Development impacts Green Belt, Access and Neolithic Rock Art

We are encouraging our supporters to object to the development of battery storage at Cochno in the green belt, which impacts on core paths and one of the densest and most accessible accumulations of pre-historic rock art in Scotland’s central belt.

Site of the development with respect to the landscape of the surrounding settlements, Faifley, Duntocher, Drumchapel, Milngavie and Bearsden and the Kilpatrick hills.

An application1 for battery storage has been made on green belt land just north of Faifley at Cochno. The site is 29 hectares and, if it were to go ahead, it will be one of the biggest of its kind in Europe.

The proposed development site at Whitehill Farm has seven cup and ring marked rocks, along the boundary, and 9 more within 250m of the boundary, with the immediate area having a total of 24 of these rocks). The Cochno Stone, which is one of the most important and most extensive pieces of prehistoric rock art in Britain2 lies only 500m from the boundary of the development.

You can see from the map below that the site dominates the Neolithic landscape of Cochno and would significantly impact on the setting of the stones. One of the sets of cup and ring marked rocks in this area have been named Whitehill 1-13, after the farm they are clustered around, which si also the location for the battery installation.

Map of locations of cup and ring marked rocks from Canmore 3

The red area denotes the proposed site and grey circles are cup and ring marked rocks. Map from Canmore.org.uk

​APRS is extremely concerned about the effect that this development, were it to go ahead, would have on the ancient landscape of this area and the setting for the Cochno Stone.

A more detailed view showing the position of the 7 closest cup and ring marked rocks to the proposed development, all within 10m of the boundary

The immediate area of the site is also a place of significant walking interest with the site bounded on three sides by core paths and with many other routes of access to and around the surrounding countryside and the Kilpatrick Hills including the long distance route, the Clyde Coastal Path, which goes along the eastern boundary of the proposed development.

Local campaigners observe the site of the Battery Storage Facility from the ‘Druid Stone’ (Whitehill 2). The site extends from the fence just 5 metres from the stone across all the green fields you can see in the photo, past the overgrown hedgerow almost to the woodlands beyond.

See diagram below with site superimposed on screen shot of core paths from NatureScot website

map of core paths taken from NatureScot website with development site superimposed in red.

We are objecting to this development, and we are encouraging anyone concerned about the impacts on the Whitehill cup and ring marked rocks, the setting of the Cochno Stone and associated rock art, the impacts of the green belt, and the access and amenity of the area to make a representation via the Energy Consents Unit Portal.

A view from the cup and ring marked rock Whitehill 6. The Perimeter of the 29 hectare Battery Storage is right up against the edge of this stone and will occupy all the green fields beyond. A cup and ring mark is visible in the photo just left of centre.

Making an Objection to the Development

There are instructions for making an Objection to an Energy proposal here, you need to register with the Energy Consents Unit website to submit it.

The number of the application is ECU00004982 

In the box giving reasons, it will strengthen the points you make if you can refer to planning policy (in the LDP or NPF4) or important to other material considerations. Here are some of the elements we will be commenting on:

Archaeology and the landscape setting

In the NPF4 Policy on Historic Assets and Places it states that:

Development proposals affecting scheduled monuments will only be supported where:
i. direct impacts on the scheduled monument are avoided;
ii. significant adverse impacts on the integrity of the setting of a scheduled monument are avoided; or
iii. exceptional circumstances have been demonstrated to justify the impact on a scheduled monument and its setting and impacts on the monument or its setting have been minimised.

This proposal will have a significant impact on the integrity of the setting of the Cochno Stone, which is a scheduled ancient monument, because the Cochno stone is one of a large group of cup and ring marked rocks. The other 24 cup and ring marked rocks provide the context and setting for the Cochno Stone and seven of them are within 10m of the boundary of the proposed development which sits at the centre of the Whitehill cup and ring marked rocks.

We are extremely concerned about the effect that this development, were it to go ahead, would have on the ancient landscape of this area and the setting for the Whitehill cup and ring marked rocks.

Public Access

Policy 11 Energy in NPF4 says that impacts on “public access, including impact on long distance walking and cycling routes and scenic routes” must be addressed.

The site is a place of significant walking interest with the site bounded on three sides by core paths and with many other routes of access to and around the surrounding countryside and the Kilpatrick Hills, including the long distance route- the Clyde Coastal Route which passes through the middle of the site (according to their website )  but this may have subsequently shifted eastward to where the current core paths are marked.

You can scroll up to see the map with the site superimposed on screen shot of core paths from NatureScot website

Green Belts and brownfield land

Two of the the policy outcomes of NPF4 Policy 8 are that the character, landscape, natural setting and identity of settlements is protected and enhances and also that development is directed to the right locations. 

