Item 8 - S36 Consultation DC25.019.S36
West Dunbartonshire Council · 14 January 2026
Back to Planning Committee — 14 January 2026 and its agenda
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WEST DUNBARTONSHIRE COUNCIL Report by Planning, Building Standards and Environmental Health Manager Planning Committee: 14th January 2026 _____________________________________________________________ DC25/019/S36: Battery energy storage facility consisting of compound of batteries and associated electrical equipment, stores, access track, buildings, fencing, pond, bunds and new planting at Braidfield Road, Hardgate, Clydebank by Braidfield Battery Storage Limited 1. REASON FOR REPORT 1.1 To agree the Council’s response to a consultation received from the Scottish Government Energy Consents Unit on behalf of the Scottish Ministers regarding a proposed battery energy storage system with a generating capacity of up to 100 megawatts. Given the nature of the proposal, this requires to be agreed by Planning Committee. 2. RECOMMENDATION 2.1 It is recommended that the Committee agrees the position set out in Section 10 of this report and submit this report to the Scottish Ministers as presenting the Council’s full, formal response to the consultation advising of the Council’s objection based on the application submission as it stands. 3. BACKGROUND 3.1 The Scottish Ministers have received an application under Section 36 of the Electricity Act 1989 for the construction and operation of a battery energy storage system (BESS) with a generating capacity of up to 100 megawatts (MW) on a site at Braidfield Farm, Clydebank. The application site is located within the West Dunbartonshire local authority area however, the assessment of the submitted application is undertaken via the Scottish Government Energy Consents Unit for the Scottish Ministers. In Scotland, any proposal to construct and operate an onshore electricity generating station with a capacity of over 50 megawatts (as is the case with this proposal) requires the consent of Scottish Ministers under Section 36 of the Electricity Act. Such applications are processed on behalf of the Scottish Ministers by the Scottish Government Energy Consents Unit. Due to the Scottish Ministers being the decision makers, representations from members of the public and other agencies are made directly to the Energy Consents Unit. The application is referred to under the project name of the Braidfield BESS. The location of the site is shown in Appendix 1. 3.2 A date of 19th January 2026 has been agreed with the Scottish Government Energy Consents Unit for the submission of the Council’s consultation response. The application documents are available to view via the Energy Consents Unit website at www.energyconsents.scot and by searching the project name ‘Braidfield’. 3.3 The Council is a formal consultee in this process. In procedural terms, the Council as Planning Authority requires to provide a response to the Scottish Ministers. In this regard, the Council in response to the consultation can: ITEM 8
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(i) Offer no objection to the Section 36 application as submitted; or (ii) Offer no objections subject to the imposition of appropriate conditions and/or legal obligations it considers necessary to make the development acceptable; or (iii) Object to the application, stating the grounds on which objection is made. 3.4 Should the Scottish Ministers be disposed to grant a Section 36 consent for the proposed development, the Town and Country Planning (Scotland) Act allows the Scottish Ministers to direct that planning permission for that development and any ancillary development shall be deemed to be granted. 4. DEVELOPMENT DETAILS 4.1 The application site is situated to the to the east of Braidfield Farm, Clydebank and extends to approximately 2.13 hectares (excluding access track from Braidfield Farm). Whilst in close proximity to the urban area, the site itself lies within open countryside comprising part of the Green Belt as defined by both the adopted West Dunbartonshire Local Plan and proposed Local Development Plan 2. To the west, the site is defined by an existing rough track which forms part of Core Path 150. To the north, south and east, the site adjoins existing grazing land. A private section of Braidfield Road leading from the existing steading to the development is also included within the application site. Excluding the access road, the site boundaries are defined by a combination of existing hedgerows and post and wire fencing. Currently the land is utilised as a paddock for grazing horses. The main part of the site (excluding the access road) is positioned around 150 metres from the farmhouse at Braidfield Farm and around 250 metres from the next closest residential properties at Braidfield Road, Braidfield Grove and Strathdee Avenue. The Antonine Wall is located 130 metres to the north of the site and the site itself lies wholly within the Antonine Wall buffer zone, which is identified along much of the Wall, protecting its setting. 4.2 The proposal is for a 100MW Battery Energy Storage System facility and associated infrastructure. Whilst supporting documents reference the eventual decommissioning of the site, the expected operational period is not clear. The proposed development would comprise 108 battery units and 135 power convertors. The battery units will take the form of metal units not dissimilar in appearance to a shipping container and would be 8.5 metres by 1.7 metres by 1.8 metres high. They would be designed with vents for cooling. Power convertors would be sited by each group of batteries and take the form of a series of metal cabinets. Transformers would also be positioned adjacent to the power convertors and take the form of large items of electrical equipment to a height of around 3 metres. A total of 27 transformers is proposed. It is further proposed to erect a control room to house a variety of equipment. This would be designed with a flat roof and extend to around 13 metres by 6 metres by 4 metres high. The transmission area would feature a similar building together with an electrical transformer, electrical disconnector and associated equipment with a height of up to 7 metres. Two storage containers are also proposed to house spares and equipment. These will be 8.5 metres by 1.7 metres by 1.8 metres high. 4.3 The site will be enclosed by a two-metre-high weldmesh fence with barbed top and it is indicated that this would be situated behind a hedgerow. Security cameras to a height of 4 metres will be provided. No permanently illuminated nighttime lighting is proposed with external lighting indicated to be for use during maintenance in the hours of darkness only. Infrared security lighting will be provided but this is not visible to the eye. The site will be levelled, and landscape bunds are proposed wrapping around the southern, western and northern boundaries of the compound. These are indicated to be between 1 and 3 metres in height. Drainage will be addressed via a sustainable
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drainage scheme (SuDS) employing a gravity-based outflow to a nearby existing drainage ditch which subsequently drains to Cleddans Burn. The existing farm track from Braidfield Farm is included in the application site and it is indicated this will be refurbished in unbound material. Tracks within the site will be formed in aggregate. Parking and turning will be provided for any maintenance vehicles visiting the site. 4.4 New planting is proposed as part of the development with the applicant indicating that this will create new biodiversity habitat and also form a screening function which will compliment the existing retained hedgerows. It is indicated that this planting will comprise a mix of predominantly native hedgerow and broadleaf species together with areas of wildflower meadow. The applicant indicates that the final landscaping plan would be agreed with the Council prior to construction in the event that consent was granted. 4.5 The applicant sets out that a 50MW capacity facility was originally considered for the site, expecting to connect at the Kilbowie Grid Supply Point on Milton Mains Road, at the voltage of 33kV. However, the Distribution Network Operator could not accommodate this and an alternative 132kV connection was offered at Windyhill Substation around 1.5kms to the northeast of the site, and this dictated a change in site capacity to 100MW. It is indicated that the development would connect to Windyhill Substation via buried cables although the grid connection does not form part of this application. 4.6 The proposal is informed by a range of supporting documentation including a planning statement, design and access statement, landscape report with associated figures and viewpoints, drainage report, ecology report, biodiversity report, heritage report and noise assessment. 5. CONSULTATIONS 5.1 The Council is a consultee in the Section 36 application process and therefore consultation by the Council is limited to Council Services. However, a summary of the wider consultation responses received by the Scottish Government Energy Consents Unit is also included below, as these are also relevant to the assessment of the proposal to inform the response by the Council. West Dunbartonshire Council consultation replies: West Dunbartonshire Council (Roads Service) (roads, traffic and flooding matters) 5.2 No objections on roads or flooding grounds. The requirement for notification of the commencement of works, abnormal load movements and pre and post development inspections of the public road network are identified by Roads, together with the requirement to ensure road sweeping if required, that surface water is not discharged to the public road and that the access to the site is hard surfaced for the first 12 metres and that any gates are set back from the public road by at least 12 metres. West Dunbartonshire Council (Environmental Health Service) 5.3 No objections. A range of matters are recommended to be addressed by condition including a variety of matters relating to the construction phase inclusive of hours of works and also in respect of possible site contamination and ground conditions together with conditions relating to noise matters during the operational phase of the development.
