits of the road and verge, works to any existing boundary fencing and walls and how these boundaries will be reinstated, and loss of any trees, hedgerows or vegetation and how this will be compensated for, and any necessary traffic management measures required to install the cable connection. The cable connection shall thereafter be installed in accordance with the measures set out within the approved CTMP. Reason: To ensure traffic impacts are mitigated during the installation of the cable connection, and that the cable connection phase is undertaken safely and the environment is protected 14. That prior to the commencement of any works on site, 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: o Project Title Page – Defines the project and applicant details o Distribution List – Includes external recipients chiefly LPA and internal distribution such as contractors; to ensure familiarity with the consented requirements o Introduction – Project overview, site description, scope of proposed works, programme of works, details of any previous environmental assessments o Roles and Responsibilities – Organisational Chart of project personnel and key contacts plus training and competencies and communication procedures o Environmental Management Policy Statement – To include any accreditations or EM Systems followed o Regulations and Requirements – Legislation, Regulations and Technical Guidance applicable to the nature and scope of the development o Identification of Environmental Assets and Impacts: o Emissions to air – dust, noise, vibration, traffic/ vehicle movements on site and to/ from site o Land and Water (extends to surface and ground water) – discharges from construction activities, i.e. pollution, substance contamination, damage, waste management o Archaeology and heritage features
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o Ecological features including habitats and species o 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 o Inclusion of an Emergency/ Incident Response Plan o Monitoring and Auditing – Procedures for audits (internal and external), monitoring and inspections, environmental performance monitoring e.g. KPIs, monitoring/ inspection reporting o 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. 15. 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. 16. That prior to the commencement of development on site, the developer shall submit a specification for the written approval of the Planning Authority which details the final design and finishing colour of all above ground elements of the development including (but not limited to) buildings, containers, plant, batteries and other component infrastructure, and all boundary fencing and gates to be developed at the site. The development shall thereafter be undertaken in accordance with the details within the approved specification. Reason: To ensure the colour of all built elements within the site is reflective of the landscape setting in the interests of visual amenity. 17. That all recommendations set out in section 6 of the Preliminary Ecological Appraisal by R & D Ecology Ltd dated 28.04.2024 shall be implemented on site during the construction phase. Reason: In the interests of safeguarding protected species. 18. That prior to the commencement of development on site, 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 and earth moving. Only the approved details shall thereafter be implemented on site.
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Reason: In the interests of visual amenity. 19. That within three months of the date of consent a Road Safety Audit (RSA), shall be submitted to the Planning Authority for written approval. As part of the RSA it shall consider road safety measures to differentiate between the vehicular accesses along Gleniffer Road and that of its junction to Hartfield Road as well as the management of traffic during both the construction phase and operational phase of the development. Thereafter any approved measures that result from the RSA shall be implemented in accordance with a timetable approved in writing by the Planning Authority. Reason: To reduce traffic speeds in the interests of traffic safety. 20. That prior to the commencement of development on site, the developer shall submit a plan for the written approval of the Planning Authority detailing the 9m x 120m x 0.6m sightlines to be provided from the centre of the proposed site access onto Gleniffer Road in both directions. These sight lines will be achieved unless otherwise agreed in writing with the Planning Authority. The works to form the sight lines (including removal of all obstructions in excess of 0.6m above ground level) shall thereafter be undertaken and the sight line formed to the satisfaction of the Planning Authority prior to the commencement of any development on the site unless otherwise agreed in writing with the Planning Authority. Reason: To ensure the site can be accessed safely during the construction and operational phases of the development. 21. All development shall be constructed in the locations shown on the Proposed Site Layout Plan ref. APA-1315-DR-PL-003 Rev 10 titled Proposed Indicative Site Layout except where adjusted by micro siting of no more than 25m from the original position shown on the Proposed Site Layout Plan ref. APA-1315-DR-PL-003 Rev 10 titled Proposed Indicative Site Layout. Notwithstanding the micro siting allowance, the micro siting area shall be limited so that no development shall be located outside the red line site boundary or within the areas demarcated as third party mitigation landscaping land and proposed landscaping land as shown on the Proposed Site Layout Plan ref. APA- 1315-DR-PL-003 Rev 10 titled Proposed Indicative Site Layout. Any changes to development locations outside of the micro siting limit are to be submitted to and approved in writing by the Planning Authority. Reason: To retain effective control over the development. The following advisory note should be attached to the deemed planning permission 1. Glasgow Airport Safeguarding has observed that given the nature of the proposed development it is possible that a crane may be required during its construction. In the circumstances, your attention is drawn to the requirement within the British Standard Code of Practice for the safe use of cranes, for crane operators to consult the aerodrome before erecting a crane in close proximity to an aerodrome. Advice Note 4 'Cranes and Other Construction Issues' (available at http://www.aoa.org.uk/policy- safeguarding.htm). Schedule of Plans Reviewed Drawing Number Revision Drawing/Document Title
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APA-1315-DR-PL-003 10 Proposed Indicative Site Layout APA-1315-DR-PL-001 2 Site Location Plan APA-1315-DR-PL-100 132kV Transformer APA-1315-DR-PL-101 Inverter APA-1315-DR-PL-102 Auxiliary Transformer APA-1315-DR-PL-103 1 Access Gate APA-1315-DR-PL-104 B DNO Building APA-1315-DR-PL-105 CCTV & Lighting APA-1315-DR-PL-106 Client & Control Room APA-1315-DR-PL-107 Transformer APA-1315-DR-PL-108 B Customer Switchroom APA-1315-DR-PL-109 Mesh Fence APA-1315-DR-PL-110 Battery Container Planning and Design and Access Statement by AAH consultants dated December 2023 RDECO00089/230/01 C Preliminary Ecological Appraisal by R & D Ecology Flood Risk Assessment by AAH consultants dated December 2023 15025A-20-R02-01-F Noise Assessment by Noise Consultants Ltd dated December 2023 Landscape and Visual Assessment by AAH consultants dated December 2023 Statement of Community Involvement and Pre-Application Consultation Report by AAH consultants dated December 2023 371 V2 Archaeological Walkover Survey and Historic Environment Assessment RHC-23-170-TS Foxbar, Renfrewshire Transport Statement, by Roberts Highway Consultants dated December 2023 For further information please contact James Weir, Development Standards Team, Email: james.weir@renfrewshire.gov.uk.