This report summarises the findings from a research project carried out by APRS between August and November 2025, into Battery Energy Storage Systems (BESS) in Scotland.
The report includes the process for determining applications and grid connections, the distribution of current and future developments, current UK and Scottish Government policy covering renewable energy infrastructure, and an analysis of decision making in planning applications. Our findings draw on publicly available data, which we have brought together to do some new analysis. The report concludes with a set of policy recommendations requiring urgent consideration in light of the evidence.
Background and Methods
Battery Energy Storage Systems play an increasingly critical role in enabling a decarbonised electricity system. By storing excess electricity generated from renewable sources, primarily wind and solar, BESS facilities help balance supply and demand, releasing stored power during periods of peak demand or reduced renewable generation. BESS delivers short duration storage (under 4 hours). Long-duration energy storage (LDES) technologies such as compressed air, gravity storage, hydrogen, pumped hydro and flow batteries are expected to complement short-duration systems, particularly for discharge durations beyond eight hours.
The project analysed 421 Scottish BESS applications recorded in the Department for Energy Security and Net Zero’s Renewable Energy Planning Database (REPD) as of Q2 2025. Detailed planning analysis was conducted on all 53 consented applications over 50 MW (those assessed by the Energy Consents Unit, ECU, of the Scottish Government), and a randomly selected sample of 26 Local Authority applications at just below the 50 MW threshold. Of the 53 ECU sites, 9 were co-located with renewables and the rest were stand-alone BESS. Planning documents, environmental reports, consultee responses, community engagement materials, and satellite imagery were examined to assess environmental and biodiversity considerations, land use and spatial impacts, and approaches to local engagement.
Applications were evaluated using criteria across three categories:
- Environment and Biodiversity (e.g. whether significant local biodiversity impacts are noted, whether an EIA was required, whether biodiversity surveys or protections were conditioned, and whether biodiversity enhancement was required.)
- Land and Spatial (including cumulative impact, whether it is fully or partially in woodland and whether it is on agricultural land) and
- Local Engagement (how many local consultation events took place, number of objections)
For analysis of applications within Green Belts we used GIS data. Records with missing, incomplete, or inaccurate data were excluded from the relevant parts of the analysis. For analysis relevant to all planning applications we used the whole dataset of REPD, but for any analysis of applications in the ‘Planning Pipeline’ we only used those applications that were still current and excluded those that were refused, abandoned, withdrawn, expired and decommissioned.
Key Takeaways from the Analysis
For references, figures and more detail please read the full report. Analysis is up to Q2 2025.
There is a huge oversupply of battery storage in the Planning pipeline.
The most recent figures from NESO, show that, for the UK, the current BESS capacity in the queue to 2030, including already built capacity of battery storage (49.8GW), is already greater than the maximum required installed capacity under any scenario at 2030 (25.2GW) and even 2050 (40.4GW).
[Planning pipeline means all applications in local authority planning systems and ECU combined. Our calculations include applications awaiting permission and appeal, awaiting construction, under construction and completed. It excluded those refused, abandoned, withdrawn, expired and decommissioned.]
This situation is even worse in Scotland where there is four times more capacity in the Planning pipeline than the maximum required by 2030, and 3.4 times more than the maximum needed by 2050.
The figures are not broken down for Scotland in the NESO report but we know, from a Freedom of Information request to the Scottish Government, that NESO modelling shows that Scotland will require 5.9-6.4GW of BESS storage by 2030, rising to 6.4-7.6GW by 2045. There is 24.8GW in the Planning pipeline as of June 2025 and 13.5GW consented (Fig. 1)
We also checked for decisions up to the present date (November 2025) and 4.74 GW of BESS over 50GW has been consented since 1 July 2025 making a total of 18.2GW.
Figure 1: Capacity of BESS in the Scottish planning pipeline (navy) and consented (blue) compared to NESO modelled projections for BESS requirements in 2030 and 2050 in Scotland. Planning data from UK Government’s Renewable Energy Planning Database, REPD, Projection of capacity requirements in 2030 and 2045 NESO, visualisation by APRS using Datawrapper.
Applications continue to rise and the size/capacity of applications is increasing
Consented capacity is increasing rapidly as there is a trend for applications for larger battery storage sites. 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. Quarter 2 2025 (our most recent data) saw the joint highest number of applications (31) of any Quarter.