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Biodiversity Officer 5.4 No objections. The applicant’s submissions, methodology and approach undertaken is accepted and it is specifically noted that additional caution has been taken in respect of the camera monitoring. A cautionary position in respect of watervole is recommended. The Preliminary Ecological Appraisal dating from 2022 is noted as being longer than is usually accepted for such to remain accurate in its findings and it is recommended that the document is updated. The proposed biodiversity enhancements are accepted and welcomed. Scottish Government Energy Consent Unit consultation replies: West of Scotland Archaeology Service 5.5 The proposal would be located around 130m to the south of the line of the Antonine Wall itself but would be wholly located within the buffer area defined in relation to the monument in the World Heritage Site designation. It is agreed that the development would be unlikely to have direct impacts on the World Heritage Site, at least in terms of archaeological material present along the line of the wall itself, though there would be a clear potential for sub-surface archaeological material to survive in the area adjacent to the frontier. 5.6 The proposal would introduce a new modern element into the setting of the monument. There are concerns as to whether the visualisations submitted provide an adequate picture of the degree to which the proposal would be visible from the World Heritage Site. It is advised that the applicant should be asked to provide at least one additional visualisation taken from the line of the Antonine Wall in the area immediately to the north of the of the site. 5.7 In the event that the Energy Consents Unit intends to grant permission, a condition should be attached to secure completion of the programme of mitigation works set out in the Heritage Assessment Historic Environment Scotland 5.8 Initially objected noting that the application did not include an appropriate heritage-led analysis of the setting and potential impacts on the setting of the Antonine Wall World Heritage Site and scheduled monument Antonine Wall and fortlet, 950m W to 335m ENE of Cleddens (SM6836), and that there was insufficient information to adequately assess the impact of the proposals. 5.9 Whilst the applicant has not provided an updated Heritage Impact Assessment following the submission of revised planting proposals, a site visit, updated plans and submitted visualisations have allowed HES to carry out their own assessment of the impacts of the proposed development on the setting of the Antonine Wall WHS and scheduled monument. 5.10 The proposed development is unlikely to appear in views as you travel along this section of the WHS and scheduled monument, and therefore the revised proposals would not interfere with how the WHS is understood as a linear monument and can be appreciated in the landscape. It is concluded that key views and relationships would be retained. 5.11 It is confirmed that the proposal would not have a significant adverse impact the integrity of setting of the scheduled monument (SM6836) and Antonine Wall WHS to such a level that HES would object. Conditions are recommended in relating to the planting proposals.
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NatureScot 5.12 No negative impacts on national or international protected areas are anticipated from the proposed development. With the proposed mitigation and enhancement measures recommended in the Preliminary Ecological Assessment and biodiversity report in place, the proposal will not give rise to adverse impacts on any natural heritage interests of national or international importance. Pre-construction surveys may be required to ascertain the presence of protected species. Further general advice is provided in the response. East Dunbartonshire Council 5.13 No objection. Glasgow City Council 5.14 No objection. Scottish Forestry 5.15 The site map shows that the development site is primarily an area of pasture surrounded by hedging with a few trees contained within. The proposal does not appear to include any permanent removal of trees. New woodland planting as proposed is welcomed. It is expected that all trees and woodland on the site be protected. If trees are to be permanently removed, conditions relating to compensatory planting are recommended. Coal Authority 5.16 There are no records of the presence of any coal mining features within the site which may pose a risk to surface stability. No objections Ministry of Defence (MOD) 5.17 No objections BT 5.18 This proposal should not cause interference to BT’s current and presently planned radio network. No objections. Scottish Environmental Protection Agency (SEPA) 5.19 No objections. Scottish Water 5.20 No objections Office for Nuclear Regulation 5.21 No comments to make on the proposal HSE 5.22 The development is not located in any consultation zones and does not comprise hazardous substances. No further comments on the proposal. NATS 5.23 No objections. SGN 5.24 No objection.
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Transport Scotland 5.25 Based on the review undertaken, there is no objection to the development in terms of potential environmental impacts on the trunk road network. Conditions are required in respect of a variety of matters including matters relating to abnormal roads on the trunk road network and the requirement for a Construction Traffic Management Plan. Glasgow Airport 5.26 No objections subject to conditions relating to details of soft and water landscaping and a bird hazard management plan. Parkhall Community Council 5.27 The Community Council object to the proposal for a variety of reasons. These include fire risk, concerns regarding ground stability from historic mining, road access and use of residential streets to access the site, and that the route of the connector to the Windyhill Substation not having been finalised. Linvale and Drumry Community Council 5.28 The Community Council object to the proposal for a variety of reasons. These include the facility not being required and BESS applications being oversubscribed, safety concerns regarding hydrogen fluoride, fire safety concerns, noise and pollution to local residents, traffic, visual impact, impacts upon wildlife and local biodiversity. 6. REPRESENTATIONS 6.1 At the time of writing, the Scottish Government’s Energy Consents Unit have advised that 2581 representations have been received in connection with the proposal. 25 of these are in support and 256 are in objection. However, the Energy Consents Unit further advises that a number of these submissions were late and it will be up to the Scottish Ministers as to whether any late submissions are taken into account. Copies of these representations are provided on the Energy Consents Unit website case file however the points raised can be summarised as follows: In objection The proposal does not accord with the development plan There are no known grid stability issues that the proposal requires to address The development will adversely impact upon the Antonine Wall, the setting of the roman frontier and associated archaeology Loss of view would occur Impact upon good quality agricultural land Lithium battery storage systems are hazardous and present a fire risk with associated pollution. Safety hazards have not been fully considered There is no suitable access to the site for heavy vehicles The development of the site will cause two years of local disruption, Local businesses will see a drop in trade resulting from disruption associated with the development The development may prevent local inward investment No local employment will create during the operational period No community benefit is proposed The development is speculative The grid connection works will cause considerable local disruption The proposal is unacceptably close to local schools and residents Community health, safety and wellbeing will be adversely impacted upon The use of Core Paths will be lost during construction
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Supporting documents are inaccurate and misleading Press advertisements were not in prominent locations in the local press Neighbour notification was not undertaken The content of the consultations responses from SEPA and HSE are not acceptable Concerns regarding the integrity of the applicant In Support The development would be good for the area cheaper electricity may result Environmental benefits would occur The development would benefit the local community and support children’s futures The aim for sustainable places to be created will be supported The development will lower carbon impact and reduce the use of fossil fuels local authorities require to support renewable energy Jobs will be provided by the development The banking of renewable electricity generation energy should be supported 6.2 Whilst many of the points raised both in objection and in support are considered as part of the Council’s wider assessment of the proposal as set out in Section 8 below, it is for the Scottish Ministers as the determining authority to consider the representations submitted to them. 7. ASSESSMENT AGAINST THE DEVELOPMENT PLAN National Planning Policy 4 7.1 NPF4 aims to create places in line with six overarching spatial principles, including the Just Transition and Rebalanced Development. The Just Transition directs development towards achieving the transition to net zero in a way that is inclusive and fair. Rebalanced Developments directs development to areas of past decline, which would include West Dunbartonshire, given the de-industrialisation that has taken place in the area. While these are high level principles, they are cross cutting and NPF4 contains a clear steer that outcomes of Policy 1, Policy 2, Policy 11 and Policy 25 are interlinked. 7.2 Strategic Renewable Electricity Generation and Transmission Infrastructure is a Scotland wide national development (National Development 3), making it a clear priority across Scotland. Regional Spatial Priorities for the Central Region also direct development to “provide net zero energy solutions” and to “build community wealth to overcome disadvantage”. These high level aims and connections between policies should be considered by the decision maker. 7.3 Policy 1 gives significant weight to the climate and nature crisis, with an intended Policy outcome of being zero carbon and nature positive. Renewables, including onshore wind and battery storage, are considered an important part of Scotland’s approach to meeting its carbon emission reduction targets. Policy 2 requires development to minimise the lifecycle greenhouse gas emissions of development as far as possible. A development that relates to renewable energy development draws strong support from these policies. 7.4 Policy 3 requires development to contribute to biodiversity enhancement, including the restoration of degraded habitat and improving connections between them. As a national development part b) of the Policy applies. Part d) of this Policy also applies, requiring the planning and design of development to minimise adverse impacts,
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including cumulative impacts, of the development on biodiversity and the natural environment. The approach to biodiversity enhancement accords with this Policy. 7.5 Policy 4‘s intent is to protect, restore and enhance natural assets making best use of nature-based solutions. Development which impacts upon landscape designations or nature conservation and protected species is not supported if significant effects would occur. It is concluded that the proposal does not conflict with this Policy 7.6 Policy 5 relates to soils and Policy 6 supports proposals that enhance, expand or improve woodland and tree cover. The development is considered acceptable with reference to these policies. 7.7 Policy 7 requires development with potential impacts on historic assets or place to be accompanied by an assessment of that asset or place, including cumulative impacts. With the potential to impact upon the Antonine Wall World Heritage Site part l) of the Policy is of particular relevance as this requires development proposals to protect and preserve the historic asset. There are serious concerns in terms of the impact upon the setting of Wall, and the proposal cannot be held to be supported by this Policy. 7.8 Proposals within a Green Belt are covered in Policy 8. Development proposals within a Green Belt designated within the LDP will only be supported in a limited set of circumstances including for essential infrastructure. The proposal falls into the definition of essential infrastructure. However, it is not considered that the applicant has sufficiently demonstrated that there are no sites outside the Green Belt for this development and this conflicts with the requirements of the Policy. 7.9 Policy 11 relates to energy, and the Policy intent is to encourage, promote and facilitate all forms of renewable energy development onshore and offshore. This includes energy generation, storage, new and replacement transmission and distribution infrastructure and emerging low-carbon and zero emissions technologies including hydrogen and carbon capture utilisation and storage (CCUS). Part a) supports proposals for renewable technologies, including battery storage under section iii. 7.10 Part c) of Policy 11 requires renewable development to maximise economic impact, including local and community socio-economic benefits. Part e) of the Policy requires the project design and mitigation to address a number of issues. In considering the impacts significant weight is placed on the contribution of the proposal to greenhouse gas emission reduction targets. Impacts to be addressed are: i. impacts on communities and individual dwellings, including, residential amenity and visual. ii. significant landscape and visual impacts. iii. public access, including impact on long distance walking and cycling routes and scenic routes. iv. impacts on aviation and defence interests including seismological recording. v. impacts on telecommunications and broadcasting installations, particularly ensuring that transmission links are not compromised. vi. impacts on road traffic and on adjacent trunk roads, including during construction. vii. impacts on historic environment. viii. effects on hydrology, the water environment and flood risk. ix. biodiversity including impacts on birds. x. impacts on trees, woods and forests. xi. proposals for the decommissioning of developments, including ancillary infrastructure, and site restoration.
