Grid Stability Facility Land north west of Rothienorman Substation
Planning Statement
WP Grid Services Ltd December 2020
Grid Stability Facility : Land north west of Rothienorman Substation
Contents
1.0 Executive Summary 1 Planning Application Submission 2 Report Structure 2
3.0 Background to the Applicant and the Development 3 The Applicant 3 Need for 3 Site Selection 4
4.0 Site Context 6 The Site and Surroundings 6 Planning History 7
5.0 The Proposed Development 8 Grid Stability Facility 8 Access 9 Drainage 9 Landscaping 9 Operation 10
6.0 Planning Policy Assessment 11 Relevant Planning Policy and Guidance 11 National Policy 11 Development Plan 12 Other Material Considerations 15
7.0 Planning Policy Assessment 16 Principle of Development 16 Landscape and Visual Impact 18 Access and Transport 19 Noise and Vibration 19 Flooding and Drainage 20 Arboriculture 20
8.0 Conclusions 23
Grid Stability Facility : Land north west of Rothienorman Substation
1.0 Executive Summary
1.1 This Planning Statement supports an application for planning permission for the erection of a grid stability facility including grid stability unit, ancillary equipment, access, landscaping, drainage, car parking, and boundary enclosures at land north west of Rothienorman Substation.
1.2 The development will provide vital stability services which are required as Scotland transitions toward increasing reliance on renewable energy sources such as wind and solar. To provide this stability, a standalone stability system is required and a particular need has been identified at Rothienorman.
1.3 This development will ensure the electricity network can be safely operated in a net zero-carbon world in which electricity is only supplied by low-carbon sources like nuclear, wind and solar and is increasingly moved through interconnectors and HVDC links.
1.4 The development will have multiple benefits including:
• Upgrading the grid;
• improving the efficiency of renewable energy;
• increasing capacity for more renewables in Scotland;
• zero emissions;
• cheaper energy; and
• blackout mitigation.
1.5 It will be a key component in supporting the transition to a Net Zero electricity system and assisting with Scotland’s net-zero target for 2045.
1.6 Having considered the potential impacts of the proposed development against the relevant national and local policy, the technical assessments that have been submitted with the planning application demonstrate that there will be no significant adverse impacts on local amenity, biodiversity, transport, flood risk, landscape/visual, noise or lighting or ground conditions.
1.7 The proposed development has been assessed against relevant planning policy and is in compliance with the aims of the National Planning Framework 3, Scottish Planning Policy and both the Aberdeen City and Shire Strategic Development Plan and the Aberdeenshire Local Development Plan.
1.8 The proposed development is therefore entirely appropriate at this location and will be a key benefit to assist with Scotland’s net-zero target for 2045.
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2.0 Introduction
2.1 This Planning Statement has been prepared by Lichfields on behalf of WP Grid Services Ltd (“the applicant”/ “WP Grid Services”) to accompany an application for planning permission to Aberdeenshire Council (“the council”) for a grid stability facility to the north west of Rothienorman Substation, which is currently under construction.
2.2 The accompanying planning application specifically seeks permission for:
2.3 Erection of a grid stability facility including grid stability unit, ancillary equipment, landscaping, drainage, car parking and boundary enclosures. Planning Application Submission
2.4 This document considers the planning merits of the application proposal against the terms of development plan policy and national planning policy and guidance.
2.5 This Statement should be read in conjunction with the other documents that have been submitted with the planning application including: 1 Drawings package; 2 Design and Access Statement; 3 PAC Report; 4 Acoustic Technical Report 5 Accessibility Statement 6 Flood Risk and Drainage Impact Assessment 7 Preliminary Ecological Appraisal Report 8 Phase 1 Contamination Assessment 9 Phase 2 Geo-environmental Assessment 10 Landscape and Visual Impact Assessment Report Structure
2.6 This document is structured as follows:
• Section 2 provides an overview of the Applicant and the background to the project
• Section 3 describes the site and its context;
• Section 4 describes the proposed development;
• Section 5 identifies the planning policy context of relevance to the proposed development;
• Section 6 assesses the development against relevant planning policy considerations; and
• Section 7 provides conclusions.
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3.0 Background to the Applicant and the Development
3.1 The project forms part of Ancillary Services being introduced by National Grid ESO (‘NGESO’). The purpose of this is to ensure the electricity network can be safely operated in a zero-carbon world in which electricity is only supplied by low-carbon sources like nuclear, wind and solar and is increasingly moved through interconnectors and HVDC links. The Applicant
3.2 The Applicant, WP Grid Services Limited, is a subsidiary of Welsh Power, which is a business with a long history in the generation and supply of electricity. WP Grid Services has been formed specifically to develop projects that support the transition to a Net Zero electricity system. Need for
3.3 Whereas historically power has been generated in large coal- and gas-fired power stations that have inherent stabilising qualities; wind turbines, solar farms and interconnectors do not have the same stabilising properties and therefore there is now a need for standalone stability systems such as the proposed Grid Stability facility to service Rothienorman Substation and the surrounding transmission network. Rothienorman substation is being built as part of the “north east 400kV upgrade”, which is a major project being undertaken by Scottish Hydro Electric Transmission in order to facilitate increased power flow through this part of Scotland. Stability of this part of the network is therefore especially important.
3.4 Before the coronavirus pandemic, National Grid was spending circa £20 million per month managing renewable energy generation due to the lack of infrastructure available to stabilise the network. This is a direct result of the decommissioning of traditional coal-fired power stations, such as Cockenzie and Longannet. In the near future, the closure of Hunterston nuclear power station will make this problem more acute in Scotland. The Coronavirus pandemic has worsened the problem as reduced demand means a larger proportion of our electricity is coming from low- carbon sources. Earlier this year National Grid Electricity System Operator, which operates the national electricity transmission network (NGESO), had estimated spending an additional £500m over the summer managing renewable energy generation, costs that could be reduced with investment in stability hardware. In many respects this is a signal of things to come as further renewable generators come online.
