Item5Appendix3AObjection20220069DETBatteryStorage

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 5 Appendix 3A 23/09/2022

AGENDA ITEM 5

APPENDIX 3A

2022/0069/DET

REP­RES­ENT­A­TIONS OBJECTION

Com­ments for Plan­ning Applic­a­tion 2022/0069/DET

Applic­a­tion Sum­mary Applic­a­tion Num­ber: 2022/0069/DET Address: Land 380M West Of East Croft­more Boat Of Garten Pro­pos­al: Con­struc­tion of bat­tery energy stor­age facil­ity (49.9 MW), con­trol build­ing, switch room, bat­tery stor­age con­tain­ers, invert­er con­tain­ers, land­scap­ing and asso­ci­ated works Case Officer: Emma Wilson

Cus­tom­er Details Name: Address: 

Com­ment Details Com­menter Type: Neigh­bour Stance: Cus­tom­er made com­ments neither object­ing to or sup­port­ing the Plan­ning Applic­a­tion Com­ment Reas­ons: Comment:To CNPA Response from own­er occu­pants of above property

Hav­ing read the plan­ning applic­a­tion from The energy work­shop, we sub­mit the fol­low­ing points and con­cerns. I pre­vi­ously had a reply to my con­cerns from Dan Gri­er­son at Whirl­wind energy who answered some of my quer­ies but did not reply to my fol­low up email, how­ever James Per­kins from the energy work­shop has just replied with some new inform­a­tion. My con­cerns about fire risk, noise and vis­ib­il­ity were only par­tially answered. Vis­ib­ilty. The pho­tomont­ages were taken from 7 loc­a­tions but do not show the infra­struc­ture con­tained inside. Con­sid­er­ing the work that has gone into this research includ­ing from cul­tur­al her­it­age sites I found it odd they would not show the true view. James Per­kins has assured me we will not see any infra­struc­ture from our ground level pos­i­tion. I totally dis­agree and once again ask why he has not provided these pho­tomont­ages show­ing the tops of bat­tery units and build­ings. Its very mis­lead­ing From a level site the tops of build­ings and bat­tery units will still be vis­ible. Some of the sites and loc­a­tions includ­ing our own are high­er so would see into the site even more so. Noise levels I had asked Mr Gri­er­son where per­haps we could see and hear a sim­il­ar site as he had remarked there are already a few, but he declined to declare where we could see one. Instead focus­sing on noise data estim­a­tions full of math­em­at­ics and cal­cu­la­tions which means little in layman‘s terms. Since then James Per­kins gave us the loc­a­tion of one site near Edin­burgh. It is 20 megawatt

pro­ject at Broxburn. We vis­ited the site just a few days ago. The area is semi indus­tri­al land below the air­port flight­path. It is easy to see why the nearest occu­pants which are fully the same dis­tance as we are from the pro­posed site at Boat of Garten would not hear much sound. This site is less than half the size of the pro­posed. Noise levels from it were not excess­ive but the high pitch of the sound was intense when stood by the fence and still quite notice­able at our dis­tance. I would ask for the screen­ing to be closely mon­itored. It was also noted that the tree plant­ing scheme imple­men­ted at Broxburn was in need of main­ten­ance. Dead trees and some strangled in their pro­tect­ors. Hope­fully this new site will be bet­ter maintained.

Fire risk I real­ise these are new gen­er­a­tion Lith­i­um bat­ter­ies and its being sug­ges­ted are much safer than any­thing pre­vi­ously pro­duced which is reas­sur­ing. How­ever its still con­cern­ing liv­ing beside a poten­tial explos­ive hazard.

We are no more than 200 mts away from the pro­posed site not 300 as on some doc­u­ments. We have open views to the sub­sta­tion to the east. (View­point 3)Not just gaps as stated by the Green­cat report. Per­haps some screen­ing can be provided at our home in the form of small trees and shrubs. We know we are for­tu­nate to work and live in such an amaz­ing land­scape and any­thing that dilutes the beauty of Strath­spey is always going to be a bit dis­ap­point­ing. While we feel in prin­ciple this pro­ject sounds like a neces­sary eye­sore it would be help­ful make sure the screen­ing is the best pos­sible. We appre­ci­ate the sub­sta­tion has been there a long time already but it has expan­ded con­sid­er­ably over the years while any forest cov­er has reduced. Yours sincerely