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xii. the quality of site restoration plans including the measures in place to safeguard or guarantee availability of finances to effectively implement those plans. xiii. cumulative impacts. It is concluded that the proposal can be justified against the above criteria as fully assessed in Section 8 of this report. 7.11 Policy 12 requires development to reduce, reuse or recycle materials in line with the waste hierarchy. It also supports developments that enable materials and components to be disassembled and reused at the end of their life and Policy 13 supports development where it is demonstrated that transport requirements satisfactorily addressed. No concerns arise in respect of these policies. 7.12 Development proposals will be designed to improve the quality of an area whether in urban or rural locations and regardless of scale as per Policy 14. Development proposals that are poorly designed, detrimental to the amenity of the surrounding area or inconsistent with the six qualities of successful places, will not be supported in accordance with Policy 14. No concerns arise in respect of this Policy. 7.13 Policy 18’s intent is to encourage, promote and facilitate an infrastructure first approach to land use planning, which puts infrastructure considerations at the heart of placemaking. Energy supplies and energy generation are included in the definition of infrastructure and Policy 22 relates to flooding. The development is acceptable with reference to these policies. 7.14 Policy 23 protects people and places from environmental harm, mitigates risks arising from safety hazards. Part e) notes that development proposals that are likely to raise unacceptable noise issues will not be supported. It is considered that no unacceptable noise impacts would occur. 7.15 Alongside part c) of Policy 11, Policy 25 makes community benefit a material consideration in planning decision. Part a) of the Policy sets out that community benefit can include “improving community resilience and reducing inequalities; increasing spending within communities; ensuring the use of local supply chains and services; local job creation; supporting community led proposals, including creation of new local firms and enabling community led ownership of buildings and assets.” The construction and decommissioning of the development present supply chain opportunities for business and could potentially contribute to local economic activity. 7.16 The matters relevant to the assessment against the above policies are addressed in detail in Section 8 below. Based on that assessment, it is concluded that the proposal is not in accordance with NPF4 with specific reference to Policy 8. West Dunbartonshire Local Plan (2010) 7.17 The application site is located in the Green Belt and Policy GB1 states that within the areas of Green Belt there will be a general presumption against development other than certain exemptions. This includes where there is a specific locational requirement and established need for the development and it cannot be accommodated on an alternative site. It has not been fully demonstrated that this development cannot be accommodated on an alternative site out with the Green Belt. 7.18 Policy DC6 relates to renewable energy proposals and states that development will be permitted where it can be established without unacceptable detriment to the landscape, natural and build heritage, sport and recreation interests and local amenity.
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The proposal can be accepted with reference to these matters as further assessed in Section 8 below 7.19 Policy E1 states that the Council will further the conservation of biodiversity. Policy E3A states that the Council will seek to maintain and enhance the environmental resources of the Plan area by protection of habitats, species and natural features which are vulnerable and/or specifically protected, including Local Nature Conservation Sites. It also states that proposals should not have an adverse effect on the integrity or character of Local Nature Conservation Sites and that satisfactory arrangements for habitat creation/site enhancement elsewhere should be made to compensate where development would cause the total or partial loss of a Local Nature Conservation Site. Policy SUS1 states that all development should seek to conserve and enhance environmental resources and ensure environmental impact is minimised. Policy E9 seeks to ensure that development proposals do not adversely impact upon landscape character. The proposal is acceptable with reference to this Policy. 7.20 Policy GD1 seeks to ensure that all new development is of a high quality of design and respects the character and amenity of the area. The proposal can be accepted with reference to this Policy. 7.21 Policy DC3 states that within the Glasgow Airport Safeguarding Zone, development which adversely affects the operational integrity or safety of the airport will not normally be permitted. No concerns arise in this respect. 7.22 Policy BE5 relates to Scheduled Ancient Monuments and other Archaeological sites. The Council will resist any development proposals that would have an adverse impact on or affect the setting of a Scheduled Ancient Monument, or upon other nationally or locally important archaeological sites. Policies BE6A and BE6B, relating to the Antonine Wall and Antonine Wall buffer zone respectively, combine to presume against development which would have an adverse impact upon the Wall. Taking account of the response from WoSAS and HES, it is concluded that significant concerns in respect of the impact upon the Wall and its setting would not arise. 7.23 Policy GN1 seeks to promote, protect and improve the Green Network. It states that development which is detrimental to the green network will be considered contrary to the Plan, and that new development should contribute positively to the protection and improvement of the green network. No concerns arise in respect of this Policy. Policy RSA1 relates to conserving the landscape quality of the Kilpatrick Hills and again, no concerns arise. 7.24 Policies F1 and F2 aim to ensure that new development is not at risk from, and does not increase the risk of flooding, and has suitable SUDS drainage infrastructure. There is a general presumption against development within the flood plain. The up-to-date development plan position in flooding is set out within Policy 22 of NPF4 which therefore has primacy in this instance. 7.25 The matters relevant to the assessment against the above policies are addressed in detail in Section 8. Taking that assessment into account it is concluded that the proposal is contrary to adopted Local Plan with reference to Policy GB1.
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8. ASSESSMENT AGAINST MATERIAL CONSIDERATIONS West Dunbartonshire Local Development Plan (LDP2) Proposed Plan 8.1 On 15 March 2023, the Planning Committee took a decision that the Council would not adopt Local Development Plan 2. The Proposed Local Development Plan 2 (LDP2), incorporating the recommended modifications of the Examination Report received on 22 April 2020, which were accepted by the Planning Committee of 19 August 2020, remains the Council’s most up to date spatial strategy and is therefore afforded significant weight in the assessment and determination of planning applications, subject to compatibility with NPF4. The Scottish Ministers’ Direction relating to the adoption of LDP2, dated 18 December 2020, is also a material consideration, although it does not directly affect the development proposal under consideration. 8.2 Policy GB1 restricts development in the Green Belt to a limited number of circumstances. This includes with infrastructure with a specific locational need. It has not been demonstrated that this development cannot be accommodated on an alternative site. Policy RE1 requires renewable energy developments to be compatible with the surrounding area and for the development to meet all other policy requirements. It cannot be held that the proposal us supported by this Policy given the conflict with Policy GB1. 8.3 Policy ENV1 sets the approach towards development in relation to nature conservation and biodiversity. Policy ENV2 relates to landscape character. Development proposals should be sited and designed to relate to the local landscape character of the area and ensure that the integrity of this landscape character is maintained and, where appropriate, enhanced. Policy ENV4 relates to forestry, trees and woodland. The loss or fragmentation of long-established woodland, high conservation value or areas covered by tree preservation orders will only be supported where any significant adverse effects are clearly outweighed by significant social or economic benefits. The proposal can be considered acceptable with reference to this Policy. Policy KH1 seeks to protect the Kilpatrick Hills Local Landscape Area but as the development is not within this designation, no matters arise in respect of this Policy. 8.4 Policy ENV5 mainly focusses on water courses and water bodies. Policy ENV8 requires minimisation or adequate mitigation of any air light and noise pollution resulting from development. Policies ENV9 and ENV10 address contaminated land and unstable land respectively. The development is acceptable in this regard. 8.5 Policy H4 of the LDP2 relates to residential amenity. The Policy states that the Council will protect, preserve and enhance the residential character and amenity of existing residential areas at all times. In this regard, there will be a general presumption against the establishment of non-residential uses within, or in close proximity to, residential areas which potentially have detrimental effects on local amenity, or which cause unacceptable disturbance to local residents. No concerns arise in this respect. 8.6 Policy CON3 is not supportive of development which disrupts or adversely impacts on any existing or potential core path, right of way, bridle path, or footpath, including off- path access rights, used by the general public for recreational or other purposes. No core paths will be interrupted by the development. Visual impacts to core path users are assessed separately but are considered acceptable. 8.7 Policy BE1 states that unscheduled archaeological sites should be preserved in-situ where possible. Where not possible, provision should be made by the developer to undertake the excavation, recording analysis, publication and archiving of the archaeological remains. This Policy also advises that where a scheduled monument or