Whilst policy 8 a) includes renewable energy developments in the list of potentially supported development proposals, no specific mention is made there or battery storage. If we assume that the battery storage is for renewable energy the 5 requirements at Policy 8 ii) must be met for support to be given to the proposal and this is clearly not the case. Specifically it could be located on an alternative site outwith the green belt; it undermines the purpose of the green belt at that location destroying the natural setting, landscape around the settlement and will have significant impacts on recreation and access rights in the area, including impacting on long distance walking routes and core paths. There will be significant visual impact given this is essentially an industrial development with associated fencing and floodlighting. 

There will clearly be significant long-term impacts on the environmental quality of the green belt with an industrial use of the site for at least one or two generations , and wider impacts including light pollution. This kind of development is clearly not compatible with the surrounding established countryside and landscape character. Such a proposal could potentially be accommodated in a green belt sites but only where the pollution and visual impact could be mitigated such as within an old quarry.  NPF4 Policy 9 clearly steers such development to brownfield or derelict land to reduce the need for Greenfield development. Policy 9 b) says that proposals on Greenfield sites will not be supported unless the site has been allocated for development or the proposal is explicitly supported by policies in the LDP. This does not seem to be the case.

Material Considerations

More information on Material Considerations is available here. The two main tests in deciding whether a consideration is material and relevant to a planning decision are the it relate to the development and use of land, and that it should relate to the particular application.

NPF4 is the National Planning Framework 4, part 2 of which contains Scotland’s National Planning Policy. 

Our Representation to Energy Consents Unit

  • Representation on Whitehall BESS  

    This letter is our Objection to the Battery Storage Facility application ECU00004982 on 29 Hectares of Land near Cochno which would impact access, green belt and an important set of Neolithic carved stones

Examining the cup and ring markings at Whitehill 4, this, and three others in the small hazel woodland, are less than 20m from the perimeter of the proposed development.

Dr Kenneth Brophy, the Glasgow University archaeologist who conducted the 2016 excavation of The Cochno Stone said

“The collection of prehistoric carved stones on the north side of Faifley, including the Cochno Stone, represent the best opportunity for people living in central Scotland to be able to visit and enjoy these fascinating ancient sites.

“The Cochno Stone itself is one of the most significant sites of this type in Britain and has a rich modern history that many people locally and who grew up in Faifley have an emotional attachment to. Making sense of the carvings and being able to appreciate carvings that are over 4000 years old are very important aspects of how we engage with our prehistoric past. So, the sites at Faifley are unique in their location beside a large urban population that can be reached on foot and by bus.”

More info on the campaign here:

Our correspondence with Historic Environment Scotland
  • Letter to Historic Environment Scotland

    APRS has written this letter to express concern over the plans for a battery storage facility that will impact on the historic landscape of the Cochno cup and ring marked rocks near Faifley, Dumbartonshire

  • Historic Environment Scotland Reply

    This is the reply from Historic Environment Scotland after we expressed concerns over the plans for a battery storage facility that will impact on the historic landscape.

Note: APRS Role in Responding to Planning Applications

APRS offer advice for people who are opposing unsustainable and unallocated4 development in their green belts – we have lots of online resources people can use and some online training to watch to help get your head around the planning system. We also support campaigners through the Green Belts Alliance.

We do not generally get involved ourselves in objecting to developments unless they are likely to be a key test case or nationally important for determining future policy.

We decided to get involved with this one as, until recently, we very rarely saw applications for large scale energy infrastructure on designated green belt. This is changing fast in response to changes in energy policy and commercial incentives.  The National Planning Framework 4 is now a year old and we are keen to see how the new policies, including on energy, green belts and nature are interacting to influence development in the green belts.

This is a useful case to get involved with as a case study because it is a site of huge importance for access public access and amenity, and the landscape is the setting for some of the most accessible cup and ring marked rocks in Scotland. However it is also only 500m from one of the main substations for Glasgow, meaning it is an extremely attractive site for energy infrastructure, due to the economics.  

A map showing the greenbelt and the site within it.


  1. It is number ECU00004982 and can be searched for using this number on the Energy Consents Unit website ↩︎
  2. The finest set of cup and ring marks in existence’: the story of the Cochno Stone, West
    Dunbartonshire’ Kenneth Brophy http://eprints.gla.ac.uk/158755/1/158755.pdf ↩︎
  3. To find the map – search on ‘cup and ring’ or ‘Whitehill’ in the search bar and then go to ‘map view’ and zoom into the location ↩︎
  4. Meaning unallocated in the Local Development Plan – ie sites that have been designated as green belt in the most recent local development plan. ↩︎

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