3.5 As a response to this, NGESO is developing an initiative to stabilise the generation of renewable electricity within the grid. In their pilot procurement exercise, NGESO procured services that it estimated would save consumers in Great Britain up to £128 million over six years. NGESO have now announced a larger procurement exercise focused on Scotland. This will include new infrastructure such as the grid stability hardware proposed at Rothienorman and is expected to save customers many times this value through the 2020s.
3.6 Facilities such as the one proposed as well as providing stability may also form part of NGESO’s strategy for addressing Black Start events, or blackouts, in Scotland in the future. It is therefore expected that this development will play a role in restoring service swiftly and safely following any blackouts in Scotland.
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Site Selection
3.7 WP Grid Services has undertaken a site selection process across Scotland to identify locations which are most suitable for this new technology. This process has included consideration of the following factors:
• Proximity to suitable substations
• Planning Policy Support
• Access
• Drainage and Flooding
• Heritage
• Noise and Vibration
• Ecology
• Ground Conditions
• Landscape
3.8 These criteria have led to Rothienorman being selected. It is one of 4 locations in Scotland which WP Grid Services is currently progressing proposals on.
3.9 A short explanation against each heading is set out below:
Proximity to suitable substations
3.10 This is one of the most important criteria in identifying suitable sites. NGESO has identified the need for grid stability equipment at Blackhillock and Peterhead.Rothienorman is therefore well sited in that a single development here could meet the need of both Blackhillock and Peterhead, thereby reducing the number of sites which require to be developed.
3.11 The proximity to the substation that the development will connect to has a bearing on its efficiency, so finding a site as close as possible to a suitable substation was a key consideration. The development site selected is as close as possible to Rothienorman Substation.
Planning Policy Support
3.12 Lichfields review of potential sites around Scotland on behalf of WP Grid Services considered whether the principle of development could be justified in the development plan. Some planning authorities have policies which specifically support electricity infrastructure, others are silent and some specifically preclude development in certain locations.
3.13 In this instance, as is explained later in this planning statement, the SDP supports such development, but the LDP is silent, in which case SPP’s “presumption in favour of sustainable development” comes into play.
Access
3.1 While the development once operational will have minimal vehicle movements, the ability to take access onto the local road network and that being suitable to facilitate construction and maintenance was a key consideration in identifying sites. The ongoing construction of the new substation on the adjacent site means that this ability is already established and was a consideration in selection of this location.
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Drainage and Flooding
3.2 The ability to suitably drain the site and develop in a location free of flood risk was also a consideration and is considered later in this statement.
Heritage
3.3 Given the nature of the development, avoiding locations which if developed could result in adverse impact upon built heritage featured in our site finding exercise. In this instance there are no listed buildings, designed landscapes, battlefields or Scheduled Monuments in the vicinity.
Noise and Vibration
3.4 The Grid Stability Equipment will generate some noise once operational. While this can be mitigated through scheme design, it was considered important to identify sites which are not immediately adjacent to sensitive residential receptors. At Rothienorman, the application site achieves the greatest distance to the nearest residential property which would be approximately 350m away.
Ecology
3.5 Site appraisals identified any ecological designations which may be prohibitive to development. None were identified on or around the Rothienorman Substation.
Ground Conditions
3.6 While investigative work wasn’t undertaken until after sites had been selected, initial appraisals sought to identify sensitive land such as prime agricultural land, peat and wetlands, none of which are present at Rothienorman.
Landscape
3.7 Avoiding sensitive landscape designations was also a consideration, as was identifying existing or emerging landscape features against which the development would be set. In this instance the substation which is under construction on the adjacent site alongside other electricity infrastructure in the area was a factor in identifying an appropriate landscape setting.
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4.0 Site Context The Site and Surroundings
4.1 The application site extends to approximately 10.67 hectares is located immediately adjacent to the Rothienorman Substation which is presently under construction and approximately 1.5m to the east of Fisherford.
4.2 The main body of the application site lies to the north west of the substation and it is here in which the Grid Stability Facility would be located. This area is currently an agricultural field and has been so for the last 100 years. The site is irregular in shape and is comprised of 3 distinct components.
4.3 The principal development area is at the northernmost part of the application boundary area. It is quadrilateral in shape and slightly slopes downwards to the south. Whilst the area is recognised as agricultural field there is infilled pond close to the eastern boundary.
4.4 The site boundary also includes a length along the western boundary of the substation site for formation of an access and extends into the substation site to enable a grid connection.
4.5 There is no public access to the site or public rights of way traversing it.
Figure 4.1 Application Site Boundary
Source: WP Grid Services Ltd
4.6 The main body of the site is fairly level with lows of 158AOD and 159 AOD at its eastern and western sides respectively, with a central point which is slightly higher at around 165AOD. The linear length along the side of the substation site falls to the south to around 135AOD.
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4.7 The site is surrounded by agricultural fields to the north, east and west. Aside from the substation construction site immediately to the south the surrounding area is predominantly undeveloped land similar to the site itself. There are high voltage overhead electricity lines present in the area, a run of which is set back 10m from the western boundary.
4.8 Geological mapping of the area shows the site to be underlain by Till (diamicton) over Macduff Formation (micaceous psammite, semipelite and pelite). The site is identified on the Scottish Environment Protection Agency (SEPA) web-based flood map to be in the low probability flood area (Flood Zone 1).