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the integrity of its setting would be adversely affected, permission would only be granted in exceptional circumstances. Policy AW1 does not support development that would have an adverse impact upon the Antonine Wall or its setting. It is concluded that significant concerns in respect of the impact upon the Wall and its setting would not arise. 8.8 Policy CP1 requires new development to take a design led approach to creating sustainable places which puts the needs of people first and demonstrate the six qualities of successful places. The development can be accepted with reference to this Policy 8.9 Policy CP2 requires all development to demonstrate that green infrastructure has been integrated into the design approach from the outset. Development that would adversely impact on the operations of Glasgow Airport or would be adversely affected by aircraft noise will not be permitted in accordance with Policy E7. No concerns arise in respect of these policies. 8.10 Policies ENV5 and ENV6 are similar to the water environment and flooding policies of the adopted Local Plan, although in respect of flooding, the up-to-date development plan position is set out within Policy 22 of NPF4 which has primacy. 8.11 The matters relevant to the assessment against the above policies are addressed in detail below. It is concluded that the proposal is not in accordance with proposed Local Development Plan 2 with reference to Policies GB1 and RE1. Renewable Energy Local Development Plan (Proposed Plan) Planning Guidance November 2016 8.12 This guidance is written in the context of proposed Local Development Plan 1 together with Scottish Planning Policy (SPP), both of which no longer form a material consideration in the assessment of planning applications. The document does not address battery storage proposals and Policy 11 of NPF4 has primacy over this guidance. Frontiers of the Roman Empire (Antonine Wall) Planning Guidance 8.13 This guidance sets out the approach and procedure for assessing development affecting the World Heritage Site and also the criteria which will be applied in determining applications for development along the line of, and within the setting and vicinity of the World Heritage Site. The Guidance sets out that the impacts of development may be physical upon the fabric of the monument, they may impact upon the setting of the wall where development will harm the character of the landscape around the world heritage site or be cumulative which adds to the existing negative effects of past or current developments thereby creating further and possibly greater adverse effects. 8.14 As it can be concluded that significant concerns in respect of the impact upon the Wall and its setting would not arise, the proposal is acceptable with reference to this guidance. Principle of Development 8.15 National Planning Framework 4 (NPF4) sets out the long-term vision for the development of Scotland through the National Spatial Strategy. NPF4 aims to meet Scotland’s climate ambition which will require a rapid transformation across all sectors of the economy and society. This proposal constitutes a National Development as it supports renewable electricity generation, repowering, and expansion of the electricity grid under National Development 3: Strategic Renewable Electricity Generation and
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Transmission Infrastructure. NPF4 recognises that additional electricity generation from renewables and electricity transmission capacity of scale is fundamental to achieving a net zero economy. Policy 1 states that there is a need to encourage, promote and facilitate development that addresses the global climate emergency and nature crisis, whilst Policy 2 seeks to encourage, promote and facilitate development that minimises emissions and adapts to the current and future impacts of climate change. The electricity transmitted for storage within the proposed batteries will likely have come from a mixture of renewable and non-renewable sources with the purpose of the batteries to ensure there is always grid stability. As renewable energy becomes more prevalent, grid stability becomes a significant issue due to the intermittent nature of renewable energy generation. 8.16 Policy 11 a) iii of NPF4 specifically supports battery storage energy solutions. NPF4 does not question the nature of the technology or the level of need for it. This general support facilitates the deployment of renewable energy which in turn will assist in decarbonising the electricity network. Whilst it can be considered that the proposal could therefore be held to support the overarching aims of the NPF4 to achieve net zero targets and provide a stable domestic energy supply, the substantial planning policy support is not unconditional, and it must be ensured that such development happens in the right place. There is thus a requirement in assessing any such developments to take into account all relevant considerations and policies. Therefore, it requires to be assessed if there are any potential adverse impacts arising from the proposed development which would be outweighed by any benefits. This assessment can be guided by Policy 11 e) of NPF4, which sets out in detail the matters for the project design and mitigation to address, together with any other relevant development plan policies. 8.17 The site is situated within the Green Belt as defined by the adopted Local Plan and proposed Local Development Plan 2. Policy 8 of NPF4 sets out the types of development that are supported within Green Belt locations. This includes essential infrastructure, and proposals that relate to the distribution and transmission of electricity grid networks fall under this definition. However, Policy 8 is clear that for development proposals in Green Belt locations the purpose of the Green Belt must not be undermined. Policy 8 goes on to require that the reasons why the Green Belt location is essential must be provided together with why the development cannot be provided on a site outwith the Green Belt. Policy GB1 of both the adopted Local Plan and proposed Local Development Plan also provide qualified support for development in the Green Belt where a specific locational requirement is identified. 8.18 The applicant advises that the development requires to be sited where a suitable electricity connection can be made into a substation with sufficient available capacity. It is set out that the site has been chosen because it is located between the Kilbowie and Windyhill substations, has characteristics that make it suitable for development and is a site where the predicted impacts could be considered to be acceptable. In this case, the applicant has advised of an offer of a connection at the Windyhill substation which lies around 1.5km from the site. It is generally accepted that the closer the point of connection is, the more efficient the transmission would be, the cabling costs would likely more viable and there would be a reduced likelihood of physical obstacles preventing a connection being implemented. While this may be accepted from a technical perspective, it remains that it must be assessed whether the applicant’s 2km search area is appropriate, how site selection was approached by the applicant and whether Windyhill is the only grid connection point available to the applicant. 8.19 The applicant has submitted a site selection assessment in support of the proposal to set out why the Green Belt location is essential and that there are no sites that could
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accommodate this development out with the Green Belt. This acknowledges that for proposals of this nature, each developer will have their own site selection criteria, including distance to the available connection point. The applicant also sets out that the availability of land is an important limiting factor to site selection. Within the assessment, there is reference to one other possible site which the applicant notes as unavailable, although this site is not specifically identified. The site selection assessment does not provide any detailed comparative analysis of possible sites which were considered as potentially being capable of accommodating the development within the 2km radius of the Windyhill substation. The applicant, however, concludes that that within the 2km search area, there is no land within the built-up area within West Dunbartonshire, which is largely residential in character, that could be considered suitable to accommodate this development. There has also been no clear justification of why a 2km search area was considered appropriate compared to a larger radius. 8.20 Notwithstanding the lack of a detailed analysis by the applicant, it can be generally accepted that, based on the applicant’s search criteria, there are likely no sites out with the Green Belt within West Dunbartonshire. However, there has been no assessment of possible available sites within either the East Dunbartonshire area where the connection point is located, and the Glasgow City area. A substantial part of the applicant’s 2km search area lies within East Dunbartonshire and Glasgow City and reference to Policy 8 a) ii) of NPF4, the test in this case is not whether there are no sites which are outwith the Green Belt within the West Dunbartonshire area only, the test is that there are no other suitable sites outwith the Green Belt. Whilst the applicant sets out the desire to invest within West Dunbartonshire to support the economic revitalisation of the area, and some support can be given to this goal, this does not negate the requirement to assess possible available sites within the whole of the identified search area. 8.21 It is not considered that the applicant’s site selection assessment provides a detailed analysis of other possible sites which could accommodate this development, why a 2km search area has been chosen in this instance and why the connection point must be at Windyhill. There has also been no consideration of much of the identified 2km search area. It therefore cannot be considered that the applicant has demonstrated that no other suitable sites are available in a location outwith the Green Belt and it cannot be concluded that the requirements of Policy 8 a) ii, which provides the most up-to-date position on Green Belt developments, are met in this regard. 8.22 Policy 8 of NPF4 goes on to require that the purpose of the Green Belt at this location is not undermined by the proposal. The purpose of the Green Belt designation is to facilitate and promote compact urban growth and ensure that land around urban areas is used sustainably. It is to further ensure that new development is directed towards the urban area to support regeneration priorities and protect the risk of settlement coalescence. The Green Belt designation also supports the protection of landscape character and setting around settlements. Whilst the proposal would represent an expansion of the developed area within the Green Belt, it is not considered that it would affect the strategy of compact urban growth, have an adverse impact on wider regeneration priorities or result in the settlement coalescence. However, it remains that the development must not have an adverse visual impact which is to the detriment of local landscape character and this is considered further below. Landscape and Visual Impact 8.23 Any development of this nature will have a visual impact, and this is not in doubt. The assessment of landscape and visual effects arising from the development is set out in the applicant’s landscape and visual appraisal (LVA) which is based on a 2km study area. The geographical extent to which the development would be visible has been
