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Ylem Energy Ltd: Construction and Operation of a Battery Energy Storage System (Bess) with Ancillary Infrastructure: Ardencaple Farm, Rhu, Helensburgh (Ref: 23/02472/Pp)

Argyll and Bute Council · 23 October 2024
Back to Planning, Protective Services and Licensing Committee — 23 October 2024 and its agenda

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LDP2 format template March 4th 2024
Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 
Classification: OFFICIAL 
Argyll and Bute Council
Development & Economic Growth   
Planning Application Report and Report of Handling as required by Schedule 2 of the
Town and Country Planning (Development Management Procedure) (Scotland)
Regulations 2013 relative to applications for Planning Permission or Planning
Permission in Principle 
Reference No: 23/02472/PP
Planning Hierarchy: Major Application
Applicant: Ylem Energy Ltd
Proposal: Construction and operation of a battery energy storage system
(BESS) with ancillary infrastructure
Site Address:  Ardencaple Farm, Rhu, Helensburgh  
DECISION ROUTE 
☐Delegated - Sect 43 (A) of the Town and Country Planning (Scotland) Act 1997 
☒Committee - Local Government Scotland Act 1973 
(A)  THE APPLICATION 
(i) Development Requiring Express Planning Permission
• 49.9MW of modular battery units with ancillary equipment (6.1m x 2.5m x
2.9m finished in a matt off white).
• Inverters (9.8m x 5.0m x 2.3m finished in matt off white).
• DNO substation (7.5m x 2.8m x 3.2m finished in matt dark green).
• Switchroom (12.3m x 3.3m x 3.4m raised on 1m stilts finished in matt dark
green).
• Site and welfare office (7.5m x 2.3m x 2.9m finished in matt dark green).
• Site transformer (3.3m x 2.3m x 3.2m finished in matt dark grey).
• Provision of 2 No. on site water towers 
(ii) Other specified operations
• Formation of internal access road 
• Provision of passing places and works to external access road
• Landscaping 
(B) RECOMMENDATION: 
That Planning Permission be refused for the reasons detailed in this report. 
(C) CONSULTATIONS:   
A&B Roads :  Dated (27.03.24, 23.04.24 & 30.08.24):  Objection.
A&B Environmental Health: (Dated 24.09.2024):  Holding Objection. (Lack of  
information on noise generation characteristics of actual plant to be installed within
submitted Noise Report)
A&B Biodiversity Officer: Dated (26.09.24). No objection subject to conditions.
A&B Emergency Planning:     No response

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LDP2 format template March 4th 2024
Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 
Classification: OFFICIAL
A&B Flooding and Drainage:  Dated ( 27.03.24) No Objection
SEPA : No response
NatureScot :                   Dated (08.03.24) No Comment Offered
Scottish Fire and Rescue : Dated (27.03.24) No Objection. (technical
requirements)
Rhu and Shandon CC :  Dated  (23.04.24) Objection
Helensburgh CC :           Dated (29.07.24) Objection
Network Rail : Dated (11.04.24 & 08.05.24) No Objection subject to conditions 
(D) HISTORY:  Y
23/01276/PAN :  Installation of 50Mw Battery Energy  Storage System
24/00674/SCREEN : Installation of 50Mw Battery Energy  Storage System . No EIA
required. 
(E) PUBLICITY:  Yes 
Reg 20  Press Notice. Expired 04.04.24 
(F) REPRESENTATIONS:  Yes 
The application at time of writing has received 63 Objections, One submission in support
and three representations. A petition with 36 signatures objecting to the proposals has also
been submitted. A full list of these is contained at Appendix B of this Report .  All third party
submissions are published in full on the planning application file and are available to view
via the Public Access section of the Council’s website. 
Members are requested to note that Jackie Baillie MSP forwarded a number of objection
letters on behalf of her constituents. All of these have been recorded as objections and are
Public Access at the link above. For clarity, no objection by Jackie Baillie MSP has been
lodged.
(i) Summary of matters in Submission of Support
• Proposal should be fully supported if we want to have a greener future
•  Battery Energy Storage an essential part of green energy delivery 
(ii) Summary of objections raised: 
• Alternative Site Assessment exercise is flawed in omitting any land in the National
Park. No reason to exclude land in national park within 3km radius site search as
there is no presumption against BESS proposals in National Parks. No compelling
argument has been made to justify why the development needs to be located inside
the greenbelt and so close to a site with specific ecological designations. 
• No evidence provided to show major local landowners in area were not willing to
accommodate the BESS proposals on other land. Landowners/Estates have already
shown willing to accommodate BESS proposals on their land and no evidence to
show they were not willing to engage on their land provided in site selection
justification submissions. Glen Fruin or beside the recycling centre at Blackhill would
be a better location for this use.
• This is not an acceptable use within the Green Belt and is contrary to Planning Policy
in relation to acceptable uses in the greenbelt.
• No clarification on how connection will be made to Substation at Glen Fruin.
Understood from consultation that a cable will be laid along Paterson Drive, Duchess
Street, Queen Drive, Queen Street and Sinclair Street. This will cause significant
disruption. Actual linkage distance is over 3km so site not viable by applicants own
site selection criteria.

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LDP2 format template March 4th 2024
Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 
Classification: OFFICIAL
• Submissions by applicant accept Green Belt and visual impact will not be mitigated
by trees which will take 10-15 yrs to have any significant impact
• Industrial scale development will detract from enjoyment of Duchess Wood and hum
from the operation of the BESS even when not in use will have an adverse impact
on the ability to enjoy the woodland for wellbeing and also disturb wildlife, particularly
Bats in the woods which are European Protected Species.
• Proposed access arrangements appear unsatisfactory after Patterson Drive ends.
Access proposed does not follow draft guidance in National Fire Chief’s Council
recommendations on access arrangements for BESS facilities. 
• Any fire at the battery scheme would require the closure of the railway line due to its
proximity and be harmful to the economy as this is a main line connection. Also the
nearest mains connection is some 1 km away in Paterson Drive to supplement the
water to be stored on site in the water tank
• Construction Traffic Management Plan fails to adequately address potential hazards
associated with the local access regime with insufficient passing places to allow
construction vehicles to safely interact with walkers, horse riders, cyclists etc who
regularly use the access track.  It also fails to reference the core path status of the
access track from Peterson Drive. Access track wholly unsuitable for construction
traffic and parking associated with construction workers likely to cause disruption to
residents and danger for children
• Construction of site will leave the area an eyesore due to machinery churning up
access and roads and will be a safety hazard to school children and other residents.
• BESS will be visible from core path network in Duchess Woods. The woods are
widely used by residents, schools for nature studies and Nursery school nature trips. 
The BESS proposals will adversely impact on the enjoyment of the woods.
• Proposals would destroy the local landscape
• Batteries likely to need replaced at end of operational life. Concerns over
environmentally sound method of disposal.
• Some of the documents are classified as preliminary/outline/proposed and are not
specific on what is being installed and what the risks are. These details are to be
determined at construction stage. This gives “remarkable” freedom to developer.
Concerned. It is also stated that further noise assessments will be needed as the
actual technology to be used not specified in the noise report.
• Concerned about the noise this proposal will generate. Particularly at nighttime.
Concerned the submitted Noise Report underplays impact that noise will have on
residents using their gardens and those using the core path to the north of Duchess
Woods. Unit will give out a constant hum detrimental to the amenity of the area and
enjoyment of Duchess Woods. Train noise comes and goes the BESS will always
be making a noise.
• Proposals fails to provide any local community benefits as required under NPF 4
Policy 11 (c) related to Energy Developments
• Facility, including the battery units, switch room and lighting columns will all be
visible from within Duchess Woods to the detriment of its natural setting and amenity
• Additional noise measurements should be taken from the footpath below the
proposed development within Duchess Woods. 
• Friends of Duchess Woods Confirm that there are Bats within the adjoining
woodlands which could be adversely impacted by the operation of the development.
• Borehole data is old and it is unclear if the proposed drainage mitigation measures
will cope and be able to contain all water within the site and not adversely impact on
watercourses and footpaths below the site. Fresh surveys and information on these
matters should be submitted.
• Lighting and noise from use proposed could adversely impact upon wildlife in the
area. ( reference to lighting/motion sensors and bats in adjoining woodland)

