Planning guidance on Battery Energy Storage Systems: EIR release

Information requested

Information about the recently published Scottish Government planning guidance publication on Battery Energy Storage Systems (BESS): Battery Energy Storage Systems: planning guidance - gov.scot.

Response

As the information you have requested is 'environmental information' for the purposes of the Environmental Information (Scotland) Regulations 2004 (EIRs), we are required to deal with your request under those Regulations. We are applying the exemption at section 39(2) of the Freedom of Information (Scotland) Act 2002 (FOISA), so that we do not also have to deal with your request under FOISA.

This exemption is subject to the 'public interest test'. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exemption. We have found that, on balance, the public interest lies in favour of upholding the exemption, because there is no public interest in dealing with the same request under two different regimes. This is essentially a technical point and has no material effect on the outcome of your request.

Response to your request

The answers to your questions are as follows:

What was the brief given to Ironside Farrar to write the BESS planning guidance?
A PDF copy of Schedule 2 from the Invitation to Tender (ITT) prepared on behalf of the Scottish Government for the Battery Energy Storage Systems (BESS) planning guidance is enclosed. This document sets out the brief that Ironside Farrar were expected to follow in writing the BESS planning guidance and was made public during the tender application process.

At what level was the brief for the guidance approved? (Ministerial? Senior Civil Servant?)
The guidance was commissioned by the National Planning Hub on behalf of Scottish Ministers. The ITT was prepared by officials from Planning, Architecture and Regeneration Directorate with input from officials in the Directorate for Energy and Climate Change and the Safer Communities Directorate. The finalised ITT was issued by a Delegated Purchasing Officer, in line with the Scottish Procurement Policy Manual and the Scotland Excel Framework for ‘Engineering and Technical Consultancy Services’

Which organisations or individuals were consulted in the preparation of the brief for the planning guidance?
The guidance was commissioned by the National Planning Hub on behalf of Scottish Ministers. As indicated above, the Brief was prepared by officials from Planning, Architecture and Regeneration Directorate with input from Scottish Government officials in the Directorate for Energy and Climate Change and the Safer Communities Directorate.

Which organisations were specified for Ironside Farrar to consult with during the preparation of the guidance?
The ITT specified that stakeholder engagement should identify best practice. Following two roundtable discussions convened by Ironside Farrar on 30 July 2025 and 14 August 2025, the guidance was prepared with input from industry, planning authorities, NatureScot, Scottish Environment Protection Agency (SEPA) and the Scottish Fire and Rescue Service (SFRS). Additionally, a small number of Community Councils contacted either the Scottish Government and / or Ironside Farrar to provide written feedback on local planning issues on BESS. This feedback was taken into account by Ironside Farrar in preparing the guidance.

What quality control measures were applied to the production of the guidance?
Ironside Farrar were selected to deliver the commission for the guidance following the ITT process. A Scottish Government steering group was established to oversee preparation of the guidance. This comprised officials from the Scottish Government Planning, Architecture and Regeneration Directorate, the Directorate for Energy and Climate Change, the Safer Communities Directorate and the National Planning Hub. An external advisory group, comprising representatives from SEPA, SFRS, NatureScot and Planning Authorities was also established to review the draft guidance.

Did anyone in the Government review drafts of the guidance before publication?
The Scottish Government steering group reviewed drafts of the guidance before publication.

Were any third parties asked to review drafts of the guidance before publication?
As noted above, an external advisory group, comprising representatives from SEPA, SFRS, NatureScot and Planning Authorities was established to review the draft guidance.

What comments were made by Government employees or Ministers about the planning guidance before or after publication?
As noted above, a Scottish Government steering group was established to oversee preparation of the guidance, this included providing comments and advice on a range of matters throughout the iterative drafting process. The steering group comprised officials from the Scottish Government Planning, Architecture and Regeneration Directorate, the Directorate for Energy and Climate Change, the Safer Communities Directorate and the National Planning Hub.

Prior to publication of the BESS planning guidance, the Scottish Government provided the following comments to the Citizen Participation and Public Petitions Committee to inform their consideration of petition PE2157: Update planning advice for energy storage issues and ensure that it includes clear guidance for the location of battery energy storage systems near residences and communities:

• The Scottish Government written submission on PE2157 dated 22 May 2025, states: “In April 2025, the Scottish Government commissioned independent consultants Ironside Farrar to produce planning guidance on Battery Energy Storage Systems. We currently anticipate this work will be completed in the autumn. This will include discussions with stakeholders, including Heads of Planning Scotland and Scottish Fire and Rescue Service. We intend that the guidance will promote good practice in determining BESS applications as well as set out information on other relevant regulatory regimes applicable to BESS in Scotland”
• The Minister for Public Finance written submission on PE2157 dated, 2 October 2025, states “The Scottish Government has commissioned independent consultants Ironside Farrar to produce guidance to support planning authorities considering BESS applications. This is progressing and once completed we expect to publish the guidance this winter.”

Upon publication of the BESS planning guidance, the Scottish Government published a news article “New guidance on battery storage sites”. The Minister for Public Finance also wrote to the Citizen Participation and Public Petitions Committee, with copies also sent to the Presiding Officer, Minister for Parliamentary Business and Veterans, Convenor of the Local Government, Housing and Planning Committee, Convenor of the Net Zero, Energy and Transport Committee, and Party Business Managers to notify them about the publication of the guidance. This letter is available at: Letter from Minister for Public Finance to CPPPC | Scottish Parliament Website

An e-alert “Planning Arcticecture and Regeneration News” was also issued to mailing list subscribers on 19 March 2026. This stated that, the guidance, prepared by Ironside Farrar, sets out how the planning process can ensure development is properly sited, well-designed, and responsive to its context. It also summarises regulatory requirements relevant to BESS. A copy of the E-Alert is enclosed.

Which budget was used to make the payment for the guidance?
The National Planning Hub Programme Budget was used to make the payment for the guidance.

What is the cost to the public for developing and publishing the guidance?

• Ironside Farrar: £29,700 including VAT
• APS Publishing Costs: £1071.41 including VAT

No record is retained of other costs including official time spent on the document.

What will the guidance be used for by the government and local authorities?
The guidance offers practical advice to support consistent, well‑informed planning decisions and encourage constructive engagement between applicants, decision‑makers, and local communities. It sets out how the planning process can ensure development is properly sited, well designed and responsive to its context, and includes advice on distances between BESS cabinets/enclosures and occupied buildings. It also summarises wider regulatory requirements relevant to BESS.

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The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at https://www.gov.scot/foi-responses.

EIR 202600513062 - Information Released - Annex

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2.1 MB