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UK Electricity Storage Developments: Consultation on the Planning process

  • United Kingdom
  • Energy and infrastructure

29-01-2019

The UK Government’s 2017 Smart Systems and Flexibility Plan committed to removing policy and regulatory barriers to the deployment of smart technologies, including electricity storage. The planning framework was identified as one of these barriers. BEIS is currently consulting on the NSIP threshold for storage projects and the disaggregation of storage capacity from generating capacity in composite generation projects. This consultation will be of interest to developers with existing generation projects below the current 50MW NSIP threshold proposing to co-locate electricity storage, or operators of existing composite projects contemplating an extension.

Definition of ‘Storage’

A wide range of electricity storage technologies is intended to be covered by the proposed reforms. For planning purposes, electricity storage is treated as a form of electricity generation. This consultation defines electricity storage as referring to a generating station, or any part of a generating station that generates electricity from stored energy.

50MW Capacity Threshold

Based on discussions with those in the storage industry, the Government considers that the 50MW threshold does not have a significant influence on the sizing and investments decisions of storage developers. Of greater influence are upfront capital costs, network connection costs and available revenue streams. The Government considers that the impact of changing the policy approach and 50MW capacity threshold for standalone storage projects would be disproportionate to any benefits and no change is therefore proposed.

Composite Projects

Uncertainty over the treatment of composite projects is considered to be the more pressing issue.

Current legislation contains no express definition of how to assess the capacity of a generating station. The application of NSIP thresholds to composite projects involving storage is not clear-cut. For new composite projects involving storage, or storage extensions to existing generating stations, the generating station as a whole may be an NSIP where the capacity of each element together exceed 50MW.

The planning system does not currently distinguish between projects involving one type of generating technology and proposals with two or more types of generation. Determining whether a particular co-location scenario should be treated as a single composite generating station or two or more distinct generating stations is a matter of planning judgement. Relevant factors in making this judgement include the proximity between assets, presence of shared infrastructure, whether there is a single operator and whether the assets are technically interoperable.

This consultation very broadly defines a ‘composite project’ as one where the nature of the development is such that a co-located storage asset and another type of generation asset should be treated as forming part of a single generating station. Developers are advised to discuss projects with the Planning Inspectorate if a proposed composite project might be a NSIP.

In terms of reform of the planning system and clarifying the permitting route for composite projects, the Government proposes to amend the Planning Act 2008. The definition of an NSIP will expressly recognise composite generating stations in England which will, when constructed or extended, include electricity storage deployed together with other forms of non-wind generation as part of a single generating station.

A new bespoke threshold will be included for composite projects including storage and another form of generation. A composite project will be an NSIP where either its capacity, excluding any electricity storage, is more than 50MW, or if the capacity of any electricity storage exceeds 50MW. A project where both the storage and non-storage elements of the generating station are less than 50MW individually will fall outside the NSIP regime.

The consultation also asks the open question of whether there are other areas of the planning system that might be considered to treat storage inappropriately relative to other forms of generation.

The consultation will close on 25 March 2019. To discuss the potential impact of the proposals for current or future proposals or more general planning issues relevant to electricity storage, please contact the team below.

For more information contact

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