4.9 A single residential property lies approximately 300m east of the main body of the site. A further two residential properties lie 300m to the east and 600m to the west of the point that the site boundary meets the unnamed road on its southern most side. Planning History
4.10 As highlighted above the site itself is previously undeveloped and is not the subject of any specific planning history. However, outlined below in the planning history for the neighbouring land:
• ENQ/2011/0397 - Erection of Six Hectare 275 / 400 Kv Substation Site, Including Site Access, Site Drainage, Landscaping and Construction Areas – PAC Agreed
• APP/2011/2038 - Construction of 400/275KV Electricity Substation & Switchgear Building Surrounded by Palisade Security Fence and Formation of Landscaping and Access Tracks – Approved
• APP/2014/3443 - Vary Condition 1 to Extend the Period of Consent (APP/2011/2038) – Approved
• APP/2014/4259 - Erection of 3 No. Wind Turbines (Hub Height 30m, Total Height 49.9m) and Associated Infrastructure – Withdrawn
• APP/2015/0528 - Erection of 1 No. Wind Turbine (Hub Height 30m, Total Height 49.9m), Substation Building and Associated Infrastructure – Refused
• APP/2017/3238 - Construction of 400/275KV Electricity Substation & Switchgear Building Surrounded by Palisade Security Fence and Formation of Landscaping and Access Tracks Without Compliance with Condition 1 (Landscaping) of Planning Permission Reference APP/2014/3443 – Approved
• ENQ/2018/0988 - Erection of Electricity Substation Comprising Platform Area, Control Building, Associated Plant and Infrastructure, Ancillary Facilities, Access Track and Landscape Works – PAC Agreed
• APP/2018/2175 - Erection of Electricity Substation Comprising Platform Area, Control Building, Associated Plant and Infrastructure, Ancillary Facilities, Access Track and Landscape Works – Approved
• APP/2018/2773 - Two new terminal towers (101A and 102A on the Blackhillock to Kintore 275 kV overhead line) and three new towers, including one terminal tower (201C, 201B and 201A on the Peterhead to Kintore 275 kV overhead line) to connect into the proposed Rothienorman substation – No objection
• APP/2019/0506 - Overhead Lines Between Blackhillock Peterhead Substation And Kintore Substation – No objection
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5.0 The Proposed Development
5.1 This planning application seeks full planning permission for:
“The erection of a grid stability facility including grid stability unit, ancillary equipment, landscaping, drainage, car parking and boundary enclosures” Grid Stability Facility
5.2 WP Grid Services has worked closely with its technology provider to design the proposed Grid Stability Facility for Rothienorman.
5.3 The Grid Stability Facility will include an electricity transmission infrastructure compound, transformers and cables/infrastructure running into a main plant room building housing the stability equipment. Coolers are connected to the equipment to ensure that they do not overheat, and control rooms are provided to enable the smooth running of the facility, as are back-up and safety systems.
Figure 5.1 Proposed Site Plan
Source: WP Grid Services Ltd
5.4 The development will be made up of a number of components:
5.5 Firstly, the principal building which will house the grid stability plant will lie in the centre of the main development site, positioned slightly to the south and parallel with the southern boundary. It will stand 12.05m tall at its apex and 10m tall at eaves level. A lower level section at its
Pg 8 Grid Stability Facility : Land north west of Rothienorman Substation
western side would stand 6m tall with a flat roof. The total building footprint would measure 2,106sq.m gross, being 54m long by 39m wide. The full height component would make up 1,490sq.m of this footprint, at 38.2m by 39m.
5.6 The building would in the 12m high section contain 2no pieces of grid stability hardware each of which would be encased within internal housing.
5.7 The flat roof part of the building would serve as a control room and area for storage of spare parts and equipment.
5.8 The building on its eastern elevation would have 2no roller shutter doors (7m high by 5.5m wide) 2 domestic scale doors on the outside edge of the roller doors and 2no louvres (2m by 1m) on the inside of the roller doors.
5.9 The northern and southern elevations would each have 2no domestic scale doors on each side, one leading into the main grid stability equipment hall and the other into the control room. The northern elevation would have 3 windows at ground floor level.
5.10 The western elevation at ground level would have 2no roller shutter doors measuring 4m high, plus 2no domestic scale doors leading into the control room area. At first floor level, above the control room area would be 2no louvres (2m by 1m).
5.11 The external surfaces of the main plant building would comprise non reflective metal cladding coloured green-grey (RAL7009).
5.12 Transformers will connect the main building to external transmission infrastructure to the south of the building. This would take the form of piped cabling at upper level from the main plant hall, over the control room into an EHV compound at the south western side of the site.
5.13 A grid connection would be made into the neighbouring substation. This would take the form of an underground cable leading from the EHV compound and into the substation to the south.
5.14 Ancillary plant such as cooling equipment and back-up generators would be situated around the building. Back-up generators with an associated covered fuel unloading bay would sit to the north of the building. Access
5.15 Access would be taken from the local road network to the south. A new access would be formed adjacent to the one for the substation. The new access road would run the length of the substation site to the east (approximately 900m long) into the site.
5.16 Ten parking bays would be provided around the site, one of which would be for disabled access and one with an electric vehicle charging point. The parking bays would be used by maintenance and delivery vehicles, of which there would normally be no more than one on site at a time. Drainage
5.17 An attenuation basin would be located at the south western side of the facility, between the EHV compound and eastern edge of the site. This would be supplemented by swales along the length of the proposed access road with a further attenuation basin adjacent to the public highway. Landscaping
5.18 A cut and fill exercise would be undertaken which would see a flat development platform formed at a slightly lower level than as existing. Bunds would be created to the north and east of the
Pg 9 Grid Stability Facility : Land north west of Rothienorman Substation
development which would mimic the rolling countryside surrounding as well as providing screening.
5.19 New planting would include mixed native woodland to the north and west of the Grid Stability Facility. An avenue of specimen broadleaf trees would be planted along the eastern edge and new hedgerow would be planted along the southern side of the facility and the access road.
