Battery energy storage: the planning consent route

Battery energy storage needs planning permission, and since the end of 2020 it is the local planning authority that decides it however large the scheme is. Standalone electricity storage other than pumped hydro was taken out of the national infrastructure consenting regime in England by the Infrastructure Planning (Electricity Storage Facilities) Order 2020, so a 200 MW site goes to the same committee as a housing estate. That has changed how these applications are run, and not always to the applicant's advantage.

Fire safety and noise decide most of them. Landscape decides the rest.

Whether storage is development

Installing containers, transformers, inverters, hardstanding, fencing and a substation on a field is plainly development under section 55 of the Town and Country Planning Act 1990, and there is no general permitted development right for standalone battery storage. A battery inside an existing building that serves that building is a different question, and usually turns on whether external plant or structures are added.

The determining authority is the local planning authority. For a site of 0.5 hectares or more the application will be major development, with the longer determination period and the newspaper advertisement that goes with it.

A Planning Statement carries the policy case, and that case is usually strong. National policy supports the transition to a low carbon energy system and recognises the role of storage in it. The difficulty is rarely the principle.

Screening for environmental impact assessment

Battery storage sits within the Schedule 2 category covering industrial installations for the production of electricity in the Environmental Impact Assessment Regulations 2017, with a site area threshold of 0.5 hectares. Most grid-scale schemes exceed it, so a screening request is the sensible first step rather than an assumption either way.

Screening turns on whether the development is likely to have significant effects by virtue of factors such as its size, location and cumulative effect with other schemes. Storage sites cluster around grid connection points, so the cumulative question is real and is often the one the authority raises.

Where a scheme is screened in, an Environmental Impact Assessment follows, and the regulations require the environmental statement to be prepared by competent experts. A drafted document is a starting point for those experts, never a substitute for them.

Siting, scale and the visual case

A grid-scale site is a field of shipping containers two and a half to three metres high, on hardstanding, behind a security fence, with lighting columns and a substation compound. The honest description helps, because an application that presents it as a discreet installation loses credibility at the site visit.

What the case turns on:

• distance and screening from residential properties and public rights of way
• whether the site is in Green Belt, where storage is likely to be inappropriate development requiring very special circumstances
• the agricultural land classification, since loss of the best and most versatile land attracts objection
• the design of the boundary treatment, since a 2.4 metre palisade fence reads very differently from a hedge and deer fence
• the colour and finish of the containers, which is worth specifying rather than leaving to the supplier

A Landscape and Visual Impact Assessment following the recognised methodology is expected on anything beyond a small compound. Where the site adjoins solar generation, assess the two together, as we discuss in the context of solar canopies and their planning route.

Fire safety and the consultees who care

This is the issue that generates objections, committee questions and local campaigns, and the technical answer is well established even though public anxiety is not.

Lithium-ion cells can enter thermal runaway, producing heat and flammable and toxic off-gassing. The design response is separation, detection, suppression, containment and planning for the fire service rather than any single measure. Expect the application to be judged on:

Engage the fire and rescue service before submission rather than during consultation. Their response carries weight with members out of proportion to its formal status, and a written comment that the applicant has engaged early is worth having in the officer's report. Consultation arrangements for storage applications have been under review, so confirm the current position with the authority rather than assuming.

The water environment matters here too. Firewater run-off is the mechanism by which a battery fire becomes a pollution incident, and the containment design should be shown on a drawing rather than described in a sentence.

Noise from inverters and cooling

Battery sites are quieter than a gas peaking plant and noisier than people expect, and they run at night.

The sources are the inverters, the transformers and the cooling systems, and the character of the sound is the problem rather than the level. Transformer hum is tonal, inverter switching produces tonal content, and cooling fans cycle. Under BS 4142 those characteristics attract corrections that can add several decibels to the rating level.

Three practical points. Assess the night period properly, because charging and discharging follow the market rather than the working day. Model the worst credible operating case, with all cooling running on a hot night, rather than an average. And where the nearest receptor is close, consider the layout before the mitigation: putting the transformers and inverters on the far side of the container rows is free, and an acoustic barrier is not.

A Noise Impact Assessment should state the assumed operating regime and recommend a limit that can be conditioned and measured.

Grid connection and the separate consents

The connection is a separate commercial and consenting track, and it drives the programme.

A connection offer from the network operator fixes the point of connection, the capacity and the date, and that date is frequently years out. The cable route from the site to the connection point may cross third party land, needing easements, and may need street works consents where it follows the highway. Overhead lines need consent under the Electricity Act 1989, which is a separate application from planning permission.

None of this is within the planning application, and all of it affects whether the permission is ever implemented. Set out the connection position in the planning statement, because an authority asked to permit an industrial installation in open countryside reasonably wants to know the scheme is real.

Conditions and decommissioning

Expect a long condition list. The ones that matter commercially:

1. A battery safety management plan to be approved before use starts, prepared with the fire and rescue service.
2. Noise limits at identified receptors, with a verification test after commissioning.
3. Landscaping and boundary treatment, with a management period.
4. A construction traffic management plan, given the abnormal loads involved.
5. External lighting, usually restricted to operational and emergency use.
6. A temporary permission, commonly 40 years, with a decommissioning and restoration scheme.

Negotiate the decommissioning condition rather than accepting a standard draft. A requirement to restore the land to its previous condition within a short period of the site ceasing operation is reasonable. A bond or financial guarantee is sometimes sought, and whether it can be required depends on the circumstances.

An illustrative case: a 49.9 MW scheme on 1.2 hectares beside an existing substation, screened out of environmental impact assessment on the basis of the site's existing industrial character. The objections were almost entirely about fire. The applicant commissioned an independent fire safety review, met the fire and rescue service twice before submission, redesigned the layout to give appliance access on all four sides, and added a lined attenuation basin for firewater. The scheme was approved at committee with 11 conditions. The technology had not changed. The explanation had.

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