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established by a ‘Zone of Theoretical Visibility’ (ZTV). This was created using mapping tools to calculate where the development will potentially be visible from in the surrounding area. The ZTV establishes the locations from which the development may potentially be visible and where there is no visibility, receptors are discounted from the assessment. ZTV mapping is presented in the applicant’s submission for the 2km study areas. Taking into account topography, existing woodland and settlements, theoretical visibility is likely from the immediate area surrounding the application site, Clydebank and District Golf Course, sections of the Antonine Wall World Heritage Site and Scheduled Monument, scattered fragments of the north-eastern and south-eastern neighbourhoods of Clydebank, Drumry Wood, the A82 corridor and the core path network, including adjacent to the site. The LVA identified five viewpoints which the applicant considered to be representative of the range of visual receptors considered within the study area. 8.24 The majority of the application site lies within the ‘Drumlin Foothills’ landscape character type (LCT 211) which the submitted LVA considers as the host landscape. A small part of the site extends into the ‘Urban’ landscape character type (LCT 0). The Drumlin Foothills comprises an undulating landform created by glacial deposition subsequently modified by fluvial erosion, small to medium scale landscape with caried views, human activities such as pastoral farming and golf courses, semi-natural woodlands along burns, farm woodlands and small plantations. These features all contribute to a predominantly rural character. The Urban landscape character type sees various components which typically comprise urban development forming the underlying character of the landscape. The applicant’s LVA identifies that the Drumlin Foothills LCT in general to be of medium susceptibility to change although within the immediate vicinity of the site it is considered to be of low susceptibility of change. The LVA does not conclude that the value to the landscape into which the development is proposed is high, and it is thus considered that overall, the landscape has a medium sensitivity to the type of changes proposed. 8.25 The area immediately surrounding the site contains trees and pockets of woodland, grazing land, farm steadings, golf course and a variety of core paths providing for recreational walking routes. This results in an area which can be characterised as one which has a high amenity value with a variety of semi-natural views. This combination of land uses leads to an area that could be characterised as relatively quiet and of high amenity value. Despite this proximity to the urban area, the busy A82 Great Western Road and relatively high-density residential areas, the location of the site feels quite different and separate from this urban area with a predominantly pleasant rural character. Whilst the site is not formally designated for its landscape character, it is clear that the area has a distinct local identity which is of high amenity value. 8.26 It is accepted that the proposed development would be unlikely to be seen over significant distances. It is accepted that both during the construction phase and the completed development before any proposed landscape mitigation matures has the potential to have moderate adverse effects. However, these effects will reduce over time as any landscape mitigation matures. It is accepted that the development would not be of significant across the Drumlin Foothills LCT as a whole. It is also accepted that whilst localised views of the site may occur from the urban area and whilst the site may be visible from elevated location such as the upper floors of the 12 storey flatted blocks to the southeast, the development would not be of significance from these locations. Notwithstanding the above, the development would be sited within an existing field and locally, this would result in a significant change to the landscape pattern which requires further consideration.
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8.27 Considering the local landscape impact, the immediately surrounding area is considered one of high amenity value which can be held to be sensitive to change from inappropriate development. In terms of mitigation for the visual impact of the development, the applicant proposes landscaping buffers within the site between the infrastructure and site boundary. Landscape bunds are also proposed to the north, west and south of the infrastructure. The proposed levels change across the site will result in the equipment sitting below the existing ground level from some locations. A number of core paths traverse the area with Core Path 149 being located on the western boundary of the site and Core Path 150 extending from Braidfield Road to connect with Core Path 149 at the north-western corner of the application site. Core Path 149 continues north to connect with Core Path 148 which follows the line of the Antonine Wall from Cleddans Road. It is accepted that Viewpoint 02 from the applicant’s LVA demonstrates that there will be little notable impact from the westernmost point of Core Path 148 with no visibility of the equipment. Viewpoint 03 is taken from the Roman fortlet to the northeast of the site and to the south of Core Path 148 and again demonstrates little impact, albeit this view may change when trees are not in leaf. Viewpoint 01 looks north from Core Path 149 where it joins the A82. This shows that the landscape bund will be visible from this location and that this will in time be screened by new planting. No equipment is visible. Core Path C2 within the Glasgow City Council is also considered in Viewpoint 04 indicating glimpsed views prior to new planting maturing. Ther is no objection from Glasgow City Council on visual impact from the core path network or any other vantage points within their area. The conclusions of the LVA that no significant effects occur and no moderate effects occur after the construction phase from the chosen viewpoints is accepted. 8.28 However, as noted above, Core Path 149 continues past the development site and is located on its immediate western boundary. Facing east, Core Path 148 travels towards the application site, with the site directly in view. While no routes are physically interrupted by the proposal, there will be a visual impact to users of the routes, and the character of the routes will be changed and the effect could be significant. The Core Path at this location extends from the urban area and takes an attractive route through rolling grazing land with various trees and pockets of woodland within the wider landscape. The experience of the landscape by users of these sections of core path has the potential to change dramatically given the presence of a development of an industrial appearance adjacent to it. No viewpoint from the Core Paths adjacent to the site was initially provided by the applicant. A viewpoint (Viewpoint 01a) facing east on Core Path 148 towards the junction with Core Path 149, adjacent to the northwestern end of the site has now been provided. The visuals provided for this additional viewpoint show that by year 10, the development would be relatively well screened by the proposed landscaping. However, the development will not be screened in its entirety to the point that users of the core path would be oblivious to its presence. Whilst planting and mitigation is proposed as shown in the visuals, this is only detailed as a simple narrative in the supporting documentation and inclusion of the general layout on the proposed site plan. Utilising native deciduous planting to screen the development would also not result in there being a consistent level of screening across all seasons. The landscaping will also take time to mature, and the development will be notable within the landscape for users of the adjacent routes in the early years, potentially affecting the understanding of the area forming part of the green belt and introducing a more urban form of development. However, on balance and accepting an initial impact prior to the landscape mitigation establishing, it is concluded that it has been demonstrated that the proposal would overall seek to minimise localised visual impact. 8.29 Policy 11(e) ii of NPF4 accepts significant landscape and visual impacts. Notwithstanding this, there is also an expectation of appropriate design mitigation for
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these impacts. Policy 8 a) ii also requires that the proposal minimises landscape and visual impacts within the Green Belt as far as possible. Whilst it is accepted that there will be a localised visual impact and that the development will be noticed by users of the adjacent Core Paths, the overall character of the routes will not be changed to such as extent that the development is considered unacceptable in this respect. The final detail of the landscape mitigation together with the implementation, retention and maintenance of this will be of particular importance in ensuring the visual impacts are minimised in the long term. These details can, however, be secured by condition. Overall, it is concluded that the landscape impacts arising from the development are not to such an extent to warrant an objection from the Council. Impact upon designated landscapes 8.30 In further assessing landscape and visual impact, consideration must be given to the potential for any effects on landscape designations. The Kilpatrick Hills Local Landscape Area (LLA) lies around 2km to the northwest of the site. The applicant’s LVA considers that analysis of the ZTV indicates theoretical visibility would be possible from the southeast of the LLA. However, with the screening effect of the urban area which lies between the site and the LLA boundaries together with topography and existing vegetation, only an area around Loch Humphrey Burn is considered to provide visibility of the site. Given that the site is some distance from the designation boundary and visibility is expected to be low from the LLA, it is agreed that as per the assessment within the submitted LVA, any effects would be negligible. Drumry Wood Site of Special Landscape Importance which is situation approximately 400 metres to the east of the site within the Glasgow City Council area. Such sites have been identified by Glasgow City Council where they contribute to the quality of life of those who live or work in the City. They include parks, golf courses, countryside and other features that are important from a visual and landscape perspective. The ZTV identifies that the site will be theoretically visible from much of the northwest of the Site of Special Landscape Importance. The LVA predicts that the effects on the Site of Special Landscape Importance would be negligible. Glasgow City Council have not objected to the proposal and raise no concerns regarding any potential for impact on the Site. It is not considered that any concerns arise in respect of the potential for significant effects on this designation and the conclusions of the LVA are accepted in this regard. Built and Cultural Heritage 8.31 No listed buildings are located within the site or the surrounding area, nor are there any conservation areas or garden and designed landscape designations within the wider area. However, the line of the Antonine Wall lies to the north of the application site. The application site also lies wholly within the Antonine Wall buffer zone. 8.32 The Antonine Wall is the most substantial and important Roman monument in Scotland. Built on the orders of the Emperor Antoninus Pius in the years following 140 AD, it extends for some 60 kilometres across central Scotland from Bo’ness on the River Forth to Old Kilpatrick on the River Clyde and marked the north-western frontier of the Roman Empire. The Antonine Wall is of great significance for a number of reasons. It represents one of many sections of a massive military system which stretched over 5000 km from northern Britain, through Europe to the Black Sea, and from there to the Red Sea and across North Africa to the Atlantic coast. This frontier helped to protect and define the Roman Empire. The Antonine Wall was the most northerly frontier of the Empire, the last of a series of planned frontiers built in the 2nd Century AD and, at the time, the most complex ever constructed by the Romans. Today the Wall continues to be subject to considerable development pressures and given its significance it is imperative that the remaining sections whether visible on the ground or not are safeguarded from inappropriate development.
