APRS Resources

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

Dear Energy Consents Unit

Re: Representation on Whitehall BESS – ECU00004982 

20 February 2024

Thank you for the opportunity to make a representation on the Whitehall BESS application. Action to Protect Rural Scotland (APRS) is Scotland’s longest established environmental charity being founded in 1926 to protect Scotland’s world renowned landscapes and the amenity of the countryside. 

Our objection to the proposed BESS is explained below with the concerns listed in relation to policies in NPF4. We understand that NPF4 is to be read and interpreted as a whole and that as stated in policy 1 in considering all development proposals significant weight will be given to the global climate and nature crises. Whilst the case for any renewable energy generation scheme or battery storage facility can be made to some extent based on contribution to address net zero targets we would argue that they still have to be in appropriate locations, where the benefits clearly outweigh the negative impacts. In this case we feel the impacts on the local area are too great to justify approving the scheme.

Woodland

The intent of NPF4 policy 6 is to protect and expand forests, woodlands and trees. From the proposals seen and Scottish Forestry’s consultation response it is identified that areas of native woodland are going to be adversely affected (see policy 6 b) ii). It is also not clear that mitigation measures will be identified and implemented in line with the mitigation hierarchy (see policy 6 b) iii).

Historic Assets and Places

Part of the policy intent of NPF4 Policy 7 is to protect and enhance historic environment assets and places and one of the identified policy outcomes is to recognise the social, environmental and economic value of the historic environment to our economy and cultural identity.

The historic environment report supplied by the developer seems to have seriously underplayed the extent and importance of the neolithic landscape and assets in the area.  We note that the applicant’s HE desk based report is also rather vague as to what the impact will be on prehistoric/neolithic assets.

From our research and site visits we note that there are 6 cup and ring marked rocks, (which form part of the wider setting of the Cochno stone which is a scheduled ancient monument), along the boundary of the site and 9 more within 250m of the boundary. The Cochno Stone, which is one of the most important and most extensive pieces of prehistoric rock art in Scotland (K, Brophy (2018) “The finest set of cup and ring marks in existence’: the story of the Cochno Stone, West Dunbartonshire. Scottish Archaeological Journal, 40(1),pp1-23. (doi:10.3366/saj.2018.0092))  lies only 500m from the boundary of the development. There appear to be at least 17 identified marked stones in the wider setting (or more if linked stones are counted separately).

You can see from the map below that the proposal site (marked red) dominates the Neolithic landscape of Cochno and would significantly impact on the setting of the stones.

Map of locations of cup and ring marked rocks from Canmore (search on cup and ring marked rocks and go to ‘map view’)

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The stones and their setting have a huge cultural and significance locally and are a major part of the attraction of the area for locals and walkers taking access.  Policy 7 a) and 7 o)  therefore need to be carefully considered. It does not appear that the cultural significance of the stones and their setting has been properly assessed – or  how the setting and wider historic landscape will be impacted.

Map of stones locations with key to coding (from Canmore)

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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 of battery storage. If we assume that the battery storage is for renewable energy, then the five requirements set out at Policy 8 ii) must be met for support to be given to the proposal and this is clearly not the case. Specifically the proposal could be located on an alternative site outwith the green belt; it also undermines the purpose of the green belt at that location destroying the natural setting, and 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 the proposal 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 an appropriate site within designated green belt 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.

Energy

NPF4 Policy 11 gives support for renewable, low-carbon and zero-emissions technology and includes battery storage at policy 11 a) iii). However, it is not clear if policy 11 c) is being met and we are very concerned that the list of impacts at Policy 11 e) have not been addressed by the project design and mitigation.  Many have been ignored or vaguely alluded to rather than fully addressed. These include Policy 11 e) i), ii), iii), vii), viii), ix), xi), xii) and xiii).

Community Wealth Building

The proposed development does not seem to be designed to achieve either of the policy outcomes in NPF4 Policy 25.

Blue and Green Infrastructure

The proposal appears to impact on the local communities accessible green space. It also seems to cover an area where there are real access demands and it is not clear that the overall integrity of the network will be maintained given the impact on Core Paths and long distance walking routes as well as the negative consequences it will have for local access – the site being popular for open air recreation and walking with local people. 

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. The long distance route – the Clyde Coastal route 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. 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.

Diagram showing proposal site (red) superimposed on screen shot of core paths from NatureScot website 

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Business and Industry

NPF4 policy 26 would give support for this development if it was proposed for a site allocated for industrial use in the LDP. However, the site is not allocated for business or industrial use – it is designated as green belt and is a greenfield site. Policy 26 d) says that development proposals to business, general industrial and storage and distribution uses outwith areas identified for those used in the LDP will only be supported where there are no suitable alternatives and ii) the nature and scale of the activity will be compatible with the surrounding area. The nature and scale of the activity are clearly not compatible with the countryside setting, the historic landscape and the public access and recreation usage of the area.

Please do get in touch if you require further information about any of the above information.

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