After being trailed in the Smart Systems and Flexibility Plan in October last year, the government have published proposals to change the planning regime for storage. The Department for Business, Energy and Industrial Strategy (BEIS) released a consultation which proposes to change the threshold for co-located or ‘composite’ storage and generation projects.

We are holding a working group for ESN members to discuss this topic next week with BEIS in attendance to provide an overview of the consultation and answer questions about the proposals. If you’d like to attend this meeting, please get in touch with Madeleine or Hannah.

The current regime can cause problems for co-located projects; any site with a combined capacity of over 50 MW is tipped into the national planning regime – a lengthy and costly process. Adding storage to a site might inadvertently tip the project into the national regime and could deter investment in storage.

BEIS are proposing to change this by allowing up to 50 MW of generation and 50 MW storage to be considered a ‘composite’ project under the local planning regime. This could encourage greater uptake of co-located energy projects, supporting renewables and ultimately benefitting the entire system by optimising generation and increasing flexibility.

For standalone storage however, BEIS have decided not to change the threshold or the unit rate. This raises an important question as to whether storage requires a more appropriate metric based on energy density, which, for batteries at least, can significantly vary the footprint of the asset. For example, a 50 MW/100 MWh battery would still be in the local planning regime, but could have significantly different planning impacts to a 50MW/25MWh battery.

BEIS do briefly debate the merits of changing the threshold metric to MWh, but reject the change due to the additional complexity and lack of economic rationale. In rejecting this change, BEIS are potentially overlooking an important distinction between energy density and capacity which could make a significant difference when assessing the planning impacts of a storage asset, either initially or if the site is augmented at a later date.

However, this does bring into question the logic of treating all types of storage in the same way in the planning regime – considering the planning impact of increased duration will be an important factor in assessing battery storage, but other technologies, hydro or liquid air for example, will need quite different considerations.  These differences highlight the consequences of, once again, lumping storage in the same category as generation; in many ways, some types of storage have more similarities with power equipment than a generating plant, but are treated under one banner by planners.

None of these are easy questions for planning officials or those involved in planning applications – improving the guidance and information available to planning officials would help to mitigate some of these difficulties, but the consultation makes no suggestion of commissioning such guidance.

The changes proposed by BEIS in the consultation are very positive and we welcome the increased threshold for co-located projects, but there is some work to do both by the sector and by government before storage is fully understood and correctly treated in the planning system. We will be working on a consultation response and would welcome any feedback.


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