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8.33 The Antonine Wall is designated as both a Scheduled Monument and to the north of the site, the scheduled monument comprises the Antonine Wall and fortlet, 950m W to 335m ENE of Cleddens. In July 2008 the international cultural and archaeological importance of the Antonine Wall was recognised when the World Heritage Committee of UNESCO inscribed the site as Scotland’s fifth World Heritage Site (WHS). The Antonine Wall became an extension of the trans-national Frontiers of the Roman Empire World Heritage Site which includes Hadrian’s Wall in England and the Upper Raetian German Limes. The intention is that the WHS will eventually include all surviving sections of the frontiers of the Romans in Europe, Africa and the Middle East. With World Heritage Site status comes a commitment to protect the exceptional cultural significance of the Antonine Wall and Outstanding Universal Values (OUV) for which the site was inscribed. The site lies approximately 135 metres to the south of the World Heritage Site and around 375 metres southwest of the fortlet. 8.34 As noted in paragraph 8.28 above, the site lies wholly within the Antonine Wall Buffer Zone. The designation of the buffer zone seeks to protect the important landscape setting of the Antonine Wall. The Buffer Zone defines a zone where added protection to the immediate setting of the World Heritage Site is given. Development proposals within the buffer zone will be given careful consideration to determine whether it is likely to significantly detract from the Outstanding Universal Value authenticity or integrity of the Antonine Wall World Heritage Site. 8.35 The Council’s Planning Guidance on the Frontiers of the Roman Empire (Antonine Wall) sets out the approach and procedure for assessing development affecting the World Heritage Site and the criteria which will be applied in determining applications for development along the line of, and within the setting and vicinity of the World Heritage Site. The Guidance sets out that the impacts of development may be physical upon the fabric of the monument, they may impact upon the setting of the wall where development will harm the character of the landscape around the world heritage site or be cumulative which adds to the existing negative effects of past or current developments thereby creating further and possibly greater adverse effects. 8.36 Considering the physical impact, the site is within the buffer zone, and the appropriateness of this location must be assessed. The integrity of the setting of the WHS and how the Site is understood and appreciated in the landscape are identified as key aspects which must be considered together with the character of the landscape in which the World Heritage Site sits. The Guidance sets out a presumption against development within the Buffer Zone which would have an adverse impact on the WHS and its setting. Where development is proposed within the buffer zone, the Guidance sets out that site selection requires to avoid the most sensitive areas and views, be a well-considered layout of an appropriate design with high quality landscaping. 8.37 The application submission is supported by a Heritage Assessment. Historic Environment Scotland (HES) assessed the proposal and initially objected noting that the application did not include an appropriate heritage-led analysis of the setting and potential impacts on the setting of the Antonine Wall World Heritage Site and scheduled monument, and that there was insufficient information to adequately assess the impact of the proposals. 8.38 The planned layout of the Wall is still apparent in, and has influences on, the modern landscape. An example of this is the linear route of Cleddans Road which largely follows the east-west line of the Wall, with Cleddans Farm located just to the east of the forlet site on the same plateau, as well as the line of hedgerow which follows the Wall route up to Castle Hill. The World Heritage Site at Cleddans is located in an area of countryside, on an elevated position which affords the site superb views in every
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direction. These views are key to the cultural significance of the monument, and the outstanding universal value to the WHS are made possible by the rural and open nature of the setting of the WHS, currently protected by the buffer zone. 8.39 In their original consultation response, HES advised that the assessment of impacts on setting from a proposed development on the historic environment, its structures and places, is not only about the character of the landscape in which they sit, but a more nuanced matter relating to the way that historic assets are understood, appreciated, and experienced. Setting can extend beyond the immediate vicinity of a historic asset into a much broader context and includes both tangible and less tangible elements. A full understanding of the setting of a historic asset should address all these matters in any assessment and should draw upon the contribution each element of an asset’s setting makes to its cultural significance. This would then set out how changes within the setting of a historic asset can impact on its cultural significance and provide informed and appropriate measures to address this. This is particularly important where a development has the potential to impact a WHS. 8.40 Following the objection from HES, the applicant has reviewed the planting proposals and provided updated details and visualisations in support of the proposal. In their further consultation response, HES note that whilst the applicant has not provided an updated Heritage Impact Assessment, a site visit, updated plans and submitted visualisations have allowed HES to carry out their own assessment of the impacts of the proposed development on the setting of the Antonine Wall WHS and scheduled monument. HES are now satisfied that the key views to the south and south-west towards the River Clyde, and in the direction of Old Kilpatrick, will not be obstructed by the development, including the proposed landscaping and planting. HES also consider that due to the sloping topography of the development site and the location of the development to the west of a small hill south of the fortlet at Cleddans, the proposals would not appear to be dominant or distracting in views from the fortlet. HES further consider that the proposals are also unlikely to draw focus or distract from views down into the fortlet at Cleddans and this section of the frontier from Castle Hill to the east, and any glimpsed views from the fort at Goldenhill to the west. Additionally, HES consider the proposed development is unlikely to appear in views as you travel along this straight section of the WHS and scheduled monument, and therefore the revised proposals would not interfere with how the WHS is understood as a linear monument and can be appreciated in the landscape. They are thus content that key views and relationships would be retained. 8.41 Overall, HES have fully assessed the proposal in the context of the revised details and additional information, and now conclude that the proposed development, including the planting proposals, would not have a significant adverse impact the integrity of setting of the scheduled monument and Antonine Wall WHS, to a level as such that would warrant an objection. Conditions to address securing the planting proposals to ensure that the final details of these do not disrupt the setting of the Wall are recommended. 8.42 Whilst not objecting to the proposal West of Scotland Archaeological Service (WoSAS) highlight points in respect of the impact upon the WHS and that a new modern element would be introduced to the setting of the Wall. WoSAS go on to advise on the potential for sub-surface archaeological material to survive in the area. WoSAS consider, however, that the mitigation programme proposed in the applicant’s Heritage Assessment in respect of archaeology is in line with the approach that they would generally recommend in relation to greenfield developments of this type, and as a result, it would be acceptable from their perspective. It is recommended that the matter is addressed by condition should the Scottish Ministers be minded granting consent.
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8.43 It is clear that the proposed development would have the potential to impact upon the Antonine Wall WHS and Scheduled Monument. Whilst Historic Environment Scotland initially objected, they are now able to conclude that there would not be a significant, adverse impact upon the Antonine Wall WHS and Scheduled Monument to together with the integrity of the setting of the Wall to the point that an objection would be warranted. Following a full assessment of the potential impact upon this asset, there is nothing to suggest that an alternative position to HES, who have considered the Council’s published guidance in their assessment of the proposal, should be taken or that there would be any additional concerns at a local level. The proposal is therefore considered acceptable with reference to policies 7 l) and 11 e) vii of NPF4, policies DC6, BE5, BE6A and BE6B of the adopted Local Plan, Policies BE1 and AW1 of proposed Local Development Plan 2 together with the Council’s Frontiers of the Roman Empire (Antonine Wall) Planning Guidance. 8.44 The connection between the proposed site and Windyhill substation does not form part of this application. However, with the Antonine Wall lying between the site and the substation it is not clear how a connection could be achieved. The Scottish Ministers would require satisfying themselves that a connection to the site could be achieved. Residential amenity 8.45 Residential amenity can be affected in a variety of ways. This includes noise from construction and operation of the proposed development together with other impacts which could arise during the construction phase. Any development will produce noise during the construction phase, and this has to be accepted. Environmental Health raise the requirement to ensure that the site is managed in such a way during construction so as not to cause undue disturbance and this could be addressed by appropriate conditions if required, including relating to hours of work, construction noise, delivery vehicles and dust. Such an approach would address any short-term impacts during construction. 8.46 The proposed site is situated outwith the urban area as defined by the adopted Local Plan and proposed Local Development Plan 2 in a location with a predominantly rural character. The nearest noise sensitive receptor is the farmhouse at Braidfield farmhouse approximately 175 metres to the west of the main equipment compound within the application site. Within the nearby urban area, there are a variety of noise sensitive receptors including dwellinghouses on Braidfield Road and Strathdee Avenue approximately 260 metres from the main equipment compound. To the south, dwellinghouses on Morar Avenue and Morar Place are some 350 metres from the main equipment compound and also lie on the opposite side of the A82 from the site. St Peter the Apostle High School also lies to the opposite side of the A82 around 250 metres distant. 8.47 Policy 11 (e) i of NPF4 requires that impacts on communities and individual dwellings including residential amenity, and noise are addressed. A noise impact assessment (NIA) has been submitted in support of the proposal. The NIA identifies a range of noise sources from the development including the energy storage units, power convertors and transformers. It is set out that the type of unit proposed would generate a typically broadband type of noise which is within strong tonal characteristics. It is set out that the transformers are tonal and are not predicted to be audible at nearby receptors. It is advised by the applicant that for procurement and engineering reasons, it may be necessary to vary the proposed equipment during or after the consenting process. In the event that alternative equipment is proposed that would give greater noise impacts at the receptors, then a full noise assessment would be undertaken and agreed prior to proceeding with that alternative equipment.