Large battery storage applications are almost never refused.
We found that the ECU has never refused an application for stand-alone BESS. Four that are marked as refused in the table were co-located with another energy project (wind farm) that was turned down. Checking decisions since Q2, there have been no cases that ECU refused a BESS to the present date (November 2025).
Battery Energy Storage Systems, both consented and proposed tend to cluster, therefore affecting some communities disproportionately.
We are seeing BESS in highest density in Caithness, along the Moray coast and all the way down the East coast, across the Central belt, Ayrshire and Dumfries and Galloway. Highland shows the highest number by Local Authority area followed by Aberdeenshire, whereas South Lanarkshire has the most capacity (3.5GW)
Environmental Impact Assessments (EIAs) are generally not required for Battery Energy Storage Systems.
Only six of the 56 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. None of the sample of smaller local authority BESS consents we looked at had required an EIA.
Scotland’s National Planning Framework (NPF4) is being badly ignored by ECU:
Energy Consents Unit (ECU), the division of the Scottish Government which deals with planning applications for energy infrastructure over 50MW is not taking due account of National Planning Framework 4 in their decision making. For decisions taken under the Electricity Act, the Development Plan (NPF4 together with the relevant Local Development Plan) is a material consideration. However, we found that they are overly relying on one NPF4 policy (Policy 11: Energy) to justify the importance of a development, while ignoring other policies which are relevant to the proposed development – see list below. Scottish Ministers have made it clear that NPF4 ‘should be taken as a whole’ and this is evidently not happening.
Our research demonstrates that the ECU are not paying proper attention to the following subjects, covered by NPF4, in their decision making:
● Green Belts
two Freedom of Information Requests (FoIs) show that ECU does not hold this information in relation to applications they are dealing with and do not ask applicants for it.
● Brownfield first
Brownfield sites do not seem to be being assessed as to whether there are alternative Brownfield sites nearby where developments could take place, (the ECU, in an FoI, said they do not hold or ask for this data for applications they assess)
● Cumulative impacts
Very few decision notices contain mention of cumulative impacts and almost all of these are in the summaries of consultation responses.
● Biodiversity Enhancement
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.
● There are other areas worthy of further GIS analysis, which we only did for Green Belts, for example the impact on prime agricultural land.
Battery storage is more often planned and consented in more deprived areas
From the 350 sites in the database which have a postcode associated with them, 227 are in postcodes more deprived than the median data zone. and 123 in those less deprived than the median data zone.
There is a lack of Standards and Guidance on Battery storage
There is a big gap in guidance and standards for BESS, especially for safety standards.
Figure 2: Data from APRS’s research using documents from Planning Portals and Data from UK Government’s Renewable Energy Planning Database, REPD, visualisation by APRS using Datawrapper. We looked at all ECU consents (n=53) and a sample of Local Authority consents (n=26)
Conclusions
The consenting system for battery storage, especially those that go to ECU, is failing to distinguish between applications, and prioritise permission for the best proposals in the most appropriate locations. ECU is widely disregarding Scotland’s National Planning Framework, as reflected in decision letters and via Freedom of Information responses showing ECU does not request the key information they need for good decision making, such as the presence of brownfield land, or whether a site lies within the Green Belt. Proposals for biodiversity enhancement from developers, and suggested conditions from Local Authorities, rarely appear in ECI’s final planning conditions.
This situation is not being helped by ECU retaining reference to Scottish Planning Policy on its website, which was superseded by NPF4 two years ago. This is despite emails from APRS alerting both ECU and Planning Directorate to the issue.
ECU’s approach is creating uncertainty around biodiversity enhancement. Developers and infrastructure providers expect to deliver such improvements, but Ministers risk sending a message that energy infrastructure will be prioritised at any cost, undermining nature and the biodiversity aims of NPF4.
We believe that BESS projects are perceived as easy to gain approval for, fuelling speculative applications and this opportunistic approach risks allowing developments that could hinder more strategic future needs. The resulting overcapacity in Scotland’s planning pipeline, is contributing to long grid-connection delays. We are concerned that 40-year permissions will lead to permanent land-use changes, leaving sites unlikely to return to their previous undeveloped state and that granting industrial development in the Green Belt may set a precedent for further erosion of these protections.
