Battery Energy Storage Systems: planning guidance

Footnotes

1 There is not a specific definition of ‘Grid Scale’ BESS, however for the purposes of this guidance, it is assumed to be systems with storage capacity of >1MW, and not for domestic or other non-commercial use.

2 The majority of BESS projects currently utilise lithium-ion batteries, though a number of alternative battery technologies (e.g. sodium-based batteries) are emerging and may become more widely deployed in future.

3 See Section 25 of the Town and Country Planning (Scotland) Act 1997

4 Town & Country Planning (Hierarchy of Developments) (Scotland) Regulations 2009.

5 Development of a type listed in Schedule 2 of the relevant EIA Regulations should be ‘screened’ to determine whether EIA is required. BESS development is not directly referenced in Schedule 2 of the relevant EIA Regulations. However, for planning applications BESS is typically considered to fall within category 3(a) ‘industrial installations for production of electricity, steam, and hot water’ for which the EIA Screening threshold is a site area exceeding 0.5 hectares. For S36 applications, BESS is typically considered as a ‘generating station’ within Schedule 2 of the Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017.

6 For BESS proposals that meet SEPA’s consultation thresholds due to the nature of the site, requests for pre-application advice should be coordinated by the planning authority.

7 Micrositing is often adopted for onshore wind farm development where conditions are applied to allow for some flexibility in final turbine placement should unexpected conditions be encountered during construction (e.g. where deeper than predicted peat)

8 As in NPF4, the mitigation hierarchy indicates the order in which the impacts of development should be considered and addressed. These are: i. Avoid – by removing the impact at the outset; ii. Minimise – by reducing the impact; iii. Restore – by repairing damaged habitats; and iv. Offset – by compensating for the residual impact that remains, with preference to on-site over off-site measures.

9 Either planning conditions or planning obligations can be used to secure financial guarantees, and it will remain in the judgement of the decision -maker as to the most appropriate mechanism in the context of an individual proposal and applications. Legal agreements may be appropriate where there are more complex ownership arrangements and financial mechanisms, or site-specific risk factors which require a more secure contractual arrangement.

10 See: Planning and Infrastructure Act 2025

11 For planning applications, Schedule 5 of The Town and Country Planning (Development Management Procedure) (Scotland) Regulations 2013 sets out the specific circumstances and thresholds that trigger consultation with other persons, authorities, or bodies, on planning application.

12 Planning authorities and other consenting bodies should consult SEPA where development proposals meet consultation thresholds in SEPA’s Development Management Consultation Thresholds and Standing Advice. Further detail on SEPA’s role in the planning, construction and decommissioning phases for BESS is outlined in SEPA’s BESS webpages.

13 NatureScot should be consulted on BESS development where it meets one or more criteria in their How and when to consult NatureScot checklist. They only seek to provide detailed advice and comment where impacts of proposals are significant and closely approach or exceed levels that raise issues of national interest. Further detail on NatureScot’s approach to planning advice is provided in their Guidance – Development Management and the Natural Heritage and they have published a suite of planning and development advice in their Planning and Development Advice - NatureScot.

14 Historic Environment Scotland is a statutory consultee for planning applications for works affecting Listed Buildings, Scheduled Monuments, and other historic designations. Further detail on their role in planning is provide in their Guidance - Historic Environment Scotland's Role in Planning.

15 BS 4142:2014+A1:2019: Methods for rating and assessing industrial and commercial sound. The noise assessment method in BS 4142 is based on the difference between the measured background sound level and the rating level of the noise source, at the receiver location. It notes that the significance of sound of an industrial and/or commercial nature depends upon both the margin by which the rating level of the specific sound source exceeds the background sound level and the context in which the sound occurs.

16 Nationwide mapping of Prime Agricultural Land and Carbon-Rich and Peatland Soils can support early site identification and review processes, but are not a substitute for site surveys to determine specific soil characteristics and condition.

17 Information is available on the SEPA website: Battery Energy Storage Systems (BESS) | Beta | SEPA | Scottish Environment Protection Agency. Run-off from completed BESS developments are authorised by Water GBR 10B .

18 Abstraction of water may require an EASR water activities authorisation depending on the quantity, and applicants should consult SEPA’s Guidance on abstraction and contact SEPA before submitting an application.

19 Detailed guidance on the consideration of cumulative effects for EIA is provided in Planning Circular 1/2017 (EIA Regulations).

20 For example, applications under Section 36 and Section 37 of the Electricity Act 1989, and considered under the Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017.

21 Regard should be had to Scottish Government’s Planning Circular 4/2025 Planning Obligations and Good Neighbour Agreements: Guidance. It states that planning obligations or other legal agreement should not be used to resolve issues that could equally be resolved in another way, and that planning conditions are generally preferable as the most efficient means of controlling development and securing mitigation.

22 Process fire precautions are special, technical or organisational measures required to prevent the risk of fire.

23 General fire precautions are fire safety measures that you would expect to find in any premises no matter what the premises is being used for.

24 The Scottish Government’s Practical Fire Safety Guidance for Existing Non-residential premises uses ‘dutyholders’ to refer to persons with fire safety responsibilities. It states that: Employers and/or other persons who operate or have control of the premises to any extent are responsible for complying with the fire safety duties. This might include managing agents, landlords and tenants, factors, owners, and managers and staff. Contractors and volunteers working on site may also have some responsibilities through their degree of control or responsibility for fire safety.

25 Section 2 of the Regulations defines “industrial battery” as any battery which is designed exclusively for industrial or professional uses.