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8.48 It is accepted that currently there is notable background noise arising from the busy A82 and general urban activity, as identified in the NIA. It is concluded in the NIA that the predicted noise arising from the proposed development at the locations set out in paragraph 8.42 above is below the background daytime noise level and no more than 3 dB above nighttime background levels. The NIA has been considered by the Council’s Environmental Health Service who conclude that the site could be developed without adverse impacts occurring. However, given the nature of the type of development, conditions are recommended in terms of noise at any dwelling or noise sensitive building not exceeding particular noise rating curves. A condition requiring a post development verification report to demonstrate that the projections as detailed within the NIA are achieved is also recommended. 8.49 Environmental Health further note the applicant’s position that for procurement reasons, the proposed equipment may be varied following the granting of consent. The NIA would therefore require to be updated in the context of the final choice of equipment if different from that which the current NIA is based on to ensure that no unacceptable impact occurs to residential properties. The requirement for an updated NIA based on the final choice and specification of equipment and undertaken in accordance with the relevant guidance could also be addressed by condition should the Scottish Ministers be minded granting consent for this development. 8.50 Overall, it is concluded that the site could be developed without giving rise any unacceptable impacts to residential amenity or having any adverse impact upon the operation of the nearby high school arising from noise. Accordingly, the proposal would be considered acceptable with regard to Policies 11 (e) i and 24 of NPF4 together with policies the relevant policies of the adopted Local Plan and proposed Local Development Plan 2. Ecology and Biodiversity 8.51 Policy 3 of NPF4 seeks to protect biodiversity, reverse loss, deliver positive effects from development and strengthen nature networks. Policy 4 seeks to protect, restore and enhance natural assets, making best use of nature-based solutions. The Policy is primarily focused on designated areas including sites designated as a local nature conservation site or landscape area. Policy 11 e) ix also requires biodiversity impact to be addressed. The applicant has submitted a preliminary ecological appraisal (PEA) and biodiversity report in support of the proposal, and these combine to assess impacts upon the proposed site. The application site comprises grazing land bound by a variety of hedgerows inclusive of a small number of trees. Two trees were identified as having good potential for bat activity, although no tree works are currently proposed. One mammal hole was identified within he survey area although no badger path to the entrance was recorded. To further determine possible use by badger, a camera trap was placed adjacent to the hole entrance. No badger activity was recorded although a pair of foxes were observed entering and exiting the hole and triggered the camera on 16 occasions. 8.52 The Council’s Biodiversity Officer has considered the applicant’s submissions and accepts the methodology and approach undertaken, specifically noting the additional caution in respect of the camera monitoring. Whilst it is accepted that there are no watercourses within the site affected by the proposal, the Biodiversity Officer recommends a cautionary position in respect of watervole, noting that the PEA did not consider the possibility that watervole could be present in the wider area, including Cleddans Burn and marshes to the east which have historical records of watervole and the Hardgate burn to the north has recent surveys with field signs of watervole confirmed. Whilst there is nothing to suggest an adverse impact on ecology and protected species, concerns are raised by the Biodiversity Officer in respect of the PEA
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dating from 2022. This is longer than is usually accepted for a PEA to still remain accurate in its findings and it is recommended that the PEA is updated to re-determine the validity of the current report. This is especially important given the mobile nature of the potential wildlife using the site. It should be re-established that currently there is no badger activity on the site and watervole could also be considered. 8.53 The Council’s Biodiversity Officer has also considered the biodiversity statement and notes that enhancement is proposed in respect of a number of habitat improvement works such as hedgerow gapping, tree retention and planting, wildflower areas, ponds and bunds, all of which offer potential for biodiversity improvement on the site. It is considered that these would also provide an extension to the existing woodland and wetland habitat to the southwest of the site (just east of the Titan Hotel) which is known to be a biodiverse site. It would also provide further connectivity to the Cleddans Farm hedgerows, burn and woodland areas to the east. 8.54 Overall, it is concluded that no adverse impact on ecology, biodiversity and protected species would arise from the development subject to a requirement to update the PEA to include updated species surveys for bats, badger and watervole. The biodiversity enhancement measures are acceptable and would have a positive effect on biodiversity. The proposal is therefore considered acceptable with reference to Policies 3, 4(d) and 11(e)ix of NPF4 together with Policies E1 and E3A of the Local Plan and Policy ENV1 of the proposed Plan. Traffic, Transport and the Impact on the Road Network 8.55 Policy 11 e) vi of NPF4 requires the impacts on road traffic to be appropriately addressed, including during construction. Access to the site will be taken from Braidfield Road via Strathdee Avenue, Kilbowie Road (A8014) and Great Western Road (A82). No transport statement has been submitted by the applicant in support of the application. The applicant’s planning statement does, however, set out that the construction phase will involve bringing construction machinery to site, the delivery of aggregate for the site track, delivery of site components including the battery units and other equipment and materials. It is further advised that this will require a mixture of light commercial and HGV loads, together with a small number of abnormal loads which will be necessary for the main transformer delivery and cranes. No details of expected vehicle movements during the construction phase are provided nor is the expected approach to managing construction vehicles. It is, however, advised that a Construction Traffic Management Plan will be developed and agreed. This would include the timing of deliveries with respect to busy periods, school times, the routing of deliveries, measures to ensure the safety and convenience of road and core path users, appropriate signage, advance notice and contact details for any issues for residents, identification of a nominated person to whom issues can be referred, considerate driving, measures to protect the public road from deleterious material from the site, procedures to deal with inclement weather and breakdowns, and access for emergency services. 8.56 The Council’s Roads Service has considered the proposal and does not identify any issues or objections. The requirement for notification of the commencement of works, abnormal load movements and pre and post development inspections of the public road network are identified by roads, together with the requirement to ensure road sweeping if required, that surface water is not discharged to the public road and that the access to the site is hard surfaced for the first 12 metres and that any gates are set back from the public road by at least 12 metres. These matters can be addressed by condition or via a Construction Traffic Management Plan which can itself be addressed by condition. Transport Scotland have also considered the proposal and offer no objections subject to a variety of matters being addressed by condition including
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matters relating to abnormal roads on the trunk road network and the requirement for a Construction Traffic Management Plan addressing a range of matters. Whilst not set out in the applicant’s submission, there is the possibility that equipment would require to be replaced from time to time, or that a wider midlife equipment replacement programme would be required. A condition can ensure that suitable traffic management plans are agreed for such events. 8.57 While the concerns relating to roads and traffic matters highlighted in the objections to the Scottish Ministers are noted, subject to the matters set out above being addressed by condition in the event the Scottish Ministers were minded to grant consent for the development, there is thus no objection to the proposal on roads and traffic grounds and the proposal is acceptable. Flooding and Drainage 8.58 Considering matters relating to flood risk, a review of SEPA’s flood risk mapping concludes that the site is not at risk of flooding from watercourses and whilst localised areas of surface water flooding are identified on the land surrounding the site, the site itself it not at risk. A drainage assessment is submitted in support of the proposal, and the development will incorporate Sustainable Drainage Systems (SuDS) to attenuate run off. The SuDS will comprise an attenuation pond which will discharge to the existing drainage ditch to the east of the site which itself drains to Cleddans Burn. This will ensure that no flooding occurs from the site up to and including the 1 in 200-year flood event plus climate change allowance. The Council’s Roads Service offer no objection to the proposal on flood risk grounds and in their consultation response to the Energy Consents Unit, SEPA also offer no objection on the grounds of flood risk. The proposal is considered acceptable with reference to Policy 22 of NPF4 which has primacy over the Local Plan and proposed Local Development Plan 2 in respect of the position on flooding. Aviation Safety 8.59 Concerns are raised in the objections to the Scottish Ministers in respect of aviation safety related issues. Glasgow Airport offer no objection to the proposal subject to the imposition of conditions relating to soft and water landscaping and bird hazard management. National Air Traffic Services (NATS) also offer no objections to the proposal. It is therefore not considered that any concerns relating to aviation safety or the operation of Glasgow Airport arise. The proposal presents no conflict with Policy 11 e) iv, Policy DC3 of the adopted Local Plan and Policy E7 of proposed Local Development Plan 2. Health and Safety 8.60 The applicant acknowledges that there are potential hazards associated with BESS facilities and that whilst it is not possible to eliminate all risk, it can be reduced and managed to an acceptable level and designed to limit the consequences of an event. No outline safety management plan or battery fire plan have been submitted by the applicant in support of the proposal although the proximity to Clydebank Fire Station is highlighted by the applicant. 8.61 Concerns are raised in the public objections to the Scottish Ministers in respect of site safety and fire risk. Policy 23 of NPF4 addresses Health and Safety but this does not cover such developments specifically but rather sets out a requirement for new development to protect people and places from environmental harm, mitigate risks arising from safety hazards and encourage, promote and facilitate development that improves health and wellbeing. Therefore, whilst health and safety are a legitimate material planning consideration, in considering the development proposal the focus requires to be on locational, design and layout aspects of the proposal rather than any