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LDP2 format template March 4th 2024
Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 
Classification: OFFICIAL
• Does not comply with policies of development plan and adverse impacts are not
outweighed by national need and in principle support for renewables which have
zero benefits for the local community.
• Concerns that Biodiversity net gain not addressed (Officer Note* Additional
submissions were made on this matter by applicant after objection lodged).
Officer Comment : The objections as set out above are considered capable of being material
planning considerations and these matters are addressed in the Officer report. However,
the following matters raised are not considered to material planning considerations which
should be given weight in the determination of the proposals as set out below;
• There is a fire risk and health and safety issue due to toxic gasses released in the
event of a fire with such developments which should not be near residential
properties.
• Network Rail have raised issues over access being allowed under the rail bridge for
the use proposed.
• A full EIA is required to properly evaluate the proposal.
• Treatments to maintain landscaping could adversely impact through washout from
the site and adversely impact upon Duchess Woods which is a Local Nature
Reserve
• Use of Lithium Batteries will create an unacceptable risk to trains and those who use
footpaths in the area.
• Concerns over the PAN commitments not being adhered to, and residents not being
consulted with a 750m Radius of the site. (Officers note that the party involved
attended one of the PAC consultation events).
• The proposal is speculative and ill considered. 
(G) SUPPORTING INFORMATION 
Has the application been the subject of: 
(i) Environmental Impact
Assessment Report:
☐Yes ☒No 
(ii) An Appropriate Assessment
under the Conservation (Natural
Habitats) Regulations 1994:   
☐Yes ☒No 
(iii) A Design or Design/Access
statement:   
☒Yes ☐No 
Green belt Location
Access to Site
Scale and Nature of Proposals  
(iv) Sustainability Checklists (with reference to the requirements of LDP2
Policy 04) 
TN06 Sustainability
Checklist
TN07 Sustainable
Buildings Checklist
☒Yes ☐No
☐Yes ☒No  
(v) A report on the impact of the
proposed development e.g.
Retail impact, transport impact,
☒Yes ☐No

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LDP2 format template March 4th 2024
Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 
Classification: OFFICIAL
noise impact, flood risk,
drainage impact etc:  
• Planning Statement (including
Design and Access
Statement)
• Pre-Application Consultation
report (PAC)
• Landscape and Visual
Appraisal (LVIA)
• Green Belt Justification
• Heritage Assessment
• Lighting Assessment
• Noise Assessment
• Ecological Appraisal Report
• Outline Construction
Environment Management
Plan
• Outline Construction Traffic
Management Plan
• Battery Safety Report
• Outline Battery Safety
Management Plan
• Heat Flux Study
• Drainage Assessment
• Flood Risk Assessment
• Alternative Site Assessment
• Economic Benefits Statement 
(H) PLANNING OBLIGATIONS 
Is a Section 75 agreement required:   ☐Yes ☒No 
(I) Has a Direction been issued by Scottish Ministers in terms of Regulation 30,
31 or 32:  ☐Yes ☒No 
(J) Section 25 of the Act; Development Plan and any other material considerations
over and above those listed above which have been taken into account in the
assessment of the application. 
(i)  List of all Development Plan Policy considerations taken into account
in assessment of the application. 
National Planning Framework 4 (Adopted 13th February 2023) 
Part 2 – National Planning Policy 
Sustainable Places
NPF4 Policy 1 – Tackling the Climate and Nature Crises
NPF4 Policy 3 – Biodiversity

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LDP2 format template March 4th 2024
Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 
Classification: OFFICIAL
NPF4 Policy 7 – Historic Assets and Places
NPF4 Policy 8 – Greenbelts
NPF4 Policy 11 – Energy 
Liveable Places
NPF4 Policy 23 – Health and Safety (Criteria e - Noise) 
Productive Places
NPF4 Policy 25 – Community Wealth Building 
Argyll and Bute Local Development Plan 2 (Adopted 2024) 
Spatial and Settlement Strategy
Policy 02 – Outwith Settlement Areas (Part C Helensburgh Greenbelt) 
High Quality Places
Policy 06 – Green and Blue Infrastructure
Policy 08 – Sustainable Siting
Policy 10 – Design – All Development
Policy 14 – Bad Neighbour Development 
Policy 15 – Protection, Conservation and Enhancement of Our Historic Environment 
Diverse and Sustainable Economy
Policy 30 – The Sustainable Growth of Renewables 
Connected Places
Policy 35 - – Design of New and Existing, Public Roads and Private Access Regimes
Policy 37 – Development Utilising an Existing Private Access or Existing Private        
Road
Policy 39 – Construction Standards for Private Access 
Sustainable Communities
Policy 55 – Flooding
Policy 59 -  Water Quality and the Environment
Policy 61 – Sustainable Urban Drainage Systems (SUDS)
Policy 62 – Drainage Impact Assessments 
High Quality Environment
Policy 73 – Development Impact on Habitats, Species and Biodiversity.
Policy 76 – Development Impact on Local Nature Conservation Sites (LNCS) 
Local Development Plan 2 Schedules 
(ii)  List of all other material planning considerations taken into account in
the assessment of the application, having due regard to Annex A of
Circular 3/2013. 
• Scottish Energy Strategy: The future of energy in Scotland (“the Energy
Strategy”) Draft Scottish Energy Strategy and Just Transition Plan 2023
• Scottish Government Climate Change Plan 
(K) Is the proposal a Schedule 2 Development not requiring an Environmental
Impact Assessment:  ☒Yes  24/00674/SCREEN. No EIA required.

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LDP2 format template March 4th 2024
Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 
Classification: OFFICIAL  
(L) Has the application been the subject of statutory pre-application consultation
(PAC):  ☒Yes   
PAC Report Submitted with application. Report states main issues identified through
Community Consultation exercise were: 
• Location: including within Green Belt, open countryside, available            
alternatives, closer to the electricity substation.
• Access: including passing through residential area, the low railway bridge,
steep track and use of track by other users such as walkers and horses.
• Grid connection: how will this be achieved and impact on local residents.
• Wildlife: including noise, visual, impact on Duchess Wood.
• Safety both in terms of construction safety and operational safety and how
will an emergency be dealt with. 
(M) Does the Council have an interest in the site:  ☐Yes ☒No 
(N) Requirement for a pre-determination hearing: ☐Yes ☒No 
This application has attracted 63 letters of objection. In addition, both Helensburgh
and Rhu and Shandon Community Councils have objected to this application. 
Whilst, there is strong policy support within NPF 4 Policy 11 and LDP 2 Policy 30 for
energy related proposals such as this BESS scheme to be supported, officers
consider that there are three reasons for the refusal of this application relating to the
lack of justification for this greenbelt location and the adverse landscape and visual
impacts on the greenbelt, the lack of a suitable vehicular access to the site and
insufficient information relating to noise impacts. 
It is considered that Members have sufficient information within the report to enable
them to determine this application.  In these circumstances it is not considered that
a pre-determination Hearing would add value to the process. 
(O)(i) Key Constraints/Designations Affected by the Development:
• Helensburgh Green Belt
• Duchess Woods Local Nature Conservation Area
(O)(ii) Soils
Agricultural Land Classification:  Class  4.2 Grazing Land
Peatland/Carbon Rich Soils Classification: ☐Class 1
☐Class 2
☐Class 3
☒N/A
Peat Depth Classification:  N/A  
Does the development relate to croft land? ☐Yes ☒No
Would the development restrict access to croft
or better quality agricultural land?
☐Yes ☒No ☐N/A
Would the development result in
fragmentation of croft / better quality
agricultural land?
☐Yes ☒No ☐N/A

