Item 7 - Consultation response - Construction and operation of a 560MW Battery Energy Storage
West Dunbartonshire Council · 11 December 2024
Back to Planning Committee — 11 December 2024 and its agenda
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WEST DUNBARTONSHIRE COUNCIL Report by Planning, Building Standards and Environmental Health Manager Planning Committee: 11th December 2024 ___________________________________________________________________ Subject: Construction and operation of a 560MW Battery Energy Storage System with associated infrastructure, substation, security fencing, CCTV, security lighting and landscaping on Land at Cochno Road, Bearsden, East Dunbartonshire - Section 36 application to Scottish Government Energy Consents Unit ref: ECU00004982 1. Purpose 1.1 To agree an updated consultation response following the receipt of further details and a revised proposal from the Scottish Government Energy Consents Unit, on behalf of the Scottish Ministers, in connection with a proposal for the construction and operation of a 560MW Battery Energy Storage System with associated infrastructure, substation, security fencing, CCTV, security lighting and landscaping on land within the East Dunbartonshire Council area. 2. Recommendations 2.1 It is recommended that the Committee agrees to maintain an objection to the above development in respect of matters specified in the response contained in Appendix 1, and that this response is submitted to form the Council’s updated position on the proposal. 3. Background 3.1 The Scottish Ministers received an application under section 36 of the Electricity Act 1989 for the construction and operation of a battery energy storage facility with a maximum power output of 560 megawatt. The application site is located within the East Dunbartonshire local authority area, however the assessment of the submitted application is undertaken via the Scottish Government Energy Consents Unit for the Scottish Ministers. West Dunbartonshire Council were consulted as neighbouring planning authority with the application site lying generally to the north of the local authority boundary. The application is referred to under the project name of Whitehall BESS. The location of the site is shown in Appendix 2. 3.2 Following consideration of the proposal by the Planning Committee on 11th May 2024, the Council issued a consultation response to the Scottish Ministers on 13th May 2024. The Council objected to the proposal due to the concerns relating to the Green Belt location of the development, visual impact, impact upon ecology, biodiversity and protected species, potential impact upon the users of the core path network, potential impact upon adjacent residential amenity and the failure to provide a decommissioning and restoration scheme. The Council did not consider that the benefits of the proposed development outweigh any adverse impacts to the adjacent West Dunbartonshire area. ITEM 7
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3.3 Following the submission of the Council’s objection, a revised proposal together with a range of additional and updated supporting documents have been submitted to the Scottish Ministers. These details include a revised site layout, revised equipment details, revised planting layout, a Landscape Statement, an updated Landscape and Visual Assessment, an updated Noise Impact Assessment and an Archaeological Investigation. A date of 13th December 2024 has been agreed with the Scottish Government Energy Consents Unit for the submission of the Council’s updated consultation response. The application documents are available to view via the Energy Consents Unit website: https://www.energyconsents.scot and the following direct link: Scottish Government - Energy Consents Unit - Application Details The Council’s original consultation response can also be viewed within the case file at this link. 4. Main Issues 4.1 The site is situated on land at Whitehall Farm, Cochno Road, East Dunbartonshire and extends to approximately 29 hectares. It is located immediately north and east of the local authority boundary which follows the line of Cochno Road at this location. The site itself is located within the open countryside comprising part of the Green Belt as defined by the adopted East Dunbartonshire Local Development Pan 2. To the south, the site is bound by Cochno Road with Whitehill Farm located directly adjacent to the southeast of the site. To the west, the site is bound by Cochno Road along its southern extent before following the general line of Lower Stourfold Glen. The northern and eastern boundaries of the site generally cut across open land before following the existing tree line to Cochno Road. The nearest residential properties within West Dunbartonshire are the houses directly opposite the site at Edinbarnet, Cochno Road. Properties at Craigton Street, Burnbrae Street, Craighaw Street and Field Road lie around 170 metres from the southernmost boundary of the proposed site. Loansdean, Cochno Road is around 200 metres from the site. 4.2 The proposal is for a 560 MW Battery Energy Storage Facility with associated infrastructure. It is indicated that the development would have an operational lifespan of 40 years. The proposed development would comprise a number of containerised units to house battery energy storage systems and associated ancillary infrastructure. Each container will have the appearance of a standard metal ISO/shipping container, and it is indicated these will be soundproof. The containers would likely be finished in dark grey or green and would be prefabricated off-site. The containers would be accessed via an external galvanised metal open grid walkway supported by stairs and railings. The dimensions of the containers have been amended from being 2.6m x 2.4m x 12.2m, to being 2.9m x 2.4m x 6.1m (height x depth x width). Power conversion system units are of the same size and take a similar appearance. No updated description of the equipment to be located on site has been provided. However, from the updated site plan, it is clear that the equipment will be provided in 64 banks of 6 units. It remains that the proposal will feature a control room, sub-station compound, sub-station building. Separate switchgear compounds are no longer proposed. The access point to the development also remains located on Cochno Road, to the western edge of the site. 4.3 Battery Energy Storage Solutions provide a means of allowing for the storage of energy at times when generating stations are working at full capacity which can then be released when additional power is needed within the grid during peak times or when energy generation has dropped. As more energy sources are now renewable, such as wind and solar, balancing generation versus demand is a critical issue for grid stability. In short, the proposed battery takes in generated electricity when there is a