Notes on policy requir­ing cla­ri­fic­a­tion Extracts from the cur­rent CNPA Loc­al Devel­op­ment Plan are provided below with com­ments on the pro­posed devel­op­ment noted in bold: 2.4 Oth­er eco­nom­ic devel­op­ment Pro­pos­als which sup­port or extend the eco­nomy, or which enhance the range and qual­ity of eco­nom­ic oppor­tun­it­ies or facil­it­ies, will be con­sidered favour­ably where they: a) have no adverse envir­on­ment­al or amen­ity impacts on the site or neigh­bour­ing areas; and b) are compatible/​complementary with exist­ing busi­ness activ­ity in the area; and c) sup­port the vital­ity and viab­il­ity of the loc­al economy.

Devel­op­ments that con­trib­ute to the pro­vi­sion of an iden­ti­fied loc­al eco­nom­ic need, such as the pro­vi­sion of small busi­ness units, or con­trib­ute to the deliv­ery of the Cairngorms Nation­al Park Eco­nom­ic Action Plan, will be par­tic­u­larly encour­aged. • These pro­pos­als neither sup­port or extend the loc­al eco­nomy, nor enhance the range or qual­ity of eco­nom­ic oppor­tun­it­ies and/​or facil­it­ies with no loc­al jobs being cre­ated. Only costs to the com­munity are incum­bent in the pro­pos­al, with loss of basic amen­ity for res­id­ents imme­di­ately adja­cent, envir­on­ment­al hab­it­at dam­age asso­ci­ated with con­vert­ing green field land to indus­tri­al use, and the addi­tion­al pres­sure on roads and drain­age infra­struc­ture which are inev­it­able through con­struc­tion and future ser­vi­cing of the site. With the main income stream of the loc­al eco­nomy lying in tour­ism, it can be argued that con­sent for an indus­tri­al devel­op­ment is dir­ectly con­trary to the aims of policy 2.4. • The pro­pos­als will have a dir­ect det­ri­ment­al effect on the hol­i­day let busi­ness of the neigh­bour dir­ectly to the West due to increased levels of con­tinu­ous back­ground noise and loss of visu­al amen­ity. 3.1 Place­mak­ing All devel­op­ments must meet the six qual­it­ies of suc­cess­ful places, which in accord­ance with Scot­tish Plan­ning Policy para­graphs 41 to 46, are to be i. dis­tinct­ive; ii. safe and pleas­ant; iii. wel­com­ing; iv. adapt­able; V. resource effi­cient; and vi. easy to move around and beyond.

• This pro­pos­al con­cerns some 50no. stand­ard sized ship­ping con­tain­ers (12.2m x 2.4m each) and is there­fore con­trary to the aims of policy 3.1. The applicant’s view­point sub­mis­sions appear to have been delib­er­ately based on aspects which would nat­ur­ally have the least visu­al impact and deserve fur­ther scru­tiny. • The scale and dom­in­ance of the pro­posed indus­tri­al install­a­tion over the exist­ing dwell­ings to the West is unac­cept­able due to loss of visu­al amen­ity and poten­tial noise pollution.