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LDP2 format template March 4th 2024
Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 
Classification: OFFICIAL 
(O)(iii) Woodland  
Will the proposal result in loss of
trees/woodland?
(If yes, detail in summary assessment)
☐Yes
☒No 
Does the proposal include any replacement or
compensatory planting?
☒Yes Landscaping Mitigation Plan with
Biodiversity Enhancement 
☐No details to be secured by condition
☐N/A  
(O)(iv) Land Status / LDP Settlement Strategy
Status of Land within the Application
(tick all relevant boxes)
☐Brownfield
☐Brownfield Reclaimed by Nature
☒Greenfield 
ABC LDP2 Settlement Strategy
(tick all relevant boxes) 
☐Settlement Area
☐Countryside Area
☐Remote Countryside Area
☒Helensburgh & Lomond Greenbelt
ABC LDP2 Allocations/PDAs/AFAs etc: 
N/A 
(P) Summary assessment and summary of determining issues and material
considerations
The application submission has in the opinion of officers failed to demonstrate that a
greenbelt location is essential for the location of the development due to the exclusion of all
greenfield land within the Loch Lomond and the Trossachs National Park Area at an early
stage in the site search exercise. This has resulted in the identification of a site, within a
sensitive greenbelt location some 2.7km from the required substation connection point on
the edge of the settlement of Helensburgh. Officers therefore consider insufficient
justification to prove the need to locate the development within the Helensburgh Greenbelt
has been provided by the applicant.   
In addition, the field within which the development is proposed to be located, forms an
integral and important part of the greenbelt at this point, framing the settlement of
Helensburgh and providing an open context for attractive and important views of the town
and beyond to the Clyde Estuary. Officers consider the quality of this view to be extremely
high and therefore its sensitivity to adverse impact is also high. The proposed development
would unacceptably undermine the function and openness of the greenbelt at this point by
introducing industrial scale development. 
The application fails to provide either a private access road to the site, or an access track
within the site to the BESS facility to an acceptable and safe standard for emergency
services access. The Area Roads engineer considers that the proposed access
arrangements are unacceptable and contrary to LDP 2 Policies 35, 37 and 39 of Argyll and
Bute Local Development Plan 2. In addition, the proposed access arrangements fail to meet
the desired guidelines and standards of the Scottish Fire and Rescue Services to access
such facilities as set out in their consultation response to this application. 
The submitted noise report fails to provide sufficient confidence to  Environmental Protection
Officers that there will not be any adverse noise impacts on surrounding area which includes

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LDP2 format template March 4th 2024
Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 
Classification: OFFICIAL
residential properties.  Adequate details have not been provided within the submitted Noise
Impact Assessment. The proposals are therefore considered to be contrary to LDP 2 Policy
14 amenity safeguarding objectives in respect of potential noise impacts. 
However, given that the proposal is for essential energy infrastructure which contributes to
addressing the Climate emergency and the objectives of NPF4 Policy 1, it must be
acknowledged in the decision-making process that there is strong policy support for such
proposals. As this recommendation to refuse the current application is a matter of officers
balancing competing policy objectives, it is essential that the strong policy support for such
proposals is also considered as set out in LDP2 Policy 30 and NPF 4 Policy 11 in coming
to a Planning decision in this case. This is not in Officers opinion a clear-cut matter, and the
significance of the contended and potential adverse impact, non-compliance with roads
Standards and inadequate noise information submission,  must be considered in the
balance against this strong Energy Policy support for such proposals.   
(Q) Is the proposal consistent with the Development Plan: ☐Yes ☒No 
(R) Reasons why Planning Permission or Planning Permission in Principle Should
be Refused: 
Unacceptable Adverse Impact on Helensburgh Green Belt. 
1. The proposed development by nature of its scale. appearance and location will introduce
development of an industrial character and appearance into a sensitive and important
greenbelt location. contrary to LDP 2 Policies  02 and 30, and NPF 4 Policies 8 and 11.   
More particularly,
a) The application submission has failed to demonstrate that a greenbelt location is
essential for the location of the development due to the exclusion of all greenfield
land within the Loch Lomond and the Trossachs National Park Area at an early stage
in the site search exercise. This has resulted in the identification of a site, within a
sensitive greenbelt location some 2.7km from the required substation connection
point on the edge of the settlement of Helensburgh. Officers therefore consider
insufficient justification to locate the development within the Helensburgh Greenbelt
has been provided by the applicant.  
b) In addition, the field within which the development is proposed to be located,  forms
an integral and important part of the greenbelt in framing the settlement of
Helensburgh and providing an open context for attractive and important views of the
town and beyond to the Clyde Estuary. Officers consider the quality of this view to
be extremely high and therefore its sensitivity to adverse impact is also high. The
proposed development would unacceptably undermine the function and openness of
the greenbelt at this point by introducing industrial scale development. 
By nature of the above matters set out at (a) and  (b) the proposal is considered to
be contrary to NPF 4 Policy 8 and LDP 2 Policy 02. 
Substandard Access  Roads and Site Access Road for Emergency Service
Vehicles 
2. The application fails to provide either a private access road to the site, or an access track
within the site to the BESS facility to an acceptable and safe standard for emergency

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LDP2 format template March 4th 2024
Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 
Classification: OFFICIAL
services access. The Area Roads Engineer considers that the proposed access
arrangements are unacceptable due to the unsatisfactory intervisibility and width of the
private access road to the site, and unacceptable gradients on the proposed internal
access road within the site contrary to LDP 2 Policies  35, 37 and 39 of Argyll and Bute
Local Development Plan 2. 
In addition, the proposed access arrangements fail to meet the desired guidelines  and
standards of the Scottish Fire and Rescue Services to access such facilities as set out
in their consultation response to this application. More particularly the proposals fail to
provide at least two separate access points to the site to account for opposite wind
conditions/directions, a perimeter road or roads with passing places for fire service
vehicles to an adequate standard, or access arrangements with no extremes of gradient. 
Noise Generation and Potential Amenity Impacts 
3..The submitted noise report fails to provide sufficient confidence to Environmental
Protection Officers that there will not be any adverse noise Impacts on surrounding area
which includes residential properties.  Adequate details have not been provided within
the submitted Noise Impact Assessment. The proposals are therefore considered to be
contrary to LDP 2 Policy 14  amenity safeguarding objectives in respect of potential noise
impacts. 
(S) Reasoned justification for a departure to the provisions of the Development
Plan 
N/A 
(T) Need for notification to Scottish Ministers or Historic Environment Scotland:
☐Yes ☒No 
Author of Report: David Moore Date: 07.10.2024 
Reviewing Officer: Sandra Davies Date: 09.10.2024 
Fergus Murray
Head of Development & Economic Growth

