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Item 7 - Appendix 1

West Dunbartonshire Council · 16 April 2025
Back to Planning Committee — 16 April 2025 and its agenda

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Section 36 application ref: ECU00004982 - 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 - project name Whitehall BESS.
Having fully reviewed the additional and updated details submitted, West Dunbartonshire
Council is now able to provide a further updated consultation response which no longer raises
an objection to the above proposal as neighbouring Planning Authority. Full details of the
Council’s consideration of the additional and updated details proposal are set out below.
Context
An application has been made to the Scottish Ministers under Section 36 of the Electricity Act
1989 (as amended) 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 and the assessment of the application proposal is
undertaken via the Scottish Government Energy Consents Unit. West Dunbartonshire Council
was previously consulted as neighbouring planning authority with the application site lying
generally to the north of the local authority boundary. Following consideration of the proposal
by the Council’s Planning Committee on 8th 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.
Following the submission of the Council’s objection, a revised proposal together with a range
of additional and updated supporting documents was submitted to the Scottish Ministers.
These details included 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. Following consideration of the
revised proposal by the Council’s Planning Committee on 11th December 2024, the Council
issued an updated consultation response on to the Scottish Ministers on 13th December 2024.
In the updated consultation response, the Council considered that some aspects of the
concerns which formed part of the original objection had been addressed, including visual
impact and the impact upon residential amenity. However, the Council considered that the
applicant failed to address other concerns relating to the Green Belt location of the
development, impact upon ecology, biodiversity and protected species and the failure to
provide a decommissioning and restoration scheme.
Following the submission of the Council’s updated consultation response, further supporting
information has been received from the applicant in respect of the need for the Green Belt
location together with an updated Preliminary Ecological Appraisal. The applicant also
provides clarification on the approach to de-commissioning and restoration proposals. The
Council has reviewed the further supporting information relating to the proposal as set out
below. For the avoidance of doubt, this updated response is based solely on the further
supporting information emailed to the Council on 15th January 2025.
ITEM 7 - APPENDIX 1

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This updated response requires to be read in conjunction with both the Council’s original
consultation response dated 13th May 2024 and updated second response dated 13th
December 2024. The Council’s position in relation to the impact upon the Kilpatrick Hills, traffic
and road safety, flood risk, built and cultural heritage, and health and safety was set out in the
response dated 13th May 2024. Whilst there was no objection from the Council in respect of
these matters, a number of points were highlighted and the position regarding these matters
stand. In the response dated 13th December, the Council was able to remove its objection
relating to landscape and visual impact, residential amenity and the impact upon the core path
network, but highlighted a number of points and again, the position regarding these matters
also stand. It remains that if the Scottish Ministers were minded to grant consent, the Council
would expect the Council’s comments to be taken into account.
This updated response focuses on the Council’s previous points of objection relating to the
Green Belt location of the development, impact upon ecology, biodiversity and protected
species and the failure to provide a decommissioning and restoration scheme.
Site description and development proposal
There is no change to the application site or the detail of the proposal since the Council’s most
recent response of 13th December 2024.  It remains that the site extends to approximately 29
hectares and is situated on land at Whitehall Farm, Cochno Road, East Dunbartonshire. The
site lies 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.
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. It remains
that as per the original proposal, the development would comprise a number of containerised
units to house battery energy storage systems and associated ancillary infrastructure. Each
container will have the appearance similar to ISO/shipping container and 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
and include external air conditioning units. The equipment will be provided in 64 banks of 6
units and the development 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.
Appraisal
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.  As highlighted in previous responses it does, however, provide a basis for the

