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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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 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 Classification: OFFICIAL 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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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Classification: OFFICIAL 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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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Classification: OFFICIAL 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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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Classification: OFFICIAL 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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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Classification: OFFICIAL 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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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Classification: OFFICIAL 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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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Classification: OFFICIAL 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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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Classification: OFFICIAL 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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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Classification: OFFICIAL 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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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Classification: OFFICIAL 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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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Classification: OFFICIAL 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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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Classification: OFFICIAL 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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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Classification: OFFICIAL 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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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Classification: OFFICIAL 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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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Classification: OFFICIAL 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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LDP2 format template March 4th 2024 Report of Handling Template for PPSL and Delegated Planning Applications – Updated 10.11.2023 Classification: OFFICIAL 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