5.20 The periphery of the site will be secured with a post and stock fence with palisade fencing around the compound. Operation
5.21 The site would operate unmanned under normal conditions, with weekly maintenance visits made by operatives.
5.22 The back-up generators would be tested monthly, but other than these components would remain unused at all times, except on the occasion of a Black Start Event if one were to occur.
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6.0 Planning Policy Assessment
6.1 This section provides an assessment of the proposed development against key planning policy and guidance. Relevant Planning Policy and Guidance
6.2 The planning policy and guidance documents which are of relevance to the planning application are as follows:
• National Planning Framework 3 (‘NPF3’) – Approved June 2014, NPF3 is the long-term spatial strategy for Scotland;
• Scottish Planning Policy (‘SPP’) – Approved June 2014, SPP sets out the Scottish Government’s planning policy which is applicable across Scotland. It confirms that although it is a non-statutory document, it is capable of being a material consideration in the determination of planning applications;
• The Aberdeen City and Shire Strategic Development Plan – Approved March 2014, provides the vision and spatial strategy which will guide development throughout the North East up to 2035;
• Aberdeenshire Local Development Plan (‘LDP’) – Adopted 2017; Other Material Considerations
6.3 The outlined documents below would be material considerations to the application:
• Proposed LDP (Adoption expected 2021) National Policy
National Planning Framework 3
6.4 NPF3 was approved in June 2015 and sets out Scotland’s “spatial priorities for change”.
6.5 The document states its intention to move Scotland into being a “low carbon place” and it will “continue to take action to help generate the equivalent of 100% of Scotland’s gross annual electricity consumption from renewable sources by 2020, with an interim target of 50% by 2015” (Page 68).
6.6 NPF3 states “the low carbon energy sector is fast moving and will continue to be shaped by technological innovation and a changing environment. As a result, our strategy must remain sufficiently flexible to adapt to uncertainty and change so we are well placed to make the most of the new opportunities that will undoubtedly emerge” (page 32) .
6.7 The low-carbon sector is a much required and growing industry in Scotland for both cities and rural areas and this is noted by NPF3 which states “Planning of rural towns and their surrounding areas must support low carbon living, decarbonisation of heat and transportation” (Page 35).
6.8 It also highlights that this move towards more sustainable methods of energy will require upgrades as “Electricity grid enhancements will facilitate increased renewable electricity generation across Scotland. An updated national development focusing on enhancing the high voltage transmission network supports this and will help to facilitate offshore renewable energy developments)” (Page 35).
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Scottish Planning Policy
6.9 Scottish Planning Policy was approved in June 2014 (with a subsequent amendment approved in December 2020) and its outcome 2 states that the SPP’s intention is “reducing our carbon emissions and adapting to climate” (Page 6).
6.10 It proposes that to achieve this the planning system should “support the transformational change to a low carbon economy”, “support the development of a diverse range of electricity generation from renewable energy technologies – including the expansion of renewable energy generation capacity – and the development of heat networks” and “guide development to appropriate locations”.
6.11 SPP considers a number of policies of relevance to the proposed development:
• Energy infrastructure developments should give consideration to landscape and visual impacts, including effects on wild land. It also advises giving due consideration to cumulative effects.
• Energy infrastructure developments proposals should consider the impact noise on communities and individual dwellings
6.12 SPP contains a “presumption in favour of sustainable development” the terms of which are considered further later in this Planning Statement. Development Plan
The Aberdeen City and Shire Strategic Development Plan
6.13 The Aberdeen City and Shire Strategic Development Plan (SDP) was approved in August 2020. This replaces the 2014 SDP under which the current adopted local development plan was prepared.
6.14 The SDP identifies 4 Strategic Growth Areas (SGAs) in the city region, and all land outwith these SGAs is classed as Local Growth and Diversification Areas (LGDAs). While the SGA boundaries are loosely defined in plan form without fixed boundaries, it does not appear as though the site falls within the nearest SGA, that being the Aberdeen to Huntly SGA.
6.15 In relation to LGDAs the SDP notes (Paragraph 3.44) that “opportunities to service the renewable energy industry will be key to promote, develop and encourage.”
6.16 It goes on to state (Paragraph 3.47) that “All development that meets more than local needs will generally be located within the Strategic Growth Areas. However in some cases, development which aims to meet more than local needs may be appropriate in the Local Growth and Diversification Areas. In these cases, developers will need to justify this against the vision, aims, strategy, and targets of this Plan. Meeting sustainable economic or regeneration needs could be part of this justification.”
6.17 In relation to Sustainable Development and Climate Change the SDP in Paragraph 6.15 states that “We will… need to tackle the supply of energy during the Plan period. This will involve increasing the supply of heat and power from renewable sources, as well as supporting reduced emissions from existing power stations. There remains some additional capacity for onshore wind, and there is still considerable potential in offshore renewables yet to be realised. This is in addition to opportunities for energy from waste, solar and biomass, as well as ground, water and air source heat pumps.”
6.18 It further states (Paragraph 6.16) that “A more diverse mix of renewable energy sources, along with storage, will be needed if we are to meet Scottish Government renewables targets, make
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best use of the resources available, and ensure continuity of supply to serve communities and businesses across the City Region. This will mean upgrading key North-East and East Coast electricity transmission lines from 275 kilovolts to 400 kilovolts.”
6.19 The document also states:
6.20 “With energy continuing to play a significant role to the economy, energy connections to and from the City Region are important. Energy network improvements are proposed for both on and offshore. The upgrading of the North-East and East Coast electricity transmission lines traverses the City Region from Kintore substation (with connection from the new Rothienorman substation) via Fetteresso substation and southwards towards Central Scotland.”
Aberdeenshire Local Development Plan
6.21 Aberdeenshire Council adopted its Local Development Plan (LDP) on 17 April 2017.
6.22 The site lies in the Fortmartine area. It is outwith the Green Belt and the LDP’s Strategic Growth Areas, lying in the wider rural area.
