The Dangers of Battery Storage in the Allt an Tuir Energy Park Application

 The Allt An Tuir proposed development is located northwest of Rosehall in the Kyle of Sutherland (KoS) just over the river Cassley off the A837.  It is to consist of 9 wind turbines with tip heights up to 200m, a solar panel array between 15 to 18 Hectares at a theoretical 18 Megawatts (MW) power capacity and a Battery Energy Storage System (BESS) of 12 (MW) power capacity.

The Environmental Impact Assessment Report (EIAR) submitted by the developer in support of their application, along with all the other documents is, in my opinion, needlessly overly long, with replication and duplication of various sections throughout.  If you wish to have a paper copy of the documentation, it will cost £2,000.00.  Yes, that is right: £2,000.00.  The regulations that cover the preparation of EIARs, that is “The Electricity Works (Environmental Impact Assessment) (Scotland) Regulation 2017” (hereafter referred to as “The Regulations”) state that:  “a reasonable charge reflecting printing and distribution cost may be made in relation to the supply of a copy of an EIA Report to any person”.  In what world is £2,000.00 a reasonable cost for an ordinary member of the public?  You can obtain a copy on a USB stick for £15.00, but what about those in the community who do not have access to a computer? 

The Environmental Impact Assessment Report (EIAR) and the Energy and Planning Statement are confusing, contradictory and irrational in how they very briefly comment on the power and energy capacities of the BESS.  Power is measured in Megawatts (MW) and the MW rating of a BESS typically refers to the maximum amount of power that that system can deliver at any given moment.  Energy is measured in Megawatt hours (MWh).  The MWh rating of a BESS typically refers to the total amount of energy that the system can store.

For example a BESS rated at 5MW:20MWh can, theoretically, deliver 5MW of power for 4 hours.  The MW (power) and MWh (energy) specification of a BESS are both important but they serve different purposes.  The MW rating determines how much power the system can deliver at any moment, while the MWh rating determines for how long the system can deliver that power.  Of course power can be rated down, so in the above example, a 20MWh BESS could deliver 1MW of power for 20 hours, or 2 MW for 10 hours and so on.

However, the power and energy ratings cannot be rated up, these should be the maximum power and total energy capacity of the BESS system.  Yet the applicant has described the BESS as having a power capacity of 12MW with indicative systems anywhere between 21.6MW or 129.6MW with energy capacity of 95.4MWh and 68MWh.  So which is it?  This just demonstrates to me the total lack of understanding of the units of power and energy used for the documentation in this BESS system.  Such comments can only reflect upon the competence of the person who wrote them.

The Regulations require that “The developer must ensure that the EIAR is prepared by competent experts”.  I do not see that competence here so I very much feel the EIAR had not been prepared in accordance with The Regulations which govern its preparation.  So on that basis alone, the application should be refused.

There are other significant deficiencies in this documentation.  There is no Battery Management Safety Plan at all that would show what would happen in a Thermal Runaway (TR) incident and to recognise that:

- There is no information on what battery chemistry will be used in the battery cells within the BESS, just a mention of a Lithium-ion (Li-ion) battery technology solution.  There are at least 12 Li-ion battery variants and safety issues depend upon what is inside the battery cell ie its chemical composition.

- Lack of any information at all on what parameters are to be monitored to ensue the safety of the BESS.

- Lack of information on any abnormalities on the parameters to be monitored that would indicate TR.

- No information on the location where monitoring will take place and what plans are in place if there is a cyber attack on the communication systems needed to carry out that monitoring.

- Lack of identification of the risks from toxic and combustible off-gases, vapours and fumes from a TR.

- No clarity whatsoever on the full range of conditions that can lead to TR, especially in the climate in the north of Scotland.

- Lack of comments on any safety measures at all, and importantly, those that would prevent heat propagation from TR, e.g. thermal barriers between cells, blast barriers to protect BESS containers from damage from debris resulting from deflagration or explosion.

- No involvement of Fire Safety professionals.

- No recognition of the potential risk of catastrophic impacts from a TR or of the contaminants that could result.

- No recognition of the potential maximum energy release from a total failure of the whole battery system however unlikely that may be.

- No planning to prevent ground peat fires or deal with them if they happen.

- No safety transportation plan specifically relating to Li-ion batteries in transit, see below.

- Nothing about an emergency response plan shared with the Scottish Fire and Rescue Service.

- No information on water sources that can be used to cool and hence contain a TR, or how any water used will be contained on site and not allowed to get into water courses etc.

- Nothing on the protections to be put in place to prevent contamination in the KoS rivers waterways and the SSSI marshes down the Kyle. Such contamination would be highly toxic to fish and all aquatic life forms.