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concern with the principle of using such technology or the technical design of equipment, which is controlled by other legislation and industry standards. 8.62 Whilst it is generally accepted that the safe operation of the site is not a planning consideration, it would be expected that the Scottish Ministers consult the Scottish Fire and Rescue Service on the proposal and satisfy themselves that an unacceptable risk does not occur from the development. Notwithstanding this, it is concluded that a precautionary approach can be reasonably captured through a condition requiring a detailed Battery Fire Safety Management Plan which includes response, management and mitigation measures in the event of a fire should the Scottish Ministers be minded to grant consent for the development. Decommissioning 8.63 No details are provided by the applicant in respect of the length of the operational period of the development or the approach to decommissioning. Whilst the preference would be that the approach to decommissioning and site restoration to be provided upfront with the detail and implementation of the decommissioning and restoration scheme then addressed by condition, it is accepted that this is at odds with the established approach to other similar developments. It is therefore accepted that the decommissioning and site restoration can be secured by condition, and any such condition(s) must be suitably robust to ensure the complete removal of all aspects of the development and the restoration of the landform within the site to its original profile. A further condition can also ensure early decommissioning should the site cease to export electricity to the grid for in excess of 12 months. A financial provision to provide sufficient funds for the decommissioning and restoration of the site should such be required must also be secured. With such an approach, it is considered the development meets the requirements Policy 11e) xi of NPF4. Community and Economic Benefit 8.64 Policy 11 c) of NPF4 sets out that development proposals will only be supported where they maximise net economic impact, including local and community socio-economic benefits such as employment, associated business, and supply chain opportunities. Policy 25 addresses the approach to community wealth building. Battery energy storage makes an indirect but significant contribution to renewable energy generation targets and greenhouse gas emissions reduction targets, by increasing the productivity of renewable generators elsewhere on the grid. The provision of a secure electricity system brings economic benefits across the national economy. The construction and decommissioning of the development present supply chain opportunities for business and could potentially contribute to local economic activity. Whilst the lack of direct community benefit is highlighted in the objections to the Scottish Ministers, the provision of a community benefit package is not a material planning consideration and therefore and therefore would not warrant an objection to the proposal. Ground conditions 8.65 No site investigation has been submitted in support of the application and as such it has been recommended by Environmental Health that conditions be applied regarding site investigation. Further conditions in respect of the importation and reuse of soils are also recommended by Environmental Health. Concerns regarding former mining activity and associated ground conditions are raised in the objections to the Scottish Ministers. In a consultation response to the Scottish Ministers, the Coal Authority confirm that there are no records of any coal mining features within the site which may pose a risk to surface stability. It is noted that the site does adjoin an area of probably shallow coal workings, but these do not extend to the site. Accordingly, the Coal Authority offer no objection to the proposal.
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9. CONCLUSION 9.1 This application has been submitted to the Scottish Government under Section 36 of the Electricity Act 1989, as it is development with a generating capacity of over 50MW. Under the terms of Section 25 of the Town and Country Planning (Scotland) Act 1997, all applications must be determined in accordance with the development plan unless material considerations indicate otherwise. In this instance, the application is made under the Electricity Act 1989 and therefore the Development Plan does not have the primacy in the determination of the application. It does, however, provide a basis for the assessment of this proposal and it is established practice to take the development plan into account in such decisions. The development plan comprises National Planning Framework 4 and adopted West Dunbartonshire Local Plan. Whilst not adopted, proposed Local Development Plan 2 (LDP2), incorporating the recommended modifications of the Examination Report received on 22 April 2020, which were accepted by the Planning Committee of 19 August 2020, remains the Council’s most up to date spatial strategy and is therefore afforded significant weight in the assessment and determination of planning applications, subject to compatibility with NPF4 9.2 The contribution of up to 100mw battery storage capacity in supporting renewable energy generating capacity, which in turn will assist in decarbonising the electricity network, draws strong support in term of renewable energy targets and supporting the overarching aims of NPF4 to achieve net zero targets. The site is situated within the Green Belt as defined by the adopted Local Plan and proposed Local Development Plan 2. Policy 8 of NPF4 sets out the types of development that are supported within the Green Belt locations. This includes essential infrastructure and proposals that relates to the distribution and transmission of electricity grid networks fall under this definition. However, Policy 8 is clear that for development proposals in Green Belt locations, the purpose of the Green Belt must not be undermined. Policy 8 goes on to require that the reasons why the Green Belt is essential must be provided together with why the development cannot be provided on a site outwith the Green Belt. It is acknowledged that such developments require to be sited where a suitable electricity connection can be made into a substation with sufficient available capacity. However, it is not considered that the applicant’s site selection assessment provides a detailed analysis of other possible sites which could accommodate this development, why the development must be connected to Windyhill substation, or why a 2km search area has been chosen in this instance. There has also been no consideration of much of the identified 2km search area. It therefore cannot be considered that the applicant has demonstrated that no other suitable sites are available in a location outwith the Green Belt and it cannot be concluded that the requirements of Policy 8 a) ii are met in this regard. 9.3 Turning to visual impact which is a key consideration, Policy 11e) ii of NPF4 explicitly accepts localised significant landscape and visual impacts and in this respect the position is thus weighted towards development’s contribution to renewable energy targets. However, this Policy requires such impacts to be addressed with appropriate design mitigation. Policy 8 a) ii also requires visual impact within the Green Belt to be minimised as far as possible. Overall, and following a full assessment, it is concluded that the landscape impacts arising from the development are not to such an extent that significant concern arises, subject to conditions requiring the landscape mitigation to be in place. 9.4 The impact upon built and cultural heritage assets is also a significant consideration with the potential for the development to impact upon the setting of the world heritage site and scheduled monument, an internationally recognised asset. Having fully
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reviewed potential impacts and being guided by the position in the consultation responses to the Scottish Ministers, including that from Historic Environment Scotland it is concluded that the proposed development, including the planting proposals, would not have a significant adverse impact the integrity of setting of the scheduled monument and Antonine Wall WHS, to a level that would be considered unacceptable. 9.5 All other matters raised, including those relating to residential amenity, ecology and biodiversity, impact upon designated landscapes, traffic, transport and the impact upon the road network, flooding and drainage, aviation, health and safety and ground conditions are considered to be satisfactorily addressed. None of these matters would have a significant impact or outweigh the substantial support that applies to renewable energy projects in national and local planning policy. 9.6 Overall, due to the above concerns relating to the Green Belt location of the development, it cannot be considered that the benefits of the proposed development outweigh any adverse impacts. On balance, the significant concern arising from the lack of justification from the applicant that the proposed development cannot be located on a site outwith the Green Belt is not considered to outweigh other policy support for the proposed development. 9.7 It must be noted that should the Planning Committee accept the recommendation to formally object to the proposed development, this will trigger a Public Local Inquiry in terms of Section 62 and Schedule 8 of the Electricity Act 1989 unless the Council subsequently withdraws its objection, or the applicant subsequently withdraws the application. 10. COUNCIL’S POSITION ON THE APPLICATION 10.1 It is recommended that this Committee Report is forwarded in full to the Scottish Ministers as presenting the Council’s full formal response to the consultation and that it is highlighted that the Council objects to the application for the following reason: The Council objects to the proposal as it has not been demonstrated that no other suitable sites are available in a location outwith the Green Belt in accordance with the requirements of Policy 8 a) (ii) of National Planning Framework 4 and this concern is not considered to outweigh other policy support for the proposed development. 10.2 Finally it is recommended that, all matters arising in respect of any Public Local Inquiry are delegated to the Planning, Building Standards and Environmental Health Manager. Michael Mulgrew Planning, Building Standards and Environmental Health Manager Date: 14th January 2026 ______________________________________________________________ Person to Contact: Michael Mulgrew, Planning, Building Standards and Environmental Health Service Manager Email: Michael.Mulgrew@west-dunbarton.gov.uk James McColl, Development Management Team Leader Email: james.mccoll@west-dunbarton.gov.uk
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Appendix 1: Location Plan Background Papers: 1. Application documents 2. Consultation responses submitted to the Scottish Ministers 3. Representations submitted to the Scottish Ministers 4. National Planning Framework 4 5. West Dunbartonshire Local Plan 2010 6. Proposed West Dunbartonshire Local Development Plan 2 2020, as amended 7. Frontiers of the Roman Empire (Antonine Wall) Planning Guidance 8. Renewable Energy Local Development Plan (Proposed Plan) Planning Guidance November 2016 Wards affected: Ward 4 (Kilpatrick)