ENERGY AND SUSTAINABILITY STATEMENT - Dyce Energy Storage Facility 28 April 2021 - Planning ...
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DYCE ENERGY STORAGE FACILITY
ENERGY AND SUSTAINABILITY STATEMENT
Dyce Energy Storage Facility
28 April 2021
1. Introduction
1.1. RPS have been appointed by Cragside Energy to provide an Energy Statement to accompany the
planning application for an energy storage facility at Farburn Place, Dyce.
1.2. Cragside Energy Limited is a wholly owned subsidiary of London based Omni Partners LLP, which
was founded in 2004. Cragside Energy develops energy schemes that support the UK’s journey
towards net zero carbon emissions.
1.3. With a focus on renewable and flexible, low carbon generation assets, Cragside seek to support the
emerging energy transition by enabling the cost-effective integration, and full utilisation of renewable
power generation. Cragside’ s projects ensure investment into a low carbon future whilst preserving a
resilient and cost-effective network.
1.4. Aberdeen City Council’s guidance suggests that Energy Statements should be submitted with
applications for all new buildings.
1.5. Rather than buildings, this proposal involves just modular battery units with associated plant and
equipment, plus two ancillary DNO units for welfare, equipment, and switchgear. This Statement is
therefore submitted in accordance with this guidance, but it is recognised that the proposed structures
will not regularly accommodate people nor be used for any purpose other than being ancillary to the
energy storage operation at the site.
2. Sustainable Development
2.1. It is recognised that sustainability is achieved where consideration has been given to the impacts of
the earth’s limited resources and how these can be used more efficiently. Scotland is regarded as a
thriving hub of renewable energy resources. With the impressive deployment of offshore wind capacity
to date and the potential for an expansive pipeline, energy storage technology has a key and
complementary role to play in the region. It is necessary to utilise the significant quantities of renewable
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power produced to the full extent possible to help Scotland and the rest of the UK achieve its climate
targets.
2.2. Energy storage is a key technology in facilitating this transition, ensuring a cost-effective, resilient, and
sustainable future. Key benefits include:
• An enabling technology in the drive for decarbonisation: Energy storage supports the integration of
more renewables which are intermittent and “non-dispatchable”.
• Help to control consumer electricity prices: Cost-effective balancing of the gird, particularly for short
term, unpredictable imbalances.
• Sympathetic integration: They are inherently compact and quiet installations without the need to
generate power from rotating equipment or disperse emissions via large stacks.
• Mitigates environmental costs in providing flexibility: The facilities themselves do not burn fossil
fuels and they also avoid the environmental impacts of running large plants at sub-optimal
efficiencies.
• The ability to avoid unnecessary local and national infrastructure investment: By making smarter
use of existing capacity and providing grid services, energy storage can help defer, or negate the
need for, grid reinforcement.
3. Sustainable Construction
3.1. During construction, best working practices would be followed. This would ensure that, where possible,
construction activities with the potential to generate carbon emissions would be appropriately managed
and undertaken to minimise carbon dioxide emissions in the following ways:
• Vehicles used in road deliveries of materials, equipment, and construction waste arisings on
and off-site would be loaded to full capacity to minimise the number of vehicle journeys
associated with the transport of these items;
• All machinery and plant would be efficiently procured to adhere with emissions standards and
would be maintained to be fuel efficient;
• When not in use vehicles and plant machinery involved in site operations would be switched
off to further reduce fuel consumption;
• All construction staff will be appropriately trained to operate plant and machinery effectively.
Plant which is operated efficiently will ultimately burn less fuel and produce less carbon
emissions; and
• To minimise the use of electricity, equipment and machinery requiring electricity will only be
switched on when required for use.
3.2. Developing this site places emphasis on the conservation of energy and careful use of natural
resources to meet the existing scenario. The development characteristics from a sustainability
perspective are provided below, with the development seeking to include the following:
• All structures will be designed to ensure the scheme satisfies the principles of sustainable
development, including air tightness, energy efficiency, lighting, sustainable materials use,
access, and internal circulation;
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• No heating of air or water on site;
• The facility is designed to last for a minimum of 25 years and exceed the standard required to
meet Building Regulations. External materials and details requiring the minimum of
maintenance have been incorporated;
• Where applicable, any timber specified required for the construction will not be tropical
hardwood and will be certified to show it has been sourced from commercially grown and
sustainable forests;
• Materials containing CFC’s and HCFC’s will not be used in any structure fabric; and
• The facility will be constructed largely in steel and aluminium, both of which can be recycled
after the demolition process.
