BESS Developments in Green Belts

Our Battery Storage report came about because we saw a rise in enquiries from communities about Battery Storage, especially those in Green Belts and that adversely affected biodiversity. One particular enquiry set us off on a path of examining Scottish Government’s Energy Consents Unit (ECU) decisions with respect to NPF4. This update from Nikki, explains.

Update:

We believe our work in this area could be making a difference because, In the Scottish Government’s new Biodiversity Guidance, we spotted slightly clearer wording which could be specifically aimed at ECU. The wording is:

“Our Fourth National Planning Framework (NPF4), published and adopted on 13 February 2023, is a long term plan looking to 2045. NPF4 guides spatial development, sets out national planning policies and designates national developments. It is part of the development plan so influences planning decisions across Scotland. As a statement of national policy, NPF4 will also directly inform decisions under other consenting regimes. NPF4 should be read and applied as a whole. The planning system requires decision makers to weigh up all relevant policies, as well as relevant material considerations, in applying balanced planning judgement (section 25 of the Town and Country Planning (Scotland) Act, 1997, as amended).” Paragraph 1.6

Case Study

APRS’s Green Belts Alliance was contacted back in 2022 by a member of the Ashwood and Woodcroft Green Spaces group over local concerns about a potential speculative proposal for housing development on a designated Green Belt site on the northern edge of Aberdeen. The large site, adjacent to local nature reserves was thought to be owned by a well known national development company.  As it turned out those plans didn’t materialise – perhaps because the site was retained as Green Belt in the new Aberdeen LDP (2023). 

However, towards the end of 2023 we were contacted about the same site – or at least part of it – as a pre-application consultation had started for a new proposal for a PV solar and battery energy storage system (BESS), Lower Bodachra. The proposed development amounted to around 117MW of combined ‘generating capacity’ so being over the 50MW threshold the application process was handled by the Scottish Government’s Energy Consents Unit (ECU) rather than the local planning authority. Responding to the enquiry and considering how NPF4 policies would relate to the proposed development, shaped some of the early APRS advice and information on energy developments.

The ECU decided the application (ECU00004848) in June 2025 and our local contact got back in touch to ask about some of the details of the determination letter, specifically about why an EIA had not been required. In considering the decision notice we were struck that whilst NPF4 was mentioned, it was not being applied as we would have expected.

For instance, under the heading ‘The Development Plan’, the fact of the proposal being in the Green Belt is mentioned and it is stated “The proposal is a suitable form of development on a green belt area as it accords with both National Planning Framework (NPF) Policy 8 and the ALDP NE1. These define the development as essential infrastructure and thus development within the green belt is permitted in principle.”  However, the letter doesn’t refer to the second part of policy 8 a) which sets out 5 requirements which developments also have to meet to gain support from policy 8. (see note at end for the list)

We also noted that the determination letter didn’t refer to NPF4 Policy 3 on biodiversity and the requirement at Policy 3 b) that such a national or major development “will only be supported where it can be demonstrated that the proposals will conserve, restore and enhance biodiversity, including nature networks so they are in a demonstrably better state than without intervention.”

The applicant had provided background information about the biodiversity of the site, responded to comments on that from the RSPB and seemed willing to ensure that biodiversity enhancements did happen. (see page from their prospectus below). The local authority in its comments as a statutory consultee requested that the resulting planning permission should contain a condition on biodiversity enhancement, several consultees raised concern over biodiversity impacts and the RSPB made a similar recommendation to that of the local authority.  However, the determination letter goes on to say that “Scottish Ministers do not agree that a condition to enhance biodiversity is necessary as it goes above and beyond the mitigation required” and none of the planning conditions referred to biodiversity enhancement.

It wasn’t clear to us why enhancement wasn’t required given NPF4 was clearly a material consideration. Adding a planning condition on biodiversity enhancement would also have meant that the planning authority could check the developers promises were delivered.

We, of course, already knew that NPF4 and government policy was extremely supportive of renewable energy developments but there seemed no reason for other policies relevant to an application to be ignored. We wondered if this case was a one-off or if it was how the ECU was applying NPF4 across the piece?  This was the starting point for the APRS research project that has resulted in a report on BESS applications across Scotland to date, published on 3 December. 

It has also led to some ongoing collaborative work with other member organisations of Scottish Environment LINK over how NPF4 Policy 3 is being applied by the ECU including this LINK letter to the Chief Planner that we led on writing.

Note: Excerpt from Policy 8 of NPF4

Policy 8 supports renewable energy developments within Green Belts (which are designated in LDPs) but only provided proposals meet the requirements set out at 8 a) ii) which are the following:

• that it cannot be located on an alternative site outwith the green belt;
• the purpose of the green belt at that location is not undermined;
• the proposal is compatible with the surrounding established countryside and landscape character;
• the proposal has been designed to ensure it is of an appropriate scale, massing and external appearance, and uses materials that minimise visual impact on the green belt as far as possible; and
• there will be no significant long-term impacts on the environmental quality of the green belt.

Extract from the developer prospectus