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surplus and stores it until there is a demand for electricity which can be released to meet this demand. 4.4 Appendix 1 comprises the recommended updated consultation response. There is no change to the position of National Planning Framework (NPF) 4 since the Council’s previous consultation response and it remains that 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 Transmission Infrastructure. NPF4 recognises that additional electricity generation from renewables and electricity transmission capacity of scale is fundamental to achieving a net zero economy. Whilst the Council considers 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, it must be ensured that such development happens in the right place. Therefore, it must be assessed if there are any potential adverse impacts upon West Dunbartonshire resulting from the proposed development which would be outweighed by any benefits. 4.5 In considering the proposal previously, it was concluded that no concerns arose in respect of matters relating to the impact upon the Kilpatrick Hills, flood risk, roads, and traffic, built and cultural heritage, and health and safety. There is no change to this position which remains as per the original consultation response issued. 4.6 In originally considering the proposal, it was concluded that the applicant did not demonstrate that there are no other suitable sites available in a location outwith the Green Belt. The applicant has not considered or addressed the Council’s previous point of objection relating to the failure to demonstrate that there are no other suitable sites available for such a development in a location outwith the Green Belt. If an alternative location was available, no landscape and visual impact would result in the proposed location, regardless of whether any visual impact could be considered acceptable. 4.7 It was also considered that the industrial character of the development will result in visual harm to the locality resulting in the industrialisation of the Green Belt and that this would not be acceptable. In an effort to address the potentially adverse visual impact resulting from the development, a revised site layout which reduces footprint and massing of the development has been submitted by the applicant. The revised site layout also moves the developed area away from the site boundaries and sensitive visual receptors, including nearby residential properties in Faifley to the south. Additional landscape mitigation is proposed in the form of extensive planting. Policy 11(e)(ii) of NPF4 explicitly accepts localised significant landscape and visual impacts and in this respect the position is thus weighted towards the development’s contribution to renewable energy targets. Whilst landscape and visual impacts will still arise from the revised proposal, the reduced development footprint, enhanced landscape mitigation and additional separation from the settlement boundary of Faifley reduces the impact. The development is no longer considered to be viewed in the context of the adjacent settlement and an industrialisation of the Green Belt at this location is no longer of such a concern that an adverse impact will occur to the West Dunbartonshire Area which outweighs the benefits of the development in respect of the contribution to renewable energy targets. It is concluded that the previous point of objection in relation to landscape and visual impact has been addressed.
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4.8 Turning to the impact upon ecology, biodiversity and protected species, the applicant’s preliminary ecological appraisal failed to identify the adjacent Local Nature Conservation Site within West Dunbartonshire and assess the potential cross boundary impact upon ecology, biodiversity and protected species within West Dunbartonshire. It therefore could not be concluded that adverse impacts would not occur within the West Dunbartonshire area. No updated surveys or information have been received in respect of the points raised in the Council’s previous consultation response and the position of the previous response with respect to ecology, biodiversity and protected species and potential impact within the West Dunbartonshire Area remains. 4.9 Considering the impact on the core path network, there was previous concern that while no routes are physically interrupted by the proposal, there will be a visual and noise impact to users of the routes and the character of the routes will be changed. With the reduction in the developed area of the site together with additional landscape mitigation proposed, it is considered that the visual amenity impacts on core path users would now be acceptable and this concern is addressed. It remains that Cochno Road acts as a connection between the various core path routes at this location and the impact of construction traffic to users of these routes has not been considered or addressed. However, this matter being addressed as part of a comprehensive construction traffic management plan in the event that consent was to be granted could be accepted. 4.10 With regard to residential amenity, it could not previously be demonstrated beyond doubt that there would be no impact upon residential amenity within West Dunbartonshire by way of noise. The updated Noise Impact Assessment (NIA) now demonstrates that there will be no impact upon residential amenity within West Dunbartonshire by way of noise. This is based on the position of the NIA which no longer refers to any flexibility in the layout of siting of the units within the development. Accordingly, this point of objection is now satisfactorily addressed. 4.11 Finally, it remains that the Council considers it essential that given the type of development together with its size and location, that details of de-commissioning and site restoration are provided to ensure that the requirements of Policy 11(e)(i) of NPF4 are met. There have been no further submissions in this respect since the Council’s previous response. 5. People Implications 5.1 None. 6. Financial and Procurement Implications 6.1 There are no financial or procurement implications in terms of this report. 7. Risk Analysis 7.1 No risks have been identified. 8. Equalities Impact Assessment (EIA) 8.1 Not required.
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9. Environmental Sustainability 9.1 Matters relating to environmental sustainability are fully considered via the application assessment. 10. Consultation 10.1 Responsibility for wider consultation on the submitted application rests with the Scottish Ministers and Energy Consents Unit as part of the application process. 11. Strategic Assessment 11.1 The following strategic priorities of the Council are relevant: Our Communities - Resilient and Thriving Our Environment - A Greener Future Our Economy - Strong and Flourishing Michael Mulgrew Planning, Building Standards and Environmental Health Manager Date: 11th December 2024 Person to Contact: Michael Mulgrew, Planning & Building Standards Manager Email: Michael.Mulgrew@west-dunbarton.gov.uk James McColl, Development Management Team Leader Email: James.McColl@west-dunbarton.gov.uk Appendix 1: Council’s further Consultation Response Appendix 2: Location Plan Background Papers: 1. Application documents 2. National Planning Framework 4 3. Adopted East Dunbartonshire Local Development Plan 2 4. Planning Committee Report dated 11th May 2024 5. Council’s Consultation response dated 13th May 2024. Wards affected: Adjacent to Ward 4 (Kilpatrick)