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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 East Dunbartonshire Local Development Plan 2.
Principle of Development
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.
As set out in the previous responses, the Council considers that the proposal could be held to
support the overarching aims of the NPF4 to achieve net zero targets and provide a stable
domestic energy supply, but 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. Policy 11(e) of NPF4 sets out in detail the matters for the project design and
mitigation to address.
Location within the Green Belt
In originally considering the proposal, it was noted that the site is situated within the Green
Belt to the north of the settlement of Faifley. 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 further requires 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. It was previously acknowledged that the site has been chosen due to it’s proximity to
appropriate grid connections. It is accepted that there is a requirement for battery storage sites
to be located close to a viable grid connection with sufficient capacity to import and export
power. In this case, while this is accepted from a technical perspective and the proximity of the
site to both the Drumchapel sub-station and Windyhill sub-station which lie 3.17kms and 560m
to the south east respectively is acknowledged, the Council was of the view that the applicant
failed to provide any analysis of other site options that were considered outside of the Green
Belt and why it was not possible to locate them in an alternative place. Accordingly, it therefore
could not be concluded that no other suitable sites are available in a location outwith the
Green Belt.
In support of the proposal, the applicant has provided an additional supporting statement
focusing on the location and siting of the development within the Green Belt. The applicant
sets out that the distribution and transmission of electricity grid networks fall under the
definition of essential infrastructure in NPF4 and this definition has been determined to include
battery energy storage systems. This is not disputed and it is acknowledged that essential
infrastructure is a type of development which can be supported, in principle, within the Green
Belt as set out in the Council’s previous responses. The applicant further sets out that Battery
Energy Storage developments have very specific locational requirements, which severely
limits where they can be sited. It is advised that battery energy storage systems must be
located within proximity of a viable grid connection that has sufficient capacity to import and
export the power that will be stored by the development. Suitable points of connection include
a sub-station or an overhead power line, however, the applicant advises that the ability to find
connections with sufficient capacity is severely limited and not every sub-station has the
capacity for such a connection. The applicant goes on to advise that in many cases, the work

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required to upgrade the sub-station can render many schemes unviable. In this case, there is
capacity for a viable connection at the Windyhill sub-station.
The applicant further sets out that where a suitable connection can be found, a number of
other factors require to be taken into consideration. This includes the distance from a sub-
station or connection point as the level of efficiency of the site reduces the further away from
the connection it lies. In addition, land ownership is also a notable consideration as without a
willing landowner, a development cannot take place. The applicant has identified a search
area of a 1.1km radius of the Windyhill sub-station and notes that no sites outwith the Green
Belt are available to allow this grid connection to be utilised.
Having considered the additional information from the applicant, it is identified that the location
of this development is dictated by the available grid connection at Windyhill sub-station and
that no alternative locations outwith the Green Belt are available without requiring a
connection over a large distance. It is therefore accepted that there is a locational requirement
to site the development within this Green Belt location to allow the available grid connection to
be utilised.
Policy 8 of NPF4 goes on to require developments not to undermine the Green Belt, be
compatible with the surrounding landscape, have an appropriate scale, massing and
appearance and ensure no significant long-term impacts. The Council concluded that the
revised proposal considered in it’s consultation response of 13th December was acceptable
with reference to the scale of the development, landscape and visual impact, landscape
screening and the separation from the settlement boundary of Faifley. The Council set out in
the previous response that the development is no longer considered to be viewed in the
context of the adjacent settlement. An industrialisation of the Green Belt at this location was
also not 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.
Overall, it is considered that the Green Belt location has been adequately justified and the
impact within the Green Belt can be considered acceptable with reference to Policy 8 of NPF4.
Ecology, biodiversity and protected species
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 also requires biodiversity impact to be addressed. The applicant’s preliminary
ecological appraisal was previously considered by the Council’s Biodiversity Officer and this
failed to identify the adjacent LNCS 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.  Accordingly, the Council did not consider that the
proposal could be held to be supported by Policies 3, 4 or 11(e)(ix) of NPF4.
The applicant has provided an updated preliminary ecological appraisal which now considers
the three LNCS within the West Dunbartonshire area adjacent to the site; Wester Cochno
Parkland, Wester Cochno Burn and Edinbarnet Woodland. The appraisal sets out an
understanding of the interest features, species and reasons for the designation together with
the potential cross boundary impacts from the development. The Council’s Biodiversity officer
has considered the updated submission and is satisfied that the three LNCS locations have
now been included and considered and the applicant. The Biodiversity Officer further
acknowledges that consideration has been given to the potential for watervole within
watercourses which was specifically highlighted by the Council in the original consultation