4. Policy Compliance
4.1. With regards to sustainability, paragraph 28 of the Scottish Planning Policy document outlines that ‘the
planning system should support economically, environmentally and socially sustainable places by
enabling development that balances the costs and benefits of a proposal over the longer term. The
aim is to achieve the right development in the right place; it is not to allow development at any cost.’
Paragraph 29 sets out that decisions should be guided by the following principles:
• giving due weight to net economic benefit;
• responding to economic issues, challenges, and opportunities, as outlined in local economic
strategies;
• supporting good design and the six qualities of successful places;
• making efficient use of existing capacities of land, buildings and infrastructure including
supporting town centre and regeneration priorities;
• supporting delivery of accessible housing, business, retailing and leisure development;
• supporting delivery of infrastructure, for example transport, education, energy, digital and water;
• supporting climate change mitigation and adaptation including taking account of flood risk;
• improving health and well-being by offering opportunities for social interaction and physical
activity, including sport and recreation;
• having regard to the principles for sustainable land use set out in the Land Use Strategy; •
protecting, enhancing, and promoting access to cultural heritage, including the historic
environment;
• protecting, enhancing, and promoting access to natural heritage, including green infrastructure,
landscape, and the wider environment;
• reducing waste, facilitating its management, and promoting resource recovery; and
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• avoiding over-development, protecting the amenity of new and existing development and
considering the implications of development for water, air, and soil quality.
4.2. Paragraph 32 indicates that there will be a presumption in favour of sustainable development;
however, this does not change the statutory status of the development plan as the starting point for
decision-making. ‘Proposals that accord with up-to-date plans should be considered acceptable in
principle and consideration should focus on the detailed matters arising. For proposals that do not
accord with up-to-date development plans, the primacy of the plan is maintained and this SPP and the
presumption in favour of development that contributes to sustainable development will be material
considerations.’
4.3. The current Aberdeen City Council LDP 2017 and Topic Area 7: Resources, provides clear direction
on measures that the Council consider limit the impact on resources and help deliver a sustainable
development.
4.4. Proposed developments are required to address the efficient use of resources by maximising
efficiency, minimising energy loss, using low and zero carbon technologies, introducing measures for
water efficiency, denser development, and reducing both construction and operational waste.
4.5. Policy R7 states that all new buildings, must meet at least 20% of the building regulations carbon
dioxide emissions reduction target applicable at the time of the application through the installation of
low and zero carbon generating technology. This percentage requirement will be increased as
specified in Supplementary Guidance. This requirement does not apply to:
1. Alterations and extensions to buildings;
2. Change of use or conversion of buildings;
3. Ancillary buildings that are stand-alone having an area less than 50 square meters;
4. Buildings which will not be heated or cooled, other than by heating provided solely for the
purpose of frost protection; or
5. Buildings which have an intended life of less than two years.
4.6. The proposals are predominantly relating to plant and machinery and although not regarded as
‘buildings’, the proposed DNO structures are ancillary to the development and both have a floor area
of less than 50m². The structures will not be heated or cooled. There is also no use of water on the
site. The proposal does not therefore need to comply with the 20% carbon dioxide emissions reduction
target.
4.7. However, the facility will assist in making the energy supply more reliable as it would maintain the
stability of the national grid which is required because of the fluctuations which can result from
renewable electricity sources. The benefits of the proposal in securing energy efficiency and
enhancing sustainability are therefore established.
4.8. Detailed assessment of the development against policy R7 is not therefore considered wholly
appropriate, as the development is supporting infrastructure for the energy sector and does not include
‘buildings’ as denoted in the policy text. However, the development should be considered for its energy
credentials in terms of supporting the energy network and providing stability.
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5. Conclusions
5.1. The proposed development is for an energy storage facility which includes modular units, transformers,
invertors and 2x ancillary buildings on a site at Farburn Place.
5.2. The structures proposed are not considered as buildings and will not regularly accommodate people
nor be used for any purpose other than being ancillary to the energy storage operation at the site and
they are not therefore required to adhere to the 20% carbon dioxide emissions target as set out in
Local Policy R7.
5.3. However, the development will provide for efficient and flexible energy supply to meet peak demands
and reduce system stress within the local power network. Energy storage facilities allow a more
efficient use of the energy produced and help to reduce energy usage in general. This should be
afforded significant weight in the assessment and determination of this application.
5.4. It is therefore concluded that the proposed development can be considered sustainable in accordance
with the aims of national and local energy related policy.
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