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Classification: OFFICIAL 
REASONS FOR REFUSAL RELATIVE TO APPLICATION REF. NO. 23/02472/PP 
1. Unacceptable Adverse Impact on Helensburgh Green Belt. 
The proposed development by nature of its scale. appearance and location will
introduce development of an industrial character and appearance into a sensitive and
important greenbelt location. contrary to LDP 2 Policies  02 and 30, and NPF 4 Policies
8 and 11.  
More particularly,
a) The application submission has failed to demonstrate that a greenbelt location
is essential for the location of the development due to the exclusion of all
greenfield land within the Loch Lomond and the Trossachs National Park Area
at an early stage in the site search exercise. This has resulted in the
identification of a site, within a sensitive greenbelt location some 2.7km from
the required substation connection point on the edge of the settlement of
Helensburgh. Insufficient justification to locate the development within the
Helensburgh Greenbelt has been provided by the applicant.  
b) In addition, the field within which it  the development is proposed to be located, 
forms an integral and important part of the greenbelt in framing the settlement
of Helensburgh and providing an open context for attractive and important
views of the town and beyond to the Clyde Estuary. The quality of this view is
considered to be extremely  high and therefore its sensitivity to adverse impact
is also high. The proposed development would unacceptably undermine the
function and openness of the greenbelt at this point by introducing industrial
scale development. 
By nature of the above matters set out at (a) and (b) the proposal is considered to be
contrary to NPF 4 Policy 8 and LDP 2 Policy 02. 
2. Substandard Access Roads and Site Access Road for Emergency Service
Vehicles 
The application has failed to provide either a private access road to the site, or an
access track within the site to the BESS facility to an acceptable and safe standard
for emergency services access. The proposed access arrangements are
unacceptable due to the unsatisfactory intervisibility and width of the private access
road to the site, and unacceptable gradients on the proposed internal access road
within the site contrary to LDP 2 Policies  35, 37 and 39 of Argyll and Bute Local
Development Plan 2. 
In addition, the proposed access arrangements fail to meet the desired guidelines 
and standards of the Scottish Fire and Rescue Services to access such facilities
as set out in their consultation response to this application. More particularly the
proposals fail to provide at least two separate access points to the site to account
for opposite wind conditions/directions, a perimeter road or roads with passing
places for fire service vehicles to an adequate standard, or access arrangements
with no extremes of gradient. 
3. Noise Generation and Potential Amenity Impacts 
The applicant has failed to provide sufficient information to satisfy the planning
authority that there will not be any adverse noise Impacts on the surrounding area
which includes residential properties.  Adequate details have not been provided within

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LDP2 format template March 4th 2024
Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 
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the submitted Noise Impact Assessment. The proposals are therefore considered to
be contrary to LDP 2 Policy 14  amenity safeguarding objectives in respect of potential
noise impacts.

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COMMITTEE REPORT
APPENDIX A – RELATIVE TO APPLICATION NUMBER:  REF: 23/02472/PP 
PLANNING LAND USE AND POLICY ASSESSMENT 
1. Settlement Strategy 
1.1. The application site is situated within the Helensburgh Green Belt where stricter controls
over both the type of development which is allowed is exercised as per LDP 2 Policy 02
and NPF 4 Policy 8. These policies also clarify the need to ensure that where a
development is acceptable on point of principle within a greenbelt location, there requires
to be a justification as to why the development has to locate in the greenbelt and further
that where this has been demonstrated that no unacceptable impacts upon the greenbelt
will occur. It is considered helpful to refer to the main elements of both policies at this
point for ease of reference and to assist in the settlement strategy policy evaluation
process for such proposals within a greenbelt location. 
1.2. The starting point for the evaluation of the proposals in respect of their greenbelt context
is to ask whether the proposals are “essential infrastructure” which can be located within
the greenbelt as a point of principle. It is perhaps useful to provide some context as to
how BESS proposals should be regarded in terms of their role in meeting climate change
objectives and therefore be regarded as essential infrastructure. 
1.3. A recent S36 decision of the Scottish Ministers on a  BESS proposal usefully clarifies the
role BESS can  make to addressing the climate emergency and achieving net zero targets
as set out in NPF 4 Policy 1; 
The generation of electricity from batteries is not in itself a renewable source of energy;
Scottish Ministers do however regard the proposed Development as essential
infrastructure. The proposed Development, through provision of energy storage, adds
flexibility and resilience necessary to maintain secure and reliable supplies of energy to
all of our homes and businesses as our energy transition takes place. Scottish Ministers
conclude that the proposed Development is supported by the Energy Strategy… The Draft
Scottish Energy Strategy and Just Transition Plan 2023 signals that strong support from
the Scottish Government for battery storage remains. 
1.4. Therefore, although officers consider that BESS proposals can properly be regarded as
essential infrastructure related to facilitating the important objectives addressing climate
change and achieving net zero objectives, it is also necessary to ensure compliance with
LDP Policy 02 and NPF 4 Policy 8 in respect of greenbelt development. 
1.5. Both NPF 4 and LDP 2 policies require that application proposals within the greenbelt
demonstrate a need to be located within the greenbelt. NPF 4 Policy 8 clarifies that as
well as comprising essential infrastructure (which is accepted by officers) proposals must
also ensure 
ii) the following requirements are met: 
• reasons are provided as to why a green belt location is essential and why it
cannot be located on an alternative site outwith the greenbelt;

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1.6. LDP 2 Policy 02 also clarifies that: 
Within the Helensburgh and Lomond Green Belt development will only be supported
where this is appropriately designed, located and landscaped and comprises. 
• Development directly supporting the provision of essential infrastructure with a
demonstrable need to be located within the Green Belt. 
1.7. In order to justify the location of the BESS proposal within Helensburgh Green Belt
additional submissions clarifying why the current greenbelt site was chosen have been
submitted by the applicant and a sequential alternative site assessment report dated July
2024 has been provided. Page 8 of the submitted supporting statement confirms that “In
this case it was identified that the Helensburgh Grid Supply Point, located roughly 2700m
North-East of the Proposed Development Site, had the capacity to support a 50MW
connection. 
1.8. Officers note from this submission that all greenfield land within the Loch Lomond and the
Trossachs National Park  was excluded on point of principle from the search parameters,
and an area of land on the edge of the greenbelt some 2.7km away has been identified
as the best location for the BESS facility by this evaluation approach. It is the opinion of
officers that this site search information does not provide sufficient justification on the
need for a  greenbelt location for this development in accordance with policy requirements
as all greenfield land within the National park has been excluded. No evidence as to why
this is a justified approach has been provided. 
1.9. There is no policy presumption against BESS proposals within a National Park as shown
by the approval of such a scheme by Cairngorms National Park Authority of Detailed
Planning Permission 2022/0069/DET (22/00601/FUL)  for Construction of battery energy
storage facility (49.9MW), control building, switch room, battery storage containers,
inverter containers, landscaping and associated works. 
1.10. Officers do not seek to compare the merits or the detailed evaluation of the current
proposal and the approved proposal. However, this approval does raise fundamental
questions as to why all greenfield land within the National Park, which is in closer proximity
to the required substation connection point, and would appear to be less sensitive, was
excluded from the search parameters at such an early stage in the sequential evaluation
exercise. 
1.11. Added to this omission, the sensitivity and importance of the greenbelt location proposed,
with its proximity to a Local Nature Conservation Site and substandard access
arrangement, appear from the alternative site evaluation submissions not to have been
given sufficient weighting in choosing the current site, despite these clearly being criteria
which should have been considered under the applicant’s own site search and evaluation
exercise. 
1.12. Therefore, Officers do not consider that a convincing case has been made as to why the
BESS facility must be located on the greenbelt site proposed. Where there are concerns
over adverse impacts this is a material consideration, in the view of officers, which counts
against the approval of the proposals. Potentially less sensitive sites within the National
Park have not been properly evaluated, and even if in principle such proposals can be
acceptable in the greenbelt , they are required in respect of both NPF 4 Policy 8 and LDP
2 Policy 02  to demonstrate a need to locate within the Helensburgh Greenbelt. The
submissions fail to satisfy officers on this point.