Without giving clarity on the power and energy ratings, providing information on the detail of the battery chemistry and the safety issues around transportation, installation, commissioning, operation, replacing and decommissioning battery systems, this is like applying to the Planning Authority to build a house, but without telling them how large it will be: 1, 2 or more storeys, or what it will be made out of.

There were 5 thermal runaways in the world last year.  There have already been 3 in the first two months of this year: one at Moss Landing in California and two in the UK, at Thurrock in Essex and Rothienorman in Aberdeenshire.  It only took the Essex County Fire and Rescue Service (ECFRS) 10 mins to get to the Thurrock TR, and yet it took over a day to contain that TR and the resulting fire. The ECFRS Commander on the ground stated a reliable water supply helped them contain the TR and Fire. The is no water supply at the Allt an Tuir site let alone a reliable one. How long will it take for the Scottish Fire and Rescue Service to get to a TR at the Allt an Tuir site?

No product is made with 100% quality control.  As more and more battery cells are manufactured and more and more BESS are constructed the incidence of TR can only increase. The fire suppression systems again very briefly mentioned in the EIAR will not have the thermal capacity to contain a TR. They may very well smother flame but that does not stop the electrochemical reaction within a battery cell from producing heat. TR will continue in the presence of such fire systems until the energy within the battery cell is depleted. The Moss Landing TR and fire on 16th and 17th January reignited on 19th February.

Why is the general public being denied the opportunity to consider and comment on the safety systems on BESS that must be put in place, by the total absence of these matters in the EIAR?  At the so-called consultation events that I have attended, I have been informed that the risk of TR in a BESS is infinitesimal.  Well, as can be seen from the incidents in the UK on 19th February 2025 and 21st February 2025, and in California on 16th and 17th January and 19th February that is manifestly not the case.

The EIAR states in Chapter 10 in paragraph 10.2.2 “There is no legislation specific to transport assessments that is required to be considered as part of the assessment.” This entirely misses the point that UN Transport Regulations classifies Lithium-based batteries as “Class 9 – miscellaneous dangerous substances and articles”. These regulations apply to the transport of grid-scale BESS and as such, they should be treated as dangerous goods. The Carriage of Dangerous Goods and use of Transportable Pressure Equipment Regulations 2009 (CDG Regs) therefor apply. It is thus entirely incorrect to state “There is no legislation specific to transport assessments that is required to be considered as part of this assessment”. This again demonstrates to me a lack of competence in the preparation of the EIAR.

So who is going to stand up and protect the local communities where such developments are proposed? The local community on the KoS had a meeting with their constituency MSP on 13th February 2025 at Bonar Bridge.  At that meeting, Ms Todd their MSP stated, as I remember it, that as she is a Minister within the Scottish Government it was not possible for her to comment on individual planning applications as that would be considered to be breaking the Ministerial code.

Subsequently I have discovered that Mairi McAllan MSP for Clydesdale constituency who is the Scottish Government’s Cabinet Secretary for Net Zero and Energy, has registered an objection to a BESS in her constituency.  I would absolutely commend and support Ms McAllan’s actions here.  You can view her objection on the ECU website under reference ECU00004823.  On The ECU website click search, then advanced search, enter the above reference in the box for the ECU Ref, click ‘Go’ and the system brings up the development ‘Rogerhill Solar and BESS’.  Click on the blue reference at the left hand side, then ‘documents’, then ‘public representations’.  Go to page 3 and list number 00326 – 00340 and Ms McAllan’s is third on this list.

If the current Scottish Government Minister for Net Zero and Energy, (who is currently on maternity leave) can make an objection as a constituency MSP, why can our constituency MSP not do the same?  I leave it to you to decide the rights and wrongs of our MSP’s position.

I would urge all readers to make an objection on the Allt An Tuir application to the Energy Consents Unit. The time limit for representation (objections) is 28th March 2025. You need to specify the grounds for your representations, see above, and that this location is totally unsuitable for a BESS.  Please quote reference ECU 00005008.  Representations can be made by letter to the Energy Consents Unit, 5 Atlantic Quay, 150 Broomielaw, Glasgow, G2 8CU, or by email to representations@gov.scot .  To have your objection taken into account you must provide your name, full postal address and date your correspondence. 

Please copy your objection to The Highland Council, to Mr Dafydd Jones, Area Planning Manager (North), ePlanning Centre, The Highland Council, Glenurquhart Road, Inverness, IV3 5NX, or e-mail at eplanning@highland.gov.uk.

William S Lockyer