The Electricity Storage Network (ESN) has been concerned for some time with how the planning regime deals with storage. To debate the issue, we have been running events over the past year and raising the issue directly with the Department for Business, Energy and Industrial Strategy (BEIS). Regen is also working on a project with the Royal Town Planning Institute to understand the potential for the planning system to support the UK’s transition to a smart energy future.

We have responded to BEIS’ recent consultation asking the government to undertake a more comprehensive review of the planning threshold for storage and provide more supportive guidance material for planning officials.

The Smart Systems and Flexibility Plan and the consultation document recognise the difficulties that storage faces in the planning regime, particularly the issue of co-located renewable and storage sites being limited to 50 MW combined capacity under the local planning regime. We welcome the change to allow a site to have 50 MW of generation and 50 MW of storage recognised separately before it triggers the Nationally Significant Infrastructure Projects regime (NSIP). However, the consultation analysis fails to capture the impact that NSIP has on a project and the industry apprehension of going through the regime due to additional costs and time. Many of our members made it clear that they were actively avoiding projects over 50 MW because of the NSIP regime – just looking at National Grid’s transmission connection data shows how many projects are clustered at 49.9 MW (35 out of 41 connections or applications).

Capping capacity at 50 MW

The 50 MW threshold is an arbitrary measure which has been applied retrospectively to storage, having originally been designed for renewable energy generation projects which have very different planning impacts. This is yet another example of the problems encountered when storage is treated as generation. Coming up with an alternative will not be an easy task; simply raising the threshold to a higher capacity will likely result in clustering around the new threshold in the future. Duration is an interesting potential measure, but this is fraught with its own difficulties given how much the impact of increased duration will vary from technology to technology.

The question needs to be approached in a more fundamental way; what is the purpose of the NSIP regime, at what point does storage become ‘nationally significant’, and what are the most important planning impacts that need to be considered?

Improving understanding and knowledge of storage

Speaking with ESN members and others across the industry, it’s clear that the experience of both local and national planning regimes varied considerably, with those involved in the planning process having limited knowledge of storage technologies and even the energy system in general. As a relatively new development encompassing several different technologies, the benefits and challenges of storage need to be fully understood by planning officials in order for the right decisions to be made.

The overwhelming message from the industry is that we need to get this right. We must learn from other technologies, like onshore wind, that have suffered through the planning system. The planning regime must truly reflect the impacts of a storage project – if we set the wrong threshold and do not give planners the information required to properly assess a project, we could find either that storage is being held back by overly stringent rules, or that projects with large impacts are pushed through without proper scrutiny with potentially negative impacts and poor public opinion.

We welcome any additional thoughts on our consultation response which you can read here.

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