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Search the Public Notice PortalA rural charity has pointed out there is is a “huge oversupply” of battery storage in the planning system and is calling for a moratorium on such projects.
A new report by Action to Protect Rural Scotland found that in Scotland there is “already four times more capacity in the planning pipeline than the maximum required by 2030”.
The research also found that there is 3.4 times more than the maximum battery storage needed in Scotland by 2050, and that, for the UK, the current Battery Energy Storage System (BESS) capacity in the queue to 2030 is already "greater than the maximum required installed capacity under any scenario at 2030 and even 2050”.
Kat Jones, director of APRS said: “We already have planning permission for three times as much battery storage capacity as we need, but the applications keep coming in, and they keep getting consented. This has to stop.”
BESS are used to store electricity from renewables such as wind and solar at times when supply is higher than demand, so they can release this electricity later, when it is needed. BESS is considered a critical element in balancing the grid, by storing electricity for periods when renewable energy generation drops, as the UK decarbonises.
Also criticising the planning system is former planning minister, Alex Neil, who described the Energy Consents Unit as “not fit for purpose”. “We need root and branch reform of the ECU to bring it up to scratch. It’s not protecting Scotland’s environment and seems to be doling out approvals willy-nilly, irrespective of the consequences for communities.
Mr Neil observed: “The system is going against the NPF4 rule that says greenfield sites should not be used unless there are no brownfield sites available. But the ECU is ignoring this planning law and doesn’t even know the status of the sites that they are approving.”
A freedom of information request that he issued revealed that the ECU did not hold the information on whether sites were greenfield or brownfield, and did not ask applicants for it.
APRS researchers found that “no application for a large stand-alone battery storage site has even been refused” and that battery parks had been “permitted on green belts, meters from 5000 year-old prehistoric sites, in woodlands, and on prime agricultural land”.
The APRS report also says that there appears to be no assessment as to “whether there are alternative brownfield sites nearby where developments could take place” and that “very few decision notices contain mention of cumulative impacts and almost all of these are in the summaries of consultation responses”.
It also finds that the “opportunities for biodiversity enhancement are being ignored even when developers are offering to deliver it as part of the project, and where Local Authorities are requesting conditions related to biodiversity enhancement”.
Applications, it found, are continuing to rise and the size/capacity of applications is increasing. “The number of applications for battery storage in Scotland is increasing year on year with 2025 looking like it will exceed the previous maximum of 2024.”
The report also contains an interactive map of BESS proposed sites. Highland shows the highest number by Local Authority area followed by Aberdeenshire, whereas South Lanarkshire has the most capacity (3.5GW) .
Only six of the sites over 50MW consented by ECU were required to do an EIA. “Whether a site was required to do an EIA was unrelated to the capacity with four 500MW and two 50MW sites required to do EIAs, none of the five largest were required to do an EIA.”
Ms Jones criticised the approach in Scotland to consent. In Scotland all applications above 50MW go to Scottish Ministers for decision - via Energy Consents Unit (ECU). In England local authorities decide on all applications for BESS.
“At present local democratic processes,” Ms Jones said, “and our National Planning Framework, are being by-passed in the decision making for these industrial developments. Decision making for all Battery Storage should move to Local Authorities, as is the case in England. We need a plan that will show where the Battery storage is needed and where it can be most appropriately sited, rather than this free-for-all we see at the moment.”
Where a Local Authority in Scotland objects to a BESS over 50MW (ie where ECU is the decision maker), this triggers a Public Local Inquiry - and it is the Local Authority which needs to pay for this inquiry.
Ms Jones said: "Developers must see large battery storage as a complete walk-over for planning permission. And it is. We found that no application for a large stand-alone battery storage site has ever been refused.”
The report provides a series of recommendations for government which include, a moratorium until “a more strategic approach is agreed on”; that applications for large battery storage sites should be required to conduct an EIA; the creation of a spatial strategy and Planning Guidance for battery storage; that all decisions on BESS to be made at Local Authority level; that BESS sites should be included in the Local Development Planning (LDP) process.
Ms Jones said that BESS inclusion in the LDP process would mean “that advice and guidance from experts on energy and the grid, can be part of the decision-making along with other stakeholders, including communities and businesses”.
READ MORE:
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She added: “The current slap-dash approach is no good for getting the infrastructure we need in the right place. It is terrible for communities fighting bad proposals and a waste of time for developers, who may never be able to get a grid connection."
“The irony is that many of the locations that are best placed to connect to the grid have plenty of brownfield sites nearby. However our research shows a really small proportion of battery storage sites proposed on Brownfield sites. We are concerned that the scattergun approach to consenting thus far could actually prevent us building a network of energy storage of an appropriate capacity and in the most appropriate locations.”
Mr Neil also pointed out that there is a safety issue around fire risk at battery storage sites. He said: “The safety issue is not being addressed.”
The APRS report calls for national standards on battery safety and that “Scottish Fire and Rescue Service (SFRS) should be a statutory consultee for all BESS applications”. Under current legislation, APRS points out, the Scottish Fire and Rescue Service (SFRS) this is not the case.
A spokesperson for Royal Town Planning Institute said: “This research brings much-needed clarity to the rapidly growing field of battery energy storage in Scotland, offering timely evidence to guide how we plan for this essential part of our energy future. It outlines a vision for Scotland's energy that is echoed in our Planifesto 2026, which calls for renewed regional planning and a clear, long-term, and strategic direction for infrastructure delivery. Getting this right will give both developers and communities the confidence and certainty they deserve.”
An SG spokesperson said: “Battery storage will play a role in the future energy mix of Scotland as it offers fast responding, dispatchable power when required to provide resilience to households and communities. Any potential impacts on communities, nature and cultural heritage, including the cumulative effects of developments, are important considerations in the decision-making process.
“All applications are subject to site-specific assessments and our planning and consenting systems ensure that local communities can always have their say.”
Work on planning guidance for Battery Energy Storage Systems (BESS) is underway, and it is expected that the Scottish Government will publish guidance this winter.