• Hav­ing taken advice from an acous­ti­cian, it is under­stood that full mit­ig­a­tion of the cumu­lat­ive noise pol­lu­tion from the exist­ing sub­sta­tion and pro­posed bat­tery stor­age facil­ity is unreal­ist­ic under cur­rent pro­pos­als. It is there­fore strongly recom­men­ded that any noise mit­ig­a­tion pro­pos­als are assessed as part of the applic­a­tion and stand­ards are not applied as con­di­tions. 3.2 Major devel­op­ments Major devel­op­ments of 50 or more homes, or 2 hec­tares or more of employ­ment, retail or mixed use devel­op­ment, will need to be sup­por­ted by a mas­ter­plan or devel­op­ment brief. Where a site is alloc­ated, this require­ment will be out­lined in the Com­munity Inform­a­tion sec­tion of the Plan. Mas­ter­plans and devel­op­ment briefs must demon­strate how the devel­op­ment meets the six qual­it­ies of suc­cess­ful places. • No devel­op­ment brief sup­plied with the applic­a­tion. • The pro­pos­als res­ult in a per­man­ent change of land use from tra­di­tion­al farm­ing to indus­tri­al which is not appro­pri­ate to the loc­al ver­nacu­lar. 3.3 Sus­tain­able Design All devel­op­ment pro­pos­als must also be designed to: a) min­im­ise the effects of the devel­op­ment on cli­mate change in terms of sit­ing and con­struc­tion and, once com­plete, achieve at least the min­im­um stand­ard in com­pli­ance with the Build­ing Stand­ards Tech­nic­al Hand­book; b) be sym­path­et­ic to the tra­di­tion­al pat­tern and char­ac­ter of the sur­round­ing area, loc­al ver­nacu­lar and loc­al dis­tinct­ive­ness, whilst encour­aging innov­a­tion in design and use of mater­i­als; c) use mater­i­als and land­scap­ing that will com­ple­ment the set­ting of devel­op­ment; d) make sus­tain­able use of resources, includ­ing the min­im­isa­tion of energy, waste and water usage, with­in the future main­ten­ance arrange­ments, and for any decom­mis­sion­ing which may be neces­sary; e) enable the stor­age, segreg­a­tion and col­lec­tion of recyc­lable mater­i­als and make pro­vi­sion for com­post­ing; f) pro­mote sus­tain­able trans­port meth­ods and act­ive travel, includ­ing mak­ing pro­vi­sion for the stor­age of bicycles and redu­cing the need to travel; g) incor­por­ate access­ible mul­ti­func­tion­al open space of appro­pri­ate quant­ity and qual­ity to meet the needs of devel­op­ment and provide green infra­struc­ture to con­nect to wider blue/​green net­works; h) main­tain and max­im­ise all oppor­tun­it­ies for respons­ible out­door access, includ­ing links into the exist­ing path net­work and ensur­ing con­sist­ency with the Cairngorms Nation­al Park Core Paths Plan; i) pro­tect the amen­ity enjoyed by neigh­bours includ­ing min­im­isa­tion of dis­turb­ance caused by access to the devel­op­ment site;

j) include an appro­pri­ate means of access, egress, levels of private amen­ity ground, and space for off-street park­ing; k) cre­ate oppor­tun­it­ies for fur­ther biod­iversity and pro­mote eco­lo­gic­al interest; and l) pro­mote good health and well-being. • The devel­op­ment fails to accord with policy 3.3 in the fol­low­ing regards: a) Chem­ic­al bat­ter­ies are an inher­ently envir­on­ment­al dam­aging product con­tain­ing rare earth min­er­als and a high car­bon foot­print in pro­duc­tion. Recyc­ling of bat­ter­ies a their end of life is also prac­tic­ally impossible — the pro­pos­als do not identi­fy how often these bat­ter­ies will need to be replaced over the 50 year pro­posed life of the install­a­tion, but on the evid­ence of oth­er such devel­op­ments, this could be as high as eight replace­ments for each bat­tery – a total of 400 replace­ment events. b) Sig­ni­fic­ant reshap­ing of the land and extens­ive hard­stand­ing con­struc­tion for access and main­ten­ance c) An indus­tri­al site with asso­ci­ated indus­tri­al fin­ish­ing mater­i­als on green field land i) Sig­ni­fic­ant loss of amen­ity for loc­al res­id­ents in terms of views and noise pol­lu­tion k) Dam­age to nat­ur­al hab­it­ats with no pro­pos­als for any mit­ig­a­tion I) Risk of major acci­dent rel­at­ively low, but effects cata­stroph­ic giv­en the prox­im­ity of the dwell­ing and hol­i­day lodge to the West. Bat­tery stor­age facil­it­ies such as that pro­posed have been known to be prone to fire and explo­sion (see Liv­er­pool 2020, Ari­zona 2019) with severe effects to the loc­al envir­on­ment, includ­ing emis­sion of high levels of tox­ic gas. Bat­tery fires require large volumes of water for long dur­a­tions of time, how­ever the applic­ant does not appear to intend to apply for any water con­nec­tion and there­fore it’s unclear how a thermal run­away fire on a lith­i­um bat­tery would be con­tained before caus­ing unac­cept­able envir­on­ment­al dam­age. No risk assess­ment provided. No fire ser­vice response time, access arrange­ments or water sup­ply strategy provided. 4.2 Nation­al des­ig­na­tions Devel­op­ment that would adversely affect the Cairngorms Nation­al Park, a Site of Spe­cial Sci­entif­ic Interest, Nation­al Nature Reserve or Nation­al Scen­ic Area will only be per­mit­ted where: a) it will not adversely affect the integ­rity of the area or the qual­it­ies for which it has been des­ig­nated; or b) any such adverse effects are clearly out­weighed by social, eco­nom­ic or envir­on­ment­al bene­fits of nation­al import­ance, and com­pensated by the pro­vi­sion of fea­tures of equal or great­er import­ance than those that are adversely affected. • Sig­ni­fic­ant adverse envir­on­ment­al effect is anti­cip­ated through the con­ver­sion of green field land to indus­tri­al use with no eco­nom­ic bene­fit loc­ally or nation­ally (the applic­ant is a private enter­prise based in Leeds). 4.6 All development

