Scotland’s New BESS Planning Guidance – What Developers Need to Know
On 19 March 2026, the Scottish Government published its first dedicated planning guidance for Battery Energy Storage Systems (BESS), prepared by Ironside Farrar with input from SEPA, NatureScot, SFRS, and industry. Here are our key takeaways.
What Does the Guidance Cover?
The guidance applies to grid-scale BESS (>1MW) and spans the full planning and consenting process – from site selection through to decommissioning. It sets out key design principles across seven topic areas:
- Landscape and visual effects
- Ecology and biodiversity
- Health and safety
- Noise and vibration
- Land use and soils
- The water environment
- Cumulative effects
It is not prescriptive – it does not mandate minimum distances or dictate specific technologies – but it does set clear expectations for how applicants should approach site selection, design, and engagement with planning authorities.
Critically, BESS is classified as essential infrastructure under the NPF4 glossary. This gives it some policy flexibility, particularly around flood risk under Policy 22, but it is not a blank cheque. The test is whether the location is “required for operational reasons”, and that is a judgment for the planning authority to make.
This ties directly into SEPA’s Land Use Vulnerability Guidance from July 2024, which clarified that all forms of renewable, low-carbon, and zero emission technologies (including BESS) fall within the Essential Infrastructure classification. If you haven’t already, it is worth reading our previous blog on this topic: Scotland Flood Risk – Essential Infrastructure.
Flood Risk and Drainage - The Dual-Purpose Challenge
This is where the guidance will have the most practical impact on how BESS sites are designed and consented.
Surface Water Drainage
BESS development typically involves areas of hardstanding for battery containers, electrical infrastructure, vehicle access, and turning areas. This increases surface water runoff, and the guidance is clear that site layouts must incorporate SuDS and surface water management measures in line with the CIRIA SuDS Manual (C753), sized to accommodate runoff without increasing the risk of flooding to others.
Firewater Containment
This is the big one. Lithium-ion battery fires are rare, but when they occur they are challenging to extinguish and can continue to burn for hours or even days. If controlled using water, this can result in large volumes of contaminated firewater runoff posing a pollution risk to soils, groundwaters, and watercourses.
The guidance requires firewater containment measures to be embedded within the overall site drainage design. This may include:
- Isolation tanks
- Bunded lagoons
- Isolation valves and penstocks
- Interceptors and drainage cut-offs
The guidance specifically references SEPA’s GPP18 (Containing Major Spillages and Firewater at Industrial Sites) and the NFCC guidance and position statement.
This means drainage strategies for BESS sites are not just about attenuation rates and greenfield runoff – they need to function as dual-purpose systems, managing routine surface water while also being capable of capturing and containing contaminated firewater in an emergency.
What Does This Mean for Your Development?
If you are bringing forward a BESS project in Scotland, here is what you need to consider:
- Site selection matters more than ever. Brownfield sites, good grid connectivity, and locations that avoid designated landscapes, peatland, and flood risk areas will face a smoother consenting process.
- Firewater containment needs to be designed in from day one. This is not something that can be bolted on at the end – it needs to be integrated into the overall drainage layout alongside SuDS.
- The essential infrastructure classification under NPF4 Policy 22 gives BESS policy support in flood risk areas – but you will still need to demonstrate that all risks of flooding are understood and addressed, and that the location is required for operational reasons.
How Aegaea Can Help
At Aegaea, we have supported many essential infrastructure development sites across Scotland, including BESS, and have been navigating the NPF4 criteria since its publication in 2023. Our team delivers Flood Risk Assessments, hydraulic modelling, and Surface Water Drainage Strategies that account for both routine drainage and the specific firewater containment requirements that BESS sites demand.
If you are planning a BESS development in Scotland and need support with flood risk or drainage, our team is here to help.
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