6.23 There are a series of polices which any future application may be assessed against. The Shaping Development in the Countryside section of the LDP contains policies R1 and R2 which are considered below. In the preamble it states:
“Some development proposals, such as extracting minerals, need a rural location or can have a significant effect on our landscape, and as such we design policies to tackle these concerns. We consider our policy on wind turbines under the ‘Climate change’ section.”
6.24 It is noteworthy that the LDP acknowledges that some developments require a rural location and confirms that policies are prepared to suit.
Policy R2 Housing and employment development elsewhere in the countryside
6.25 The site is outwith the greenbelt and coastal zone therefore Policy R2 applies. This states that the council will restrict development in the countryside to small scale development that would:
• Be appropriate in the greenbelt; or
• Involved the refurbishment or replacement of a building on site; or
• Involve the remediation of redundant brownfield land.
6.26 Small Scale Development is defined in the Glossary as being a site no bigger than 350m2 (a large house plot); 3 dwellings; or in the case of employment, a site of less than 0.5 hectares and employing 5 or less full time people.
Policy R1 Special rural areas
6.27 Although the site is not in the greenbelt, Policy R2 makes reference to the greenbelt policy. Policy R1 sets out the types of development which will be permitted in the greenbelt. This includes:
• “development for the purposes of agriculture, forestry, horticulture, nature conservation or essential public infrastructure;…
• development identified as a national priority in the National Planning Framework;…
• developments (including community infrastructure) under Policy PR2 may be permitted in the greenbelt where they meet an established need and where it can be adequately demonstrated that no alternative location can be found.”
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Policy PR1: Protecting important resources
6.28 The council will not approve developments that have a negative effect on important environmental resources associated with the water environment, important mineral deposits, prime agricultural land, peat and other carbon rich soils, open space, and important trees and woodland.
Policy P4: Hazardous and potentially polluting developments and contaminated land
The council will not support development if there is a risk that it could cause significant pollution, create a significant nuisance, or present an unacceptable danger to the public or the environment.
Policy E1: Natural heritage
New development which may have an adverse effect on a nature conservation site designated for its biodiversity or geodiversity importance will not be supported, except where particular circumstances apply.
Development should seek to avoid any detrimental impact on protected species through the carrying out of surveys and submission of protection plans describing appropriate mitigation where necessary. A baseline ecological survey should be prepared for all major developments.
Policy E2: Landscape
“The council will refuse development that causes unacceptable effects through its scale, location or design on key natural landscape elements, historic features or the composition or quality of the landscape character. These impacts can be either alone or cumulatively with other recent developments.”
Policy C2: Renewable energy
The council will support solar, wind, biomass (energy from biological material derived from living, or recently living organisms) and hydroelectricity developments which are in appropriate sites and of the right design. The policy focuses specifically on renewable energy generation but not on associated infrastructure.
Policy C3: Carbon sinks and stores
6.29 This policy seeks to protect woodlands and carbon rich soils. It specifies the use of the Carbon Calculator tool to demonstrate that the loss of peatland or woodland will be offset during the lifetime of the development.
Policy C4: Flooding
6.30 Flood risk assessments will be required for development proposals in the medium to high category of flood risk of 0.5%-10% annual probability (1 in 200 years to 1:10 years). Assessment may also be required in areas of lower annual probability (0.25-0.5%) in circumstances where other factors indicate a potentially heightened risk.
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Policy RD1: Providing suitable services
The council will only allow development that provides adequate road, waste management, water or waste water facilities, connections and treatment as appropriate. All developments must provide for access by wheelchair users and people with sensory disabilities (access arrangements are required for children and the elderly however that is not applicable for this development) and safe and convenient access should also be provided for service, delivery and other goods vehicles required by the development.
6.31 New accesses should be designed to an agreed standard.
6.32 Waste water and sewage can be treated by private arrangements where connection to the public sewer is infeasible and evidence supports private arrangements. Surface water must be dealt with sustainably.
Policy HE1: Protecting historic buildings, sites, and monuments
6.33 New developments will not be supported if they have a negative effect on the character, integrity or setting of listed buildings, or scheduled monuments, or other archaeological sites. Other Material Considerations
Proposed Local Development Plan
6.34 The proposed LDP is at Stage 2 of the local development plan process. Consultation has now closed and the proposed LDP was presented to Full Council on 5th March 2020 where local members agreed that the content of the proposed plan 2020 provides the settled view of the council. It is anticipated that the new LDP will be adopted in 2021 following examination by Scottish ministers.
6.35 Fundamentally the requirements of the proposed policies are broadly similar to the existing policy. The policies we note for consideration are:
• Policy R2 Development Proposals Elsewhere in the Countryside
• Policy R1 Special Rural Areas
• Policy PR1 Protecting Important Resources
• Policy P1 Layout, Siting and Design
• Policy P4 Hazardous and Potentially Polluting Developments and Contaminated Land
• Policy E1 Natural Heritage
• Policy E2 Landscape
• Policy C2 Renewable Energy
• Policy C4 Flooding
• Policy RD1 Providing Suitable Services
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7.0 Planning Policy Assessment
7.1 The assessment initially considers compliance with National and Regional Policies before turning to assess the proposals against the policies of the current development plan, comprised of the SDP (approved 2020) and LDP (adopted 2017), set out in relation to the below topic headings: Principle of Development
7.2 The achievement and deliverability of sustainable development and a low carbon future is embedded in both national and local policy. The low-carbon sector is a much required and growing industry in Scotland and NPF3 states its intention to transition Scotland toward being a “low carbon place”.