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1.13. Had the need to locate within the greenbelt been justified as required to the satisfaction
of officers, there are also further requirements to evaluate the impact of the development
on the greenbelt which relate to site specific considerations. More detailed evaluation of
the potential impacts of the development upon the greenbelt and its character and function
at this point is provided at Section 3 of this report. 
2. Location, Nature and Design of Proposed Development 
2.1. The proposed site is located at Ardencaple Farm, Rhu, Helensburgh, Argyll & Bute
approximately 1km North-East of Rhu, on approximately 0.5ha of agricultural land
currently used for pasture. The site is bounded by a combination of vegetation and rail
fencing with the railway line running along the southern boundary. The nearest residential
properties, are identified in submissions as being located approximately 450m to the
south east on McLeod Crescent and Paterson Drive. 
2.2. Beyond the railway line to the South lies Duchess Woods a designated Local Nature
Conservation Area and an extremely valuable community facility which is well used by
local residents as an amenity resource. 
2.3. The purpose of the Proposed Development would be to install a Battery Energy Storage
System (BESS) which would provide standby, emergency electricity for National Grid in
times of high electricity demand or when renewable energy projects are unable to fulfil
demand. This would be for the installation of: 
• 49.9MW of modular battery units with ancillary equipment (6.1m x 2.5m x
• 2.9m finished in a matt off white).
• Inverters (9.8m x 5.0m x 2.3m finished in matt off white).
• DNO substation (7.5m x 2.8m x 3.2m finished in matt dark green).
• Switchroom (12.3m x 3.3m x 3.4m raised on 1m stilts finished in matt dark
• green).
• Site and welfare office (7.5m x 2.3m x 2.9m finished in matt dark green).
• Site transformer (3.3m x 2.3m x 3.2m finished in matt dark grey).
• Erection of acoustic barrier Fence along Southern Boundary 
2.4. In order to account for the topography, the application proposes to create a two-tiered
site. All equipment would be sited on individual concrete slabs and the site made suitable
for servicing by commercial vehicles as shown in submitted Appendix A2: Site Layout
Plan. An access road would be provided utilising the existing Ardencaple Farm access
road off Paterson Drive and entering the site from the north. 
2.5. The battery containers and ancillary equipment would be painted in a muted green colour
to be agreed with the Local Planning Authority. The development would be secured by a
2.4 metre high mesh welded security fence, with the western and southern boundary
being a 3.0m wooden acoustic fence. 
2.6. Additional landscaping details in the form of tree and shrub planting has been proposed
by the applicant to both assist screening as assimilation of the development into the
landscape and to ensure a biodiversity net gain associated with the proposals. 
2.7.  It is worth noting at this point that the applicant’s own submissions indicate that the
equipment proposed is not fixed, and a conditional approval to allow changes to the actual
plant/machinery to be installed has been suggested in submissions. This matter is

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addressed in more detail at section 4 which evaluates the potential noise characteristics
of the development. 
3.  Greenbelt and Landscape Evaluation 
3.1. As has been set out at Section 1 of this report, the application seeks to locate a BESS
facility on a site within Helensburgh greenbelt. The development will therefore require to
address the policies which apply to greenbelt development in their entirety. As has been
set out at Section 1, even if the location of the development within the greenbelt had been
satisfactorily justified, there are also a number of other relevant policy requirements which
development proposals must satisfy. Relevant extracts of these policies are set out below. 
3.2. LDP 2 Policy 02 clarifies, inter alia, that applications : 
will also be required to demonstrate that there will be no unacceptable adverse effects
(either individually or cumulatively) on natural heritage resources, built and/or cultural
heritage resources, and landscape and visual amenity..... 
3.3. ....Within the Helensburgh and Lomond Green Belt development will only be supported
where this is appropriately designed, located and landscaped 
3.4.  LDP 2 Policy 04 which relates to sustainable development requires that; 
In preparing new development proposals, developers should seek to demonstrate the
following sustainable development principles, which the planning authority will also use
in deciding whether or not to grant planning permission... 
i) Respect the landscape character of an area and the setting and character of
settlements; 
3.5.  LDP 2 Policy 08 in respect of sustainable siting states 
Each of the following will apply when assessing any proposal for development...... 
• The development should integrate into the landscape or existing built form to minimise
detrimental effects on the environment. Particularly careful attention should be given to
hilltop, skyline or ridge locations, where development will only be acceptable if such a
location cannot be avoided and any significant adverse landscape and visual effects are
clearly outweighed by social, environmental or economic benefits of community wide
importance arising from the development proposal, and have been sufficiently mitigated
through an environmental impact assessment or landscape and visual impact
assessment.
.
3.6. LDP 2 Policy 10, which sets out the design principles applicable to all development,
requires that; 
The design of any development must: 
• Demonstrate an understanding of and appropriate response to the proposed
development site and wider context including consideration of character and, where
applicable, urban grain;....

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3.7. NPF 4 Policy 8 also requires that for development in the greenbelt, where is locational
need is justified, that 
The character, landscape, natural setting and identity of settlements is protected and
enhanced. 
3.8. Officers are aware of the strong support for BESS proposals given within both NPF4 and
LDP 2 Energy Related Policies and these will also be evaluated at a later stage in the
report.  The proposed site for this industrial scale BESS development, in Officers view, is
on an integral and important component part of the greenbelt at this point. Although it is
accepted that views are constrained along the access road to the site by hedges and that
the greenbelt compartment is formed by boundary hedgerows to the east and west , these
do not form part of the application site and are not within the control of the applicant to
secure their retention. Therefore their screening role cannot be guaranteed for the future. 
Importantly, this is a well-used access road for residential, business and recreational
users and there is an important viewpoint over the site at the site entrance opposite Cherry
Wood stables.  From this well used vantage, the field within which the application is
proposed, forms an important and open compartment of the greenbelt where the open
views are an important contributor to the open character of the greenbelt at this point. 
3.9. The field where the application is proposed, in the opinion of officers, forms a critical
element in defining the openness of the greenbelt at this point, and contextualising and
framing the setting of the settlement of Helensburgh in an attractive manner. The field
both frames the settlement and also provides the desirable open context for longer range
views of Helensburgh and the Clyde Estuary beyond. The quality of this view and the vital
role this field plays in facilitating open and attractive vistas within the greenbelt is, in
officer’s opinion, of clear importance. The proposed development would, in Officers
opinion, unacceptably harm and undermine the greenbelt at this point by introducing a
large industrial scale development into an important greenbelt compartment to the
detriment of the greenbelt and its role at this point. The proposals are therefore considered
to be contrary to LDP 02 Policies 02, 04, 08 and 10 objectives and also NPF 4 Policy 8
requirements. 
3.10. However , given that the proposal is related to the delivery of a renewable energy based
system which supports addressing the roll out of renewable grid infrastructure in
accordance with NPF 4 and wider Government climate change objectives, it is also
necessary to balance any conflicts with the above policies with the  extremely supportive
policies within LDP 2 and NPF 4 for energy related development (as well as other climate
change related Scottish Government advice as set out in the material considerations
section of this report). Further policy evaluation related to these supportive energy policies
is set out below. 
NPF 4 and LDP 2 Energy Policy Evaluation 
3.11. Given that the proposal is for essential energy infrastructure which contributes to
addressing the Climate emergency and the objectives of NPF4 Policy 1, it must be
acknowledged in the decision making process that there is strong policy support for such
proposals. As this recommendation to refuse the current application is a matter of officers
balancing competing policy objectives, it is essential that Members in coming to a planning
judgement, also take into account the strong policy support for such proposals set out in
LDP2 Policy 30 and NPF 4 Policy 11 in coming to a Planning decision in this case. This
is not, in Officers opinion, a clear-cut matter, and the significance of the contended and
potential adverse impact, non-compliance with roads standards and inadequate noise
information submission, must be considered in the balance against this strong Energy
Policy support for such proposals as referenced. LDP 2 policy 30 states;

