A campaigner in Aberdeenshire wrote to her MSP about our Battery Report and forwarded us this letter which she received from the Planning Minister, Ivan McKee.

Jackie Dunbar MSP

Dear Jackie

Thank you for your email of 29 January on behalf of your constituent regarding concerns around solar and battery energy storage system (BESS) applications. 

We are aware of the report published by Action for the Protection of Rural Scotland and will consider its recommendations as part of our wider work. We will publish a call for evidence on BESS later in 2026 which will help inform a future policy statement on the technology. This will allow everyone, including communities hosting this infrastructure, to share their experiences and suggestions. 

The Scottish Government has also commissioned independent consultants to produce planning guidance on BESS which is intended to increase clarity for developers, and support more consistent decision-making. New guidance will not alter our existing statutory or policy frameworks. 

You will appreciate that it would not be appropriate for me to comment on the merits of any individual proposal as that could be seen as detrimental to the decision-making process. Where new development proposals come forward, our Fourth National Planning Framework (NPF4) ensures the impacts of proposals on communities and nature, including cumulative impacts, are important considerations in the decision-making process.  All applications are subject to site specific assessments. NPF4 policies should be read and applied as a whole, and it will be a matter for the decision maker to determine what weight to attach to policies on a case-by-case basis.  

NPF4 is a significant consideration in assessment of Electricity Act proposals. There is an expectation from Scottish Ministers that in the siting and design of proposals which require section 36 or section 37 consent, developers will seek to find support from as many of the policies within NPF4 as is possible. 

This would include the policy principles relating to biodiversity. 

Whether an Environmental Impact Assessment (EIA) is required, is determined through a formal screening process in line with the Electricity Works (Environmental Impact Assessment) (Scotland) Regulations 2017. Not all projects over 50MW automatically require an EIA. The requirement depends on the characteristics, scale, and location of the development, and the significance of its likely environmental effects. 

Potential impacts on communities, nature, landscape and other valued natural assets are important considerations in the decision-making process. The merits of each proposal are considered on a case by-case basis, and a careful balance must be struck between the potential impacts of the development and the associated environmental, economic, renewable energy and climate change benefits. 

With regard to the continued reference to Scottish Planning Policy (SPP), ECU officials are taking steps to ensure the Scottish Government’s Energy Infrastructure page is updated and references fully aligned with the current statutory framework. 

Finally, you may find it helpful to be aware that we are consulting on increasing the current threshold of 50MW for onshore electricity generating stations to be considered by local authorities. The consultation will run from 30 December 2025 until 27 March 2026 and we encourage stakeholders to share their views: Onshore electricity generation – Electricity Act threshold: consultation – gov.scot. All responses received will be carefully considered before any decision is made. 

Thank you again, and I hope that the above is helpful to you and your constituent. Yours sincerely, 

IVAN McKEE