7.3 NPF3 acknowledges that electricity grid enhancements will facilitate increased renewable electricity generation across Scotland. In order to facilitate the move to a low carbon future and NGESO’s aim of a zero carbon electricity system, the proposed grid stability unit servicing Rothienorman Substation and the surrounding network will allow multiple sources of renewable and low-carbon energy to feed into the grid efficiently and safely. The proposed development is considered a key component to meeting the national targets and compliant with the aims of NPF3 and SPP which supports the development of a diverse range of electricity generation from renewable technologies.
7.4 The proposed development is considered a key component to meeting the national targets and compliant with the aims of NPF3 and SPP which supports the development of a diverse range of electricity generation from renewable technologies.
7.5 Similarly, the SDP notes “opportunities to service the renewable energy industry will be key to promote, develop and encourage.”. The proposed development is precisely the type of development which provides further means of moving away from traditional methods of energy generation and toward renewables.
7.6 In paragraph 6.15 the SDP acknowledges the need to upgrade key North-East and East Coast electricity transmission lines from 275 kilovolts to 400 kilovolts, an upgrade of which this proposal forms part.
7.7 The SDP recognises that in Local Growth and Diversification Areas such as that in which the site is located, development which meets more than a local need can be brought forward with sufficient justification against the vision, aims, strategy and targets of the SDP. This justification can include sustainable economic need.
7.8 The vision in the SDP references resilience and sustainability, with energy being a target industry for growth. The aims include sustainability, using resources more efficiently and to take on the urgent challenges of climate change.
7.9 The development proposals meet these criteria by:
• Introducing resilience to the grid through stabilisation and black out mitigation;
• Improving efficiency in the grid and its ability to accom0date renewable energy resources;
• Facilitating the growth of the renewables industry through increased capacity; and
• Through the attributes listed above, contributing toward tackling climate change.
7.10 The LDP defines the site as being within the countryside but beyond either the greenbelt or the coastal zone. The relevant policy covering this area is Policy R2: Housing and employment
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development elsewhere in the countryside. As the development would not take place on brownfield land and nor would it make use of an existing building, the only test left is policy R2 - whether the development might be acceptable in the green belt (although not greenbelt the green belt policy test can still apply).
7.11 The tests for green belt development are set out in Policy R1: Special rural areas. This states that development for essential public infrastructure can be acceptable in the green belt where they meet an established need and where it can be adequately demonstrated that no alternative location can be found.
7.12 As the national policy highlights there is a recognised national plan for a move to renewable energy and on this basis the development does fall under the need for essential public infrastructure. Without development of this nature the national targets will not be able to be met and nor will the transition towards greater reliance on renewables. Furthermore, the site has been chosen located immediately adjacent to the substation being constructed to the south east, allowing for easy connection and maximum efficiency, making the proposals compliant with Policy R1.
7.13 The wording of Policy R2 is such that it is only to apply to housing and employment uses in the countryside and only to small scale proposals of this type (with small scale being defined in the Glossary). It does not therefore bite in this instance as the proposals are neither housing, nor an employment use as they do not comprise uses 4, 5 or 6, nor is it expected at this stage to result in direct on site employment post-construction.
7.14 The LDP’s climate change section includes Policy C2 which would apply in this area, but this is solely concerned with renewable energy developments and make no reference to ancillary supporting infrastructure associated with them.
7.15 The LDP is silent on all other uses in the countryside and on electricity infrastructure beyond renewable generation. None of the policies referred to above specifically preclude development such as that proposed by way of a negative wording.
7.16 This results in an unusual situation where the proposed development could be easily justified in the more heavily protected green belt area but in the less pressurised rural area in which the site is located and a specific locational need exists a specific policy hook, positive or negative, is absent.
7.17 In the absence of specifically relevant policy, the proposals are given support by Scottish Planning Policy in which includes the “presumption in favour of sustainable development”. Paragraph 33 goes on to confirm that “Proposals that do not accord with the development plan should not be considered acceptable unless material considerations indicate otherwise. Where a proposal is for sustainable development, the presumption in favour of sustainable development is a material consideration in favour of the proposal .”
7.18 The subtext to the presumption sets out (Paragraph 29) policy principles which policies and decisions should be guided by. These include:
• giving due weight to net economic benefit;
• responding to economic issues, challenges and opportunities, as outlined in local economic strategies;
• supporting delivery of infrastructure;
• supporting climate change mitigation and adaptation; and
• avoiding over-development, protecting the amenity of new and existing development and considering the implications of development for water, air and soil quality.
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7.19 The proposals fully accord with these policy principles as they:
• Will result in economic benefit through improving efficiency in the grid resulting in savings which will be passed down to the consumer, by supporting jobs during construction and beyond and through increasing capacity for the growth of the renewables industry in Scotland and the rest of GB;
• Will increase capacity for the growth of the renewables industry which is identified in the LDP to be an increasing component of the local economy;
• Represent the delivery of infrastructure;
• Will support climate change mitigation and adaptation through the transition to renewables; and
• Have been carefully sited and designed to consider amenity, water, air and soil quality as is evident through the supporting documents which form this planning application.
7.20 It is therefore clear that, in the absence of specific policy in relation to grid enhancements, the proposals are fully aligned with the policy principles in Paragraphs 28 and 29 of SPP and, if considered against the presumption find strong support.
7.21 In light of the above, it is concluded that the principle of development is aligned with NPF3, SPP, the SDP (Paragraphs 3.44 and 3.47) and in the absence of a relevant policy in the LDP, SPP’s presumption in favour of sustainable development. The principle of development is therefore acceptable. Landscape and Visual Impact
7.22 Landscape and visual impact is protected by Policy E2 which advises new development proposals will be refused they if have an unacceptable impact on key natural landscape elements, historic features or the composition or quality of the landscape character as set out above.
7.23 As part of the application, a Landscape and Visual Appraisal Report was undertaken by SWECO in November 2020. The appraisal identified potential receptors around the site then considered 7 representative viewpoints in response.