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The Council will support renewable energy developments where these are consistent
with the principles of sustainable development and it can be adequately demonstrated
that there would be no unacceptable environmental effects, whether individual or
cumulative, on local communities, natural and historic environments, landscape
character and visual amenity, and that the proposals would be compatible with adjacent
land uses….In assessing any application the Council will additionally have regard to the
opportunities for energy storage, local energy networks, and long term environmental
management of the site. 
3.12. NPF 4 Policy 11 clarifies that: 
a) Development proposals for all forms of renewable, low-carbon and zero emissions
technologies will be supported. These include: 
iii. energy storage, such as battery storage and pumped storage hydro; 
3.13. Notwithstanding these energy policies and other policy advice which strongly support the
approval of BESS proposals, and which the council is supportive of, there are specific
locational and site constraint issues associated with this particular proposal which officers
consider are unacceptable and outweigh the policy support in principle for such
developments as set out in this report. 
4. Noise and Amenity 
4.1. The submitted Noise Report confirms that the ‘discharge’ process is when noise emissions
are at their maximum, with the cooling systems to all of the plant operating at a much higher
capacity (and thus noisier level) during discharge compared to the majority of the day/night
when energy is being drawn/stored. The discharge hours would be dictated by the demands
of the National Grid, but would likely occur between around 07:30 and 20:30, not for this
whole period, but typically for up to 2 hours at a time. Officers note that the submitted Noise
Report states: 
…. that should planning permission be granted, that this would include a planning condition
which requires a further assessment to be submitted prior to construction / once the design
has been finalised and the exact manufacturers/model numbers of all of the plant are
known, given that the design could conceivably change. 
The Council’s Environmental Protection officer has evaluated the submitted noise report
which seeks to address noise concerns expressed by residents. In his response dated
24.09.24 the Environmental Health Officer confirms that; 
With regards to the Noise Impact Assessment submitted in connection with the above
planning application, although the methodology of the assessment was competent, it is
fully acknowledged that it was based on an assumed variety of equipment that may be in
place on the BESS site. In order that we can be satisfied that the amenity of the local
residents could be protected, we would need to see an assessment based on date of the
actual equipment to be used as there will likely be variation in terms of both general
sound level and frequency spectra. Any controls noted thereof would have to be in
relation to the assessment of sound produced from the actual equipment to be installed.
We would also need to see information on “tick over” sound levels and any impact on
start up/shut down between tick-over and fully operational as it is these changes of noise
states that are more attractive to any listener.

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4.2. The above response clarifies that the methodology of the report is agreed, but failing to
commit to the actual plant/machinery to be installed on the site, and suggesting that a
suspensive condition would be expected to cover this, leaves any evaluation of resultant
nose levels at sensitive receptor locations and changes in noise levels without the
necessary certainty to ensure this matter is properly addressed. In an addendum response
to this above (dated 04.10.24) the Environmental protection officer further comments that; 
I note that there was no vibration assessment undertaken for the initial BESS submission.
We would require this to be undertaken and mitigations identified as required. 
4.3. In respect of the objections raised about the potential noise disturbance to users of Duchess
Woods, which is a well-used and high-quality amenity area rich in wildlife (designated as a
Local Nature Conservations Site and Local Nature Reserve). Officers note: 
• the failure to clearly commit to the exact type of equipment to be installed and its noise
output and vibration characteristics, 
• the lack of clarity on 24 hr operational noise output characteristics of that equipment, 
• the lack of detail on predicted noise impact on the core path route within Duchess
Woods at its closest point to the development, 
4.4. All these matters in Officers’ opinion represent a deficiency of the application submissions.
Had this been a less sensitive adjoining use, such matters would be less material to the
determination, however Duchess Woods is a highly regarded and valued Local Nature
Reserve formally identified in the Statutory Plan and a Local Nature Conservation Site
where members of the public  should legitimately expect (subject to train noise incidents)
they can enjoy nature. It is therefore considered to be a sensitive receiving environment by
Officers. 
4.5.  For clarity, Officers do not contend, as a matter of certainty, that the proposals will result
in unacceptable noise impacts on the amenity value and enjoyment of Duchess Woods.
However, the lack of certainty on this matter on the level of any noise which would be
audible from the woodland is a further material consideration in concluding that the current
submissions do not adequately address the issue of noise, and potential amenity impacts
to the satisfaction of Officers. 
4.6. Had officers been minded to approve this development, a revised noise survey, accurate
in respect of the proposed equipment and its noise and vibration generating characteristic
over a full 24hr operational period would have been required. Given the fundamental
importance of these matters to the proposed location of the BESS being acceptable,
Officers do not consider the use of a suspensive condition would adequately address these
matters in this particular case. 
4.7. For the reasons set out above it is considered that the proposal fail to provide sufficient
detail in respect of potential noise impacts upon surrounding sensitive receptors and land
contrary to the objectives of LDP 2 Policy 14. 
5. Network, Parking and Associated Transport Matters. 
5.1. The applicants confirm by submission that they would utilise the existing Ardencaple Farm
access track off Paterson Drive, and thereafter would propose to enter the site from the
north via a new private access track to the BESS. The management of access during the
construction phase set out in the submitted Construction Traffic Management Plan (CTMP).
The lack of adequate and safe access for both construction, operational and emergency
service access is a concern which a considerable number of objectors have raised. The

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Area Roads Engineer has recommended refusal of the application over inadequate and
substandard access arrangements being submitted. In his response dated 07.08.24 he
comments that, 
On review, having attempted to access the site in a vehicle, it has become apparent that
the route does not offer the necessary intervisibility between vehicles and pedestrians,
nor the available width for vehicles access or pedestrian ‘step-off’ due to the extents of
vegetation growth. 
Additionally, access to the proposed site from the existing access route/ road covers a
significant change in elevation. Stated within the submission, the access road will be
installed at a ratio of 1:5 (20%), Argyll and Bute design guidance states that access roads
must be installed no greater than 1:20 (5%). Any solutions to lessen the gradient would
require significantly more area than that which has been identified within the applicant’s
red line boundary. 
In conclusion, the combined access issues and access gradient issue require
improvement to reach the minimum design guidance set out with Argyll and Bute standard
details and design guidance. As the commensurate improvements to achieve these
standards appears to be out with the applicant’s gift, Roads refuse the proposed on the
grounds of road safety. 
5.2. Members should note that discussions were entered into with the applicant to seek to
provide adequate intervisibility and passing places and revised proposals were provided by
the applicant to seek to address access to the site. However, the applicant has failed to
provide reassurance to the Area Roads Engineer that the proposals could be delivered due
to constraints over the land they have control of and given the extent of necessary
improvements. 
5.3. Further consideration of the proposals also raised concerns in relation to the gradients
proposed for the private access road to the site and the internal access road within the site
in respect of not meeting necessary roads standards for emergency vehicle access.
Officers consider that the ability to provide safe and acceptable access to the site for
emergency service vehicles is a fundamental matter to the suitability of the site for a BESS
development. This is therefore considered to be a matter which requires to be resolved at
application submission to the satisfaction of the Area Roads Engineer and is not an
appropriate matter for the use of a suspensive condition. 
5.4. In the consultation response dated 27.03.24 from the Scottish Fire and Rescue Service
(SFRS) they have clarified a number of access and other technical requirements for BESS
proposals. Of most relevant to access requirements is the following extract: 
Suitable facilities for safely accessing and egressing the site should be provided. Designs
should be developed in close liaison with the local FRS as specific requirements may
apply due to variations in vehicles and equipment. 
This should include: 
At least 2 separate access points to the site to account for opposite wind
conditions/direction. 
Roads/hard standing capable of accommodating fire service vehicles in all weather
conditions. As such there should be no extremes of grade. 
A perimeter road or roads with passing places suitable for fire service vehicles.