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response, together with a general requirement for pre-construction surveys. It is therefore
considered that the concerns regarding the lack of consideration of the three LNCSs within the
West Dunbartonshire area and potential for cross boundary impacts is addressed.
The original consultation response also set out the advice from the Councils Biodiversity
Officer that West Dunbartonshire Council has undertaken a two year nature restoration project
within the area known as Auchnacraig Estate (which is comprised of the three LNCS above),
and on Faifley Knowes to the south.  Both Auchnacraig and Faifley have now been connected
by a new native woodland which straddles the hillside to the east of Douglas Muir Road.  This
has created an integrated habitat which connects the urban environment to wider Green Belt
and the Kilpatrick Hills LLA. The Council’s Biodiversity Officer further advised that to the
northwest of the site, Glasgow University at Cochno Farm have also been carrying out a
number of nature restoration works including a large scale planting programme as well as a
private forestry grant development north of Duntocher. Collectively all the work put in by the
various agencies in this location has resulted in landscape and nature restoration around the
proposed development site. The woodland will have a positive effect on the surrounding
environment as it will provide a reservoir of species which can migrate into surrounding areas
when conditions are suitable.
Should the Scottish Ministers be minded to grant consent for the development, the Council
requests that they satisfy themselves that the final detail of the proposed landscape mitigation
and planting compliments the work in the surrounding area set out above. This includes
ensuring that in terms of biodiversity enhancement, areas which currently comprise a mixed
habitat and wet and marshy sections are not given over to inappropriate tree planting solely
under the role of biodiversity enhancement, as these are valuable habitats of their own accord.
Overall, the applicant’s updated preliminary ecological appraisal has been considered by the
Council’s Biodiversity Officer and now satisfactorily considers the adjacent LNCS within West
Dunbartonshire and assess the potential cross boundary impact upon ecology, biodiversity
and protected species within West Dunbartonshire. It can therefore now be concluded that
significant adverse impacts should not occur within the West Dunbartonshire area.  The
proposal can therefore be considered acceptable with reference to Policies 3, 4 and 11(e)(ix)
of NPF4.
Site Decommissioning and Restoration
Policy 11(e)(xi) of NPF4 requires matters relating to the decommissioning of developments,
including ancillary infrastructure, and site restoration to be addressed. The applicant has
indicated that the intended lifetime of the proposal is 40 years, after which the facility will be
decommissioned and the land restored to its former state. However, it was identified in the
Council’s previous responses that no other information regarding this has been submitted and
this raised concerns.  
As previously noted, the applicant’s Supporting Statement sets out that at the end of the
operational period the site will be decommissioned and the land restored to it’s former state.
The updated LVIA also advises that following the completion of the operational phase, the
components of the battery storage may be removed and landscape effects potentially
reversed. Whilst there is thus a commitment from the applicant, it remains that there is a
question over the extent of any decommissioning and a clear commitment to the approach to
decommissioning and restoration.
In response to the concerns raised, the applicant has set out that that is common practice for
decommissioning of such sites to be addressed by condition with detailed decommissioning
information and a restoration bond to be agreed prior to the commencement of any works on
site. Examples of other, similar development proposals which have consented by the Scottish
Ministers within Renfrewshire are given, and these take such an approach. The Council