7.24 The appraisal concludes that long term visual effects arising from the development on 5 of the 7 viewpoints would be negligible. Only 2 would experience long term effects, these being minor. The report confirms that this outcome has been achieved through a number of mitigation strategies that have been employed, including:
• “Selection of a site already affected by the presence of existing electricity infrastructure
• Careful positioning of the main plant building in relation to the existing substation and landform
• Setting the building into the slope approximately 1.5m below existing ground level and incorporation of planted bunding to the north east of the main plant building, approximately 2 – 3m above existing grade, to hasten the levels of visual screening achieved
• Use of a simple block treatment of grey-green colour for the main plant building to help integrate the building into the largescale landscape pattern. Where the building is often viewed as sitting against a backdrop of land. This will also visually blend into the earthworks on the northern edge.
• New planting to screen the development and to integrate it with the landscape context and existing tree belts to the north and south.”
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7.25 The proposals are therefore in accord with Policy E2 of the LDP. Access and Transport
7.26 Access to new development sites is covered by Policy RD1: Providing suitable services. The policy advises that developments will only be supported where there are adequate road connections.
7.27 An Accessibility Statement has been undertaken by MLM Group which considers the access for vehicles associated with the proposed development. A new access would be formed onto the local highway network to the south (C46S). The access would achieve visibility splays of 2.4m x 90m in each direction, which is comparable to that utilised for the adjacent substation access. Vehicle tracking has been undertaken which demonstrates the ability for large vehicles to safely access and egress the site.
7.28 Construction access is considered in the Accessibility Statement, with delivery/extraction routes proposed to the west, avoiding the nearby settlement of Rothienorman.
7.29 Trip rates post construction are anticipated to be very low, with 1-2 visits per week.
7.30 Further details can be found within the Accessibility Statement. On the basis of the above the proposals are in compliance with Policy RD1: Providing suitable services. Noise and Vibration
7.31 SPP states that energy infrastructure development proposals should consider the impact noise on communities and individual dwellings. It further notes that applications where operational arrangements including noise impact have been satisfactorily mitigated should be supported.
7.32 There is no specific policy in the adopted LDP regarding noise and vibration, so the analysis reverts to an assessment of national policy.
7.33 An assessment of the potential noise impacts associated with the development has been undertaken by MLM Consulting Engineers Ltd.
7.34 An initial assessment was carried out in early November 2020. Monitoring equipment was positioned at the northern and southern extremities of the site, to gather data representation of the nearest residential receptors in each direction. Upon receipt of the survey data it became evident that the daytime measurements were affected by ongoing construction work at the substation site and that the night-time measurements were affected by 2no construction compound generators which were running at the construction site overnight.
7.35 In response, MLM agreed with officers of Aberdeenshire Council to revert to the data in surveys undertaken by Scottish and Southern Energy in 2018 which supported the application for the adjacent substation development. This represented a baseline scenario which was free of construction noise in normal conditions.
7.36 Using this baseline and applying a predicted noise rating for each component, plus worst case scenario correction for the predicted noise levels arising from the substation once operational, MLM’s assessment finds that during both daytime and night-time the noise from the proposed development is predicted to have low impact at the nearest and most affected residential receptors.
7.37 The sound from the plant will not exceed the night-time limits proposed and agreed with the Local Authority, provided that the plant is constructed and operated in accordance with the acoustic assumptions of the assessment.
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7.38 As a result the proposals meet the terms of SPP in relation to protection of residential amenity. Flooding and Drainage
7.39 Matters of Flooding and Drainage is covered by Policy PR1: Protecting important resources and Policy C4 Flooding. Policy PR1 states that new development, including aquatic engineering works, which will generate discharges or other impacts on existing water bodies, or which could affect the water quality, quantity, flow rate, ecological status, riparian habitat, protected species or flood plains of water bodies (including their catchment area) must not prejudice water quality or flow rates, or their ability to achieve or maintain good ecological status.
7.40 A Flood Risk Assessment and Drainage Impact Assessment has been prepared and submitted as part of the planning application.
7.41 The assessment initially found that the best infiltration rates are found to the east of the site and initial designs reflected this accordingly. However, as a result of the outcome of pre-application consultation a private water supply was identified to the east and the layout and drainage design has been amended in response.
7.42 An infiltration basin is now proposed to the west of the main compound, with an attenuation swale along the length of the access road. A second attenuation basin is proposed adjacent to the new access where it joins the existing road.
7.43 A septic tank is proposed to address foul drainage, in the absence of potential to connect to the public network. This would be emptied at suitable intervals under private arrangements.
7.44 The assessment shows that the development is in compliance with Policy C4: Flooding as they will not contribute to flooding issues elsewhere and Sustainable Urban Drainage principles have been applied. It is also compliant with Policy RD1 of the LDP in relation to provision of private arrangements for foul drainage. Arboriculture
7.45 NPF3 does not have any specific policy regarding arboriculture however states its intention to increase the rate of woodland creation. Similarly, SPP states that where appropriate, planning authorities should seek opportunities to create new woodland and plant native trees in association with development.
7.46 Policy PR1: Protecting important resources from the adopted LDP states that the support opportunities for new woodland creation and/ or enhancement, in line with the Aberdeenshire Forest and Woodland Strategy which provides a focus for new planting, restocking, enhancement and management of trees and woodlands.
7.47 There are no mature trees or planting on the site and for this reason an Arboricultural Assessment has not been produced to support the application after discussion with the council. New planting has been proposed to screen the development and lessen its visual impact. This new planting is in line with national policy.
7.48 An Outline Landscape Scheme has been produced and submitted with the application.
Ecology
7.49 Policy E1: Natural heritage advises that any new development should seek to avoid any detrimental impact on protected species through the carrying out of surveys and submission of protection plans describing appropriate mitigation where necessary.