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5.5. It is considered that the failure of the proposal to meet these SFRS requirements is a further
material consideration, reinforcing the objection of the Area Roads Engineer in respect of
the proposed site and access arrangement roads being substandard to ensure acceptable
emergency service vehicle access to site. This again suggests that insufficient weight has
been given to these constraints within what was in officers opinion a flawed site search
approach as has been previously referenced at Section 1 of this report. 
5.6. Given the above the proposals are considered to be contrary to requirements of LDP 2
Policies 35, 37 and 39. 
6. Other Key Policy Matters 
6.1 Flooding and Drainage 
The Councils Flooding advisor has raised no objection to the proposals and has
commented that: 
The site lies outwith the indicative limits of fluvial and coastal flooding, as per the SEPA
Future Flood Maps. A small, localised region of surface water flooding overlaps with the
southern boundary of the site, however, depths are recorded to be less than 30cm, and
extends over a small surface area. The proposed development is outwith the surface water
flood extent. The small watercourses to the west and east of the site have catchment areas
of less than 3km2 and hence haven’t been accounted for in the SEPA Fluvial flood map.
Flood risk from these watercourses has not been quantified in the Flood Risk and Hydrology
/ Drainage Impact Assessment. However, as the site plans show a stand-off distance
between the watercourse and the proposed development and the site is outside of the
indicative surface water extent, the proposals are considered to be acceptable regarding
flood risk 
A Drainage Impact Assessment includes a drainage plan and drainage calculations for the
site, and the following comments are made: 
• The Drainage layout shows that surface water run-off will be routed to storm cells and
attenuated within the site before discharge to the small watercourse to the west of the
site. Flow exceedance routes are included in the drainage plan.
• The Drainage calculations show that the drainage capacity of the storm cell system (345
m3) will accommodate rainfall events up to and including the 200-year event plus an
allowance for climate change. This is acceptable. 
It is noted that the proposals have water tank provision on site as part of a proposed fire
suppression system and that further technical requirements in terms of water suppression
requirements have been provided in the consultation response from the SFRS. Should the
need arise for water suppression of a fire on the site, the water will be required to be
retained on the site and not allowed to discharge in a similar manner to surface water as
there will be contaminants in the water associated with the materials the batteries are made
of. 
Officers are of the opinion that had the recommendation been to approve the current
proposal, a condition requiring a fire safety and site drainage and pollution containment
plan would have been required to ensure both the capability of the system and the ability
to meet the requirements of the SFRS. It would also be essential to ensure any external
fire service related water used in combination with on-site water tank use, would not
discharge from the site on a worst case scenario given the North to South slope, and
proximity of the Local Nature Conservation Site.

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It not considered that these concerns would in themselves form a reason to refuse the
application and a suspensive condition requiring further submissions on these matters
could have been imposed had the recommendation been to approve the proposals. 
6.2 Biodiversity and Natural Environment 
The Council’s Biodiversity Officer has evaluated the application submissions, and in particular
the details contained within submitted Landscape Mitigation plan. In her response she clarifies
that: 
Comments from the Ecology Report:
I agree with the proposed mitigation measures:
• Installation of noise fence during construction phase
• Works to be completed outwith the breeding bird season
• Pre-works check for reptiles, amphibians, water vole, breeding birds
• Good practice carried out on site
• Delivery of ToolBox Talk prior to works 
I also agree with the recommendations for general biodiversity enhancement. 
The Biodiversity Officer has had regard to the fact that it is likely that bats from the surrounding
woodland will overfly the site when hunting and has therefore referenced the need for lighting
to be properly controlled in any grant of planning permission in accordance with good practice
(reference is made to the advice within the Bat Conservation Trust Guidelines on lighting and
Pages 29-30 as a useful reference). 
In respect of any necessary future information on submissions which should be conditioned
had an approval been proposed. She clarifies: 
Recommendations:
• I would suggest a bat survey be conducted prior to works commencing due
to the potential for ongoing disturbance to bats from potential light and noise
pollution. There is moderate value habitat present for bat commuting and
foraging. Limitations of the survey included trees to the east of the site that
were only able to be surveyed for potential bat roosting features from the
ground level due to the canopy layer of leaves during the survey. 
• A programme of tree / flower planting should be included to show species,
location, timings and methods of implementation, and on-going monitoring and
maintenance. This will ensure all new vegetation is protected until such a time it
becomes established and ensure biodiversity enhancement. 
Officers accept and acknowledge that the enhanced landscaping proposals which have been
submitted, on balance of probability, achieve biodiversity net gain given the current low
biodiversity/habitat value of the site. Officers also accept that the planting proposals would in
the longer term assist in both biodiversity enhancement objectives and assist in reducing the
visual impact of the proposals on the greenbelt at this point. It is considered that, had it been
officer recommendation to approve the current proposal, a suspensive condition requiring

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further submissions to demonstrate biodiversity net gain has been achieved could adequately
address these matters in this particular instance. 
Given the above, it is considered that the proposals can be considered in general adherence
NPF Policy 3 and LDP 2 Policy 73 objectives. 
6.3 NPF Policy 11 (c) and 25 and LDP 2 Policy 11 Economic Benefits 
The policy framework against which proposals for energy development proposals must be
evaluated also includes the following policy matters: 
NPF 4 Policy 11(c) states 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(a) of the NPF4 states: 
“Development proposals which contribute to local or regional community wealth
building strategies and are consistent with local economic priorities will be supported.
This could include for example 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.” 
LDP 2 Policy 11 requires energy related proposals to be assessed against a number of criteria
, including: 
Net economic impact, including local and community socio-economic benefits such as
employment, associated business and supply chain opportunities.” 
The applicant has submitted an Economic Benefits Statement as Appendix M to the proposal.
This clarifies that: 
• Battery development projects create employment opportunities particularly during
construction phase. Wherever possible, the Applicant will seek to utilise local
employment for the civil engineering aspect. Furthermore, these projects can
stimulate local economies and generate revenue for the community, both through
direct employment and indirect benefits to local businesses and services.
Furthermore, they can attract investment and foster innovation in Scotland's growing
green energy sector. 
• Opportunities for indirect benefits include utilising local labourer workforce
(~£500/week), and using locally owned accommodation to house external workforce
(i.e. 4 nights a week at ~£100 per night). In addition, sustenance costs for workforces
spent in local shops (~£20/day) 
• It is anticipated there would be an average of 10 labourers per site at any given time,
with project build time of 12 months = ~£240,000 contribution to local economy.
20 Battery storage facilities require enhanced grid reliability and resilience, reducing the
risk of local power outages. This would include the introduction of fibre
communication networks and replacing outdated or overtaxed electrical infrastructure

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at the substation. As with all infrastructure networks, these would be owned by the
operator and would therefore be available to local businesses and residents. In times
of natural disasters, extreme weather events, or unforeseen grid disturbances,
battery storage facilities can provide a critical, temporary, source of backup power,
supporting essential services, hospitals, and emergency response units. 
• During the initial project phase, a project of this kind can bring in excess of £1,000,000
of direct investment into a local area by using local companies to undertake the civil
engineering element of the project. At the point of tender, the Applicant will engage
with appropriate local businesses invite them to submit tenders for the civil
engineering element of the project. Also, there will be additional local benefits
through hiring of equipment and sourcing incidental materials. The installation and
commissioning process is likely to be undertaken by the equipment suppliers and
involves highly specialised, qualified and experienced personnel. It is acknowledged
that this is unlikely to be from local companies. However, secondary benefits of the
technical installation and commissioning process (likely to be for a 12 month period)
would be for local businesses to benefit by providing accommodation and hospitality
services during the construction period. 
• Longer term, battery energy storage projects create high skill employment
opportunities with transferrable skills. The energy sector is the largest direct employer
in Scotland outside of the public sector. (source: The Economic Impact of Scotland's
Renewable Energy Sector). The Applicant would explore opportunities to upskill local
tradesmen to undertake this work. 
• The project will be subject to a high band of business rates, contributing an estimated
£225,000 each year to the local authority to fund public services for the full 25-30
year project life. 
Officers consider that the matters set out above are satisfactory to address the policy
requirements of this particular proposal, although further details on the mechanisms to deliver
the desired outcomes would be required to provide additional reassurance. Officers are
content that such matters could be resolved through the use of a suspensive condition
requiring further details on how these commitments would be adhered to and delivered (such
as commitment to hold open days for suppliers and to explore training or education
opportunities associated with the proposals) 
6.4 Restoration Bond and Site Restoration Plan (to include waste management and
disposal plan for any potentially contaminating materials) 
Had it been the recommendation of officers to approve this application, a suspensive condition
requiring a site decommissioning Plan and Waste Management Plan would have been
required This would also require the provision of an appropriate financial mechanism (the sum
and indexing mechanism to be independently verified), to ensure any costs associated with
site restoration were adequately covered in a similar manner to a minerals restoration
requirement. The need for a waste management element reflects the know needs associated
with the proper removal and disposal of BESS units. In accordance with established practice
the use of a suspensive condition could, in the opinion of Officers, adequately address these
matters. 
6.5 Workers Housing Strategy 
Discussions with relevant policy officers has confirmed that a workers housing strategy
condition would not be required for development sites within daily commuting distance from