Where there is evid­ence to indic­ate that a pro­tec­ted or pri­or­ity hab­it­at or spe­cies may be present on, or adja­cent to, a site, or could be adversely affected by the devel­op­ment, the developer will be required to under­take a focused sur­vey of the area’s nat­ur­al envir­on­ment to assess the effect of the devel­op­ment on it and to sub­mit a species/​habitat pro­tec­tion plan where neces­sary to set out meas­ures to avoid, reduce or mit­ig­ate such effects. • No eco­logy sur­vey sup­plied with the applic­a­tion. It is anti­cip­ated that sev­er­al spe­cies will exper­i­ence a det­ri­ment­al effect to their hab­it­at. 5.1 Spe­cial Land­scape Qual­it­ies There will be a pre­sump­tion against any devel­op­ment that does not con­serve or enhance the land­scape char­ac­ter and spe­cial land­scape qual­it­ies of the Cairngorms Nation­al Park includ­ing wild­ness and the set­ting of the pro­posed devel­op­ment. Devel­op­ment that does not com­ple­ment or enhance the land­scape char­ac­ter of the Nation­al Park and the set­ting of the pro­posed devel­op­ment will be per­mit­ted only where: a) any sig­ni­fcant adverse effects on the spe­cial land­scape qual­it­ies of the Nation­al Park are clearly out­weighed by social or eco­nom­ic benefts of nation­al import­ance; and b) all the adverse effects on the set­ting of the pro­posed devel­op­ment have been min­im­ised and mit­ig­ated through appro­pri­ate sit­ing, lay­out, scale, design and con­struc­tion to the sat­is­fac­tion of the plan­ning author­ity. • Con­ver­sion of green field land to indus­tri­al use dir­ectly con­tra­venes the aims of policy 5.1 in so much as it has a det­ri­ment­al effect on the land­scape char­ac­ter and eco­logy of the loc­al area and Nation­al Park as a whole. No loc­al or nation­al eco­nom­ic bene­fits are appar­ent and no mit­ig­a­tion for the loss of wild­life hab­it­at is provided. Policy 7 not applic­able — bat­tery stor­age does not con­trib­ute to any renew­able energy aim and is purely a com­mer­cial ven­ture to bene­fit from excess grid capa­city in times of low demand such that the energy can be sold for a great­er price in times of high­er demand. All profits reside with the Leeds based applic­ant. 10.2 Flood­ing All devel­op­ment should: a) be free from Medi­um to High risk of flood­ing from all sources tak­ing into account pre­dicted impacts of cli­mate change; and b) not increase the risk of flood­ing else­where; and c) not add to the area of land that requires flood pre­ven­tion meas­ures; and d) not affect the abil­ity of the func­tion­al flood­plain to store or move flood waters. In excep­tion­al cases where devel­op­ment is per­mit­ted in a Medi­um to High risk area, water resi­li­ent mater­i­als and con­struc­tion may be required. This may also be neces­sary for devel­op­ment in Low to Medi­um risk areas. Con­sid­er­a­tion should also be giv­en to the type of devel­op­ment pro­posed. For some land uses there may be addi­tion­al flood risk require­ments or con­straints, and an assess­ment of the Low to Medi­um risk area may be needed. Devel­op­ment should only be per­mit­ted for uses of equal or less vul­ner­ab­il­ity in accord­ance with SEPA’s Land

Use Vul­ner­ab­il­ity Guid­ance. Devel­op­ments should incor­por­ate SuDS as pro­por­tion­ate to the scale and nature of devel­op­ment. • No assess­ment of exist­ing or pro­posed over­land flows provided. As such, flood risk is unknown, how­ever an addi­tion­al 2+ hec­tares of hard­stand­ing will undoubtedly have a det­ri­ment­al effect on sur­face water run­off and may con­trib­ute to the high risk area of flood­ing iden­ti­fied adjacent.