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further notes that for a recently consented development in Inverclyde, the same approach was
also taken. 
It remains the Council’s preference that that given the type of development together with its
size and location, that details of the approach to decommissioning and site restoration is
provided to ensure that the requirements of Policy 11(e)(xi) of NPF4 are met. Thereafter, the
detail and implementation of the decommissioning and restoration scheme can be addressed
by condition. It is, however, accepted that such a position is as odds with the approach taken
by the Scottish Ministers in determining similar developments. It is disappointing that it
appears to be established practice that the approach to decommissioning and site restoration
is addressed by condition rather than being considered up front. 
The Council considers that any restoration scheme would require to be of an extent that
achieves a complete reversal of any landscape harm that occurs.  Given the extensive cut and
fill proposed to accommodate the development, the restoration would require to include
substantial ground works to ensure the restoration of the landform to its original profile
following the removal of all hardstanding, infrastructure and equipment. In the event that the
Scottish Ministers are minded to grant consent for the development, a robust condition(s) to
address all aspects of site decommissioning and restoration would be required, and the
Council would expect any such condition(s) to be clear that the decommissioning and
restoration scheme must ensure the complete removal of all aspects of the development and
the restoration of the landform within the site to its current pre-development profile.
The Council also considers that in the event that the development fails to export electricity to
the grid for a continuous period of 12 months it will be considered to have become redundant
and the components of the development removed and the site restored. In the event that
consent was granted, the Council considers it essential that that this requirement is to be
addressed by a condition.
In the event that the Scottish Ministers were minded to grant consent for the development, the
Council further considers that there is the requirement for a financial bond to ensure sufficient
funds are available to decommission and restore the site. If the developer was to go out of
business with unfinished works potentially being left this can be safeguarded by ensuring that
a bond or other financial provision is to put in place to cover such an eventuality. The bond or
other financial provision would address reinstatement works both in the event of a developer
failing or being unable to complete restoration works together with any failure in the aftercare
arrangements associated with the site restoration.
Whilst the Council’s preference remains for the approach to decommissioning and site
restoration to be provided upfront with the the detail and implementation of the de-
commissioning 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 accepted that the
decommissioning and site restoration can be secured by condition. Any such condition(s)
must be suitably robust to ensure that the de-commissioning and site restoration scheme
results in the complete removal of all aspects of the development and the restoration of the
landform within the site to its current pre-development profile. A condition relating to the
decommissioning of the site should it cease to export electricity to the grid for in excess of 12
months is also required as is a bond or other financial provision to provide sufficient funds for
the decommissioning and restoration of the site should such be required. With such an
approach, the Council would consider that the development meets the requirements Policy
11(e)(xi) of NPF4.

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Landscape and Visual Impact, Residential Amenity, and the Impact on the Core Path Network
The Council’s position on these matters remains as per the response dated 13th December
2024.
Impact upon the Kilpatrick Hills, Traffic and Road Safety, Flood Risk, Built and Cultural
Heritage, and Health and Safety
The Council’s position on these matters remains as per the response dated 13th May 2024.
Summary and conclusions
As set out in the Council’s most recent consultation response dated 13th December 2024,
concerns remained in respect of the Green Belt location not being justified, the impact upon
ecology, biodiversity and protected species, and the lack of an approach to de-commissioning
and site restoration. 
Considering the Green Belt location, the applicant has provided additional details to justify the
Green Belt location and why there are no suitable sites for this development outwith the Green
Belt. The Green Belt location is required to take advantage of the availability of a grid
connection at Windyhill sub-station. The distance of such developments from the grid
connection is also an important consideration as the level of efficiency of the site reduces the
further away from the connection it lies. Accordingly, the applicant has identified a 1.1km
search area from the available connection in which no suitable sites exist outwith the Green
Belt. It is now considered that the Green Belt location has been adequately justified, there are
no suitable sites outwith the Green Belt which can take advantage of this connection and the
impact within the Green Belt can be considered acceptable with reference to Policy 8 of NPF4.
Turning to the impact upon ecology, biodiversity and protected species, the applicant’s
updated preliminary ecological appraisal has been considered by the Council’s Biodiversity
Officer and now satisfactorily considers the adjacent LNCS within West Dunbartonshire and
assesses the potential cross boundary impact upon ecology, biodiversity and protected
species within West Dunbartonshire. It can therefore be concluded that significant adverse
impacts should not occur within the West Dunbartonshire area. Whilst it is expected that the
Scottish Ministers fully consider the appropriateness of the proposed planting and landscape
mitigation within the site and ensure that it compliments the surrounding area, the Council is of
the view that the proposal can now considered acceptable with reference to Policies 3, 4 and
11(e)(ix) of NPF4.
Finally, whilst the Council preference remains for the approach to de-commissioning and site
restoration to be provided upfront with the detail and implementation of the de-commissioning
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 accepted that the de-commissioning
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 current pre-development 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, the Council would consider that the development meets the requirements Policy
11(e)(xi) of NPF4.
Following a full assessment of the further and updated details relating to the Council’s
outstanding concerns which formed the previous objection, it is concluded that these concerns
have now been addressed satisfactorily.  Whilst the Council no longer objects to the proposal,

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a variety of points are, however, set out in this response together with the two previous
responses dated 13th December 2024 and 13th May 2024 and it is expected that the Scottish
Ministers fully consider and address these in the event that they are minded to grant consent.
For the avoidance of doubt, all three responses require to be read in conjunction with each
other.