Decision-makers, especially the ECU, but also Local Authorities, must take a more discerning approach and begin applying NPF4 properly. However, in addition, decision makers need additional guidance in terms of where the required battery capacity is needed, and how much is required.
In the Scottish planning system, which has no right of appeal for communities, the plan-led system is essential. The Scottish government expects there to be front-loading of planning decisions in Local Development Plans, which allow the public, business and other stakeholders a proper process for consultation and input. However, although the consent of energy projects is through the Planning System, the strategic planning of these projects is not. We suggest that Battery Energy Storage Systems should become part of the Local Development Plan process to enable a far more strategic and place-based approach.
Large BESS projects, as energy infrastructure, are classed as ‘National Development’ under NPF4 but are mostly built by private companies for profit, not public benefit. This makes it even more important that planning for these developments is part of the democratic systems set up to ensure a balancing of different stakeholder, environmental and community interests.
Policy Recommendations
1. Large battery storage should be on Schedule 1 of the Environmental Impact Assessment (EIA) Regulations
This would mean that all applications for large battery storage sites (over 50MW) would be required to conduct an EIA.
2. A moratorium on all new consents for battery storage until a more strategic approach is agreed on
This will not harm our net zero targets – we already had twice as much consented by June 2025 as is needed by 2030 and nearly twice as much as needed by 2050. We need to balance supply with demand, and with the amount in the planning system, we can afford to choose the right development for the right place.
3. A spatial strategy and Planning Guidance for battery storage
The NESO modelling will not be in the detail needed – the regional modelling takes Scotland as a region – and so this more granular work will still need to be done in Scotland and is particularly urgent for battery storage.
4. All decisions on BESS to be made at Local Authority level
This should ensure better local democracy and decision making and ensure the NPF4 is more transparently considered in decision making. This is the case in England at present. Until this is the case:
- ECU should be required to include all conditions requested by the Local Authority in the decision letter.
- ECU should consider all relevant NPF4 Policies in every consent decision and deemed planning permission.
5. BESS sites should be included in the Local Development Planning (LDP) Process
This will enable far better local engagement, will enable NESO input to advise where battery storage is required and ensure we have the right development in the right places, Brownfield first and out of Green Belts (except on specific appropriate sites which meet the criteria in NPF4) and where there are significant impacts on biodiversity.
6. There should be national standards on battery Safety
We need nationally mandated standards for BESS to ensure safety for communities, workers and the environment.
7. Scottish Fire and Rescue Service (SFRS) should be a statutory consultee for all BESS applications
At present SFRS are not a statutory consultee for applications made under the Electricity Act 1989 (BESS developments over 50MW).
About APRS
Action to Protect Rural Scotland (APRS) is Scotland’s countryside charity. Since our founding nearly a century ago, we have worked to protect, enhance and promote Scotland’s countryside and rural landscapes for the benefit of everyone. We believe that the quality of our surroundings is central to well-being, and that Scotland’s countryside is vital, not only for those living in rural areas but also for all those living in towns and cities. The countryside is fundamental to addressing the climate emergency, reversing the nature crisis, and supporting livelihoods and resilient communities.
We started looking into issues of battery storage due to a huge increase of enquiries from local people about BESS proposals in their area. Many of these queries were related to proposals on Green Belt, or which impacted on biodiversity and heritage.
You can learn more about our work and find out how to join us or support us at:
Acknowledgements
This report is down to the sheer hard work from two incredible volunteers, Katie Woodward, who wrote the policy sections, created the visualisations, figures and maps, and did the GIS work, and Cameron Luck, who spent countless hours bringing together the huge spreadsheet of data and searching through planning portals in order to read reams of paperwork for each consented installation. Dr Kat Jones did the data analysis, key takeaways, summary, discussion and recommendations. We are very grateful for comments and input from members of the APRS Board, Nikki Sinclair, colleagues at CPRE, and some external specialists.
[1] Planning pipeline means all applications in local authority planning systems and ECU combined.
Our calculations include applications awaiting permission and appeal, awaiting construction, under construction and completed. It excluded those refused, abandoned, withdrawn, expired and decommissioned.