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7.50 A Preliminary Ecology Appraisal was undertaken by SWECO in July 2020. The PEA highlights no activity of bats, badgers, otters, water voles, amphibians or Non-Native Species (INNS) on this site.
7.51 A number of bird species were recorded during the site visits. While no bats were identified within the survey area, three tree features were identified during the site visit which have potential to be used by bats for roosting owing to the presence of cavities which offer shelter or protection. However, none of these features are within the area proposed for development and all offer low bat roost potential.
7.52 The Site is not located within any statutory designated sites and the closest statutory designated site is outside the distance in which hydrological and ecological connectivity would be expected to occur.
7.53 SWECO have set out a number of requirements and recommendations in order to minimise adverse ecological impacts to notable habitats and species. The main recommendation to promote biodiversity by planting hedges has been incorporated in the landscaping proposals.
7.54 While there are no habitats or flora on site, it is recommended that vegetation clearance and felling be avoided or minimised as much as possible.
7.55 Desk study records and direct observation show that the Site and surrounding 2km area is suitable for a wide variety of bird species. It is recommended that vegetation clearance works and ground investigations be undertaken outwith the nesting bird season (which is March to August inclusive) and if the works programme cannot be amended to facilitate this, that a pre- works check for nesting birds be undertaken by suitably qualified ecologist no more than 48 hours prior to works.
7.56 No bats were sited during the visit however it is recognised that they are likely to use the Site and wider survey area for foraging and commuting. It is recommended that overnight working is avoided and that any artificial lights used during construction are directed away from the lines of mature trees in order to reduce disturbance and changes to bat behaviour. It is also recommended that if tree felling is unavoidable, an equivalent area of land is planted with shrubs and trees to replace the habitat which would be lost.
7.57 As noted above, no signs of badger were observed within the Site or 50m buffer. However it is recommended that a pre-works survey for badgers be undertaken by a suitably qualified ecologist to ensure that there are no active setts within the proposed work area or disturbance distance of it (typically a minimum buffer of 30m is required between any works and active setts; and buffers of up to 100m is more appropriate if particularly disturbing works such as pile driving or blasting were to be undertaken) and to inform any potential licence applications or specific mitigation measures which may be required in order to protect badgers.
7.58 There are no ponds which would provide breeding opportunities for amphibian species present within the Site or 50m survey area and amphibians are not considered to be a constraint to development. It is recommended that during vegetation clearance or clearance of any potential hibernacula a pre-works check for these species should be conducted by a suitably qualified ecologist. If any reptiles are found during pre-construction checks, they should be moved to safe receptor areas outwith the works area.
7.59 No Invasive Non-Native Species were recorded at the Site. Desk study results show that Himalayan balsam and Rhododendron is present within 2km of the site. As INNS are, by their very nature, invasive and vigorous colonisers there is a risk that INNS may spread along linear features (road or watercourses) and colonise the Site. It is therefore recommended that an
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update survey of the Site and any ancillary works area is undertaken prior to the works commencing.
7.60 In light of the above the proposals can be considered compliant with Policy E1 of the LDP.
Geo-environmental
7.61 Matters regarding ground conditions are protected by Policy PR1: Protecting important resources and Policy P4: Hazardous and potentially polluting developments and contaminated land.
7.62 Policy PR1 seeks to protect prime agricultural land as well as peat and other carbon rich soils. Whilst being agriculture field the land is not recognised as prime agricultural land by either The James Hutton Institute or the council’s own map as is therefore in compliance with Policy PR1.
7.63 Policy P4: Hazardous and potentially polluting developments and contaminated land states that development on land that is known or suspected to be contaminated unless appropriate site investigations have been undertaken.
7.64 A Phase 1 Contamination Assessment was undertaken by MLM in August 2020 and demonstrated that the site has been an agricultural field since pre-1868 until present day.
7.65 A Phase 2 Geoenviromental Assessment was subsequently undertaken and found that the site makeup was 0.25m bgl topsoil, 2.5m bgl till and 3m bgl Macduff Formation (micaceous psammite, semipelite and pelite).
7.66 Soil contamination which could potentially significantly affect human health during the construction and/or operation of the proposed development was not identified, nor were ground gases.
7.67 Based on the information presented no significant potential sources of contamination that could impact on receptors have been identified. On this basis, no further mitigation is proposed and the proposals are in compliance with Policy P4.
7.68 As no Carbon rich soils were identified as part of the investigations this part of Policy PR1 is not required.
Heritage
7.69 Historic assets are protected under Policy E2: Landscape which states developments would have an unacceptable impact on historic features. There are no listed buildings, scheduled monuments or designed landscapes in or around the site.
7.70 In light of the above we find the proposals are compliment with Policy E2: Landscape as there are no unacceptable impacts on any historic features.
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8.0 Conclusions
8.1 The proposed Grid Stability Facility will perform a vital role in ensuring a reliable energy supply in the national electricity grid. With Scotland’s energy generation industry switching to renewable energy the ‘inertia’ that was an inherent part of traditional coal- and gas-fired power stations is no longer available to provide stability to the electricity network.
8.2 It is therefore necessary to develop standalone facilities that can provide the same role. This will be delivered by the Grid Stability Facility that is proposed north west of Rothienorman Substation.
8.3 Having considered the potential impacts of the proposed development against the relevant national and local policy, the technical assessments that have been submitted with the planning application demonstrate that there will be no significant adverse impacts on local amenity, biodiversity, transport, flood risk, landscape/visual, noise or lighting or ground conditions.
8.4 The proposed development is therefore entirely appropriate at this location and will be a key benefit to assist with Scotland’s net-zero target for 2045.
8.5 The proposals are in accordance with both the statutory development plan and with the overarching aims and objectives of national planning policy guidance. In light of the above it is respectfully submitted that planning permission should be granted.
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