Electricity Storage Network responds to National Fire Chiefs Council consultation

The Electricity Storage Network (ESN) has responded to the National Fire Chiefs Council (NFCC) consultation on revised planning guidance for battery energy storage systems (BESS). This guidance supersedes previous guidance from 2023 and progress has been made in key areas, such as on spacing between units. However, we believe further revisions are necessary to provide greater clarity in other areas and to ensure the guidance does not represent a barrier to development.

ESN has been engaging with NFCC via our Sustainability, Safety & Supply Chain Working Group and recognises NFCC’s work to update its planning guidance following feedback from industry. While there has been progress in the revised draft, such as on minimum spacing between units, there remains uncertainty in some areas, including the interaction between the guidance and local planning authorities. ESN is calling for greater clarity, regular updates (e.g. every 2 years) and for some of the revisions to go further.

Thanks to all those members who engaged with us over the past two years via our Sustainability, Safety & Supply Chain Working Group.

Below is a summary of ESN’s key messages:

Scope of Guidance 

• We disagree with the potential for retrospective application of the guidance to projects already in development or operational. We recommend that NFCC explicitly rule out retrospective application.
• We advocate for regular updates to the guidance, at least every two years, to ensure it reflects the latest technology and industry practices.
• The guidance should be clear about where it applies.

Planning Approval Process

• There is a need for greater clarity on how the guidance should be used by local planning authorities. The current draft also creates uncertainty regarding the role of discussions with local fire and rescue services during the planning process. We recommend that NFCC provide more detailed guidance on the interaction between its guidance and the planning process, to avoid inappropriate use in planning decisions.
• Inconsistent engagement from fire services during the planning stage creates challenges for developers, highlighting the need for standardised practices.
• The guidance does not account for the differing availability of site details during stages of project development.

System Design, Construction, Testing, and Decommissioning

• The current guidance suggests providing information to the fire and rescue service (FRS) via local planners, which could cause delays. Direct communication between developers and FRS is preferred.
• There is uncertainty about the applicability of Fire Prevention Plans to BESS projects, highlighting the need for clarification.

Site Location and Access

• The continued emphasis on a second access point to BESS sites poses a significant barrier to development, especially given the challenges of site constraints near electricity substations. We recommend that NFCC consider alternative access solutions, such as a loop of track around sites, joining a single external access road with two access points.

Water Supplies  

• We disagree with the recommendation for large static water supplies for fire suppression, given that water is generally not effective in addressing a BESS fire. We recommend that the guidance be amended to reflect that lower water supply volumes may be appropriate when manufacturers do not recommend water-based suppression. Clarity is needed on criteria for determining lower volumes of static water.

Emergency Response Plan

• The draft guidance is unclear about when Emergency Response Plans and Risk Management Plans should be produced and to what level of detail, which can result in uncertainty about expectations during different stages of development.

The ESN response is available to read here and below.