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the central belt area.  Therefore, in this particular instance, no suspensive condition on this
matter would be imposed by officers had the recommendation been to approve the
development. 
6.6 Cultural Heritage 
The applicants have submitted a heritage statement dated October 2023 in respect of  these
matters as part of the application submission package. Designated Heritage assets in the
surrounding area are identified at Figure 1. The Conservation Area Boundary is identified at
Figure 2 and non-designated assets are identified at Figure 3. The report concludes at Section
5 that: 
a range of heritage assets in accordance with best practice as provided by Scottish Natural
Heritage Good Practice Advice. It has shown that the Proposed Development Site would not
impact on any designated or undesignated heritage assets and therefore accords with NPF4
and the Local Plan. 
Officers are in agreement with this conclusion and the proposals are considered to be in
accordance with the requirements of NPF 4 Policy 7 and LDP 2 Policy 15. 
6.7 Network Rail Suspensive Conditions 
Officers note that Network Rail in their consultation response have also confirmed the need
for the imposition of suspensive conditions on any grant of planning permission to safeguard
their interests. 
Officers are uncertain as to whether all the Network Rail conditional requirements could be
satisfactorily addressed by the applicants.  However, as the Officer recommendation is to
refuse the application, the need to examine these matters in more detail at this stage is not
required.

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Appendix B Representations in relation to 23/02472/PP 
Objection  
Adam McLean 3 Paterson Drive Helensburgh Argyll And Bute G84 9QY 
Aimee Woolfries No Address Given    
Albert Barclay Carbeth House Torwoodhill Road Rhu Helensburgh Argyll And Bute 
Alistair Stewart 61 Macleod Drive Helensburgh Argyll And Bute G84 9PS 
Allan Naismith 44 Queen Street Helensburgh Argyll And Bute G84 9PT 
Antonio Lopez Jordan 10 Macleod Crescent Helensburgh Argyll And Bute G84 9QX 
Audrey Baird No Address Given    
Brian McCutcheon     
Caroline Strugnell 22 Duchess Drive Helensburgh Argyll And Bute G84 9PR 
Cathryn Silverthorne 3 Duchess Drive Helensburgh Argyll And Bute G84 9PR 
Catriona Davies Suite A3 Stirling Agricultural Centre Stirling FK9 4RN 
Craig Fyffe 18 Paterson Drive Helensburgh Argyll And Bute G84 9QY 
David Anderson Ashton Rhu Road Higher Helensburgh Argyll And Bute 
David Cantello 35 Redclyffe Gardens Helensburgh Argyll And Bute G84 9JJ 
David Fox 49 Charlotte Street Helensburgh G84 7SE  
David Lewin 36 Queen Street Helensburgh Argyll And Bute G84 9PU 
David McNaught 38 MacLeod Drive Helensburgh  G84 9QU  
Dawn Archard No Address Given    
Fiona Baker Hillcroft Station Road Rhu Helensburgh 
Fiona Young Edward Drive Helensburgh   
Helen Ratcliffe 65 Macleod Drive G849PS   
Hilary Stuart Dunaivon Armadale Road Rhu Helensburgh Argyll And Bute 
Iain MacLaren Twiga Glenoran Road Helensburgh Argyll And Bute 
Jackie Baillie MSP Constituency Office 11 Castle Street Dumbarton G82 1QS 
James Scullion No Address Given    
James Silverthorne 3 Duchess Drive Helensburgh Argyll And Bute G84 9PR 
Jean McFarlane 38 MacLeod Drive Helensburgh G84 9QU  
Joe McIntyre 46 Macleod Drive Helensburgh Argyll And Bute G84 9QU 
John Allwood 10 Macleod Drive Helensburgh Argyll And Bute G84 9QS 
John Thompson Full Address Not Given    
Jonathan Sutton No Address Given    
Keith And Elaine Ferguson     
Lewis Martin 7 Lower Sutherland Crescent Helensburgh Argyll And Bute G84 9PG 
Lois Nicolson     
Louise Syme Willow Bank Garelochhead Helensburgh Argyll And Bute 
Lucy Scullion Cherryhill Stables Helensburgh Argyll And Bute G84 9QG 
Lynn Harper 67 Macleod Drive Helensburgh Argyll And Bute G84 9PS 
Martin Grafton 17 Queens Point Shandon Helensburgh Argyll And Bute 
Mary Kingshott 46 Queen Street Helensburgh Argyll And Bute G84 9PT 
Michaela Mather 9 Duchess Drive Helensburgh Argyll And Bute G84 9PR 
Michelle McCutcheon No Address Provided    
Morag Young 73A West King Street Helensburgh Argyll And Bute G84 8EE 
Natasha Watkiss 20 Duchess Drive Helensburgh Argyll And Bute G84 9PR 
Nicky Brownrigg Ardentigh Glenoran Road Helensburgh Argyll And Bute 
Noble Macpherson 31 Kennedy Drive Helensburgh Helensburgh Argyll And Bute 
Nora Morocza Flat 2/1 27 John Street Helensburgh Argyll And Bute 
Paula McIntosh 66A Colquhoun Street Helensburgh Argyll And Bute G84 9JP 
Penny Ward 25 Laggary Road Rhu Helensburgh Argyll And Bute 
Peter Davies 66 James Street Helensburgh Argyll And Bute G84 9LF 
Rachel Black 26 Ardencaple Drive Helensburgh Argyll And Bute G84 8PS

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Rob Stuart Dunaivon Armadale Road Rhu G84 8LG 
Roger And Ruth Scullion     
Roger Scullion Cherrytree Stables Paterson Drive Helensburgh  
Ross Mather 9 Duchess Drive Helensburgh Argyll And Bute G84 9PR 
Sally Butt Upper Flat 2A West Lennox Drive Helensburgh Argyll And Bute 
Seonag Bates Redwood Glenarn Road Rhu Helensburgh 
Suzanne Hamilton No Address Given    
Terence Brownrigg No Address Given    
Thomas Carruthers 4 Paterson Drive Helensburgh Argyll And Bute G84 9QY 
Vivien Monteith 5 Duchess Drive Helensburgh Argyll And Bute G84 9PR 
Xanne Janssen 22 Duchess Drive Helensburgh Argyll And Bute G84 9PR 
Xanne Janssen 22 Duchess Drive Helensburgh Argyll And Bute G84 9PR 
Nigel Millar     
Support  
James Rae 104 West King Street Helensburgh Argyll And Bute G84 8EQ 
Representation  
Jackie Baillie Constituency Office 11 Castle Street Dumbarton G82 1QS 
Martin Grafton No Address Given    
Friends Of Duchess Wood