Battery Storage Guidance Note 1 PDF

Battery storage guidance note 1:
Battery storage planning

BATTERY STORAGE GUIDANCE NOTE 1: BATTERY STORAGE PLANNING
First edition
August 2019
Published by
Energy Institute, London
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CONTENTS
Page
Acknowledgements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Foreword . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
1.1 Audience�� 7
2 Battery energy storage types . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

2.1 What is a battery? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
2.2 What is a battery storage system? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
2.3 Types of batteries in use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
3 Navigating the planning regime – a UK example . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

3.1 The planning background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
4 What should be considered during risk assessment and planning applications? . . 15

4.1 Site selection �� 15
4.2 Issues for design and planning applications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
4.3 Specific energy storage considerations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
4.4 Construction considerations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
4.5 Operational considerations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
4.6 Fire risks�� 19
4.7 Intended applications, asset life and environmental impact . . . . . . . . . . . . . . . . . . 20
4.8 Hybrid installations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
5 Compliance with legislation and standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
6 Risk assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
7 Decommissioning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
Annexes
Annex A Further reading and references . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

A.1 Further reading . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
A.2 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
Annex B Abbreviations and acronyms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
3
LIST OF FIGURES AND TABLES

Page
Figures
Figure 1 Typical components within a grid scale battery installation . . . . . . . . . . . . . . . . . . . 9

Figure 2 A standalone 250 kW 500 kWh ZnBr battery system . . . . . . . . . . . . . . . . . . . . . . 12
Figure 3 The inside of a 6 MW, 10 MWh lithium-ion battery system operated by UK Power
Networks at Leighton Buzzard . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
Figure 4 A multi container lithium-ion battery storage project . . . . . . . . . . . . . . . . . . . . . . 12
Figure 5 UK planning regime for generation projects (at a glance) . . . . . . . . . . . . . . . . . . . 13
Tables
Table 1 Battery chemistry types . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Table 2 Standards concerning specific battery type . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
Table 3 Standards concerning energy storage systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
Table 4 Standards concerning electrical installations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
Table 5 Standards concerning electrical networks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
4
ACKNOWLEDGEMENTS
Battery storage guidance note 1: Battery storage planning was developed by Anthony Price
(Swanbarton) on behalf of the EI Energy Storage Working Group. During this work the working
group consisted of the following individuals:
Jacob Allinson RWE

Jonathan Buston HSL
Victor Craig SSE
Joseph Dunn Scottish Power
Frank Gordon (Vice-Chair) Renewable Energy Association
Stuart King (Chair) Energy Institute
Lee Reed Centrica
The EI thanks the following contributors who reviewed the project deliverables:
Christophe Banos EDF Renewables

Hannah Clapham BEIS
Scott Drinkell Greenergy
Ed Jamieson RWE
Adrien Lebrun Pivot Power
Affiliations are correct at the time of contribution.
5
FOREWORD
Battery storage is expected to play an important role in the energy transition, allowing the
storage of electrical energy from renewables for later use, and helping to balance grid load.
At the time of publication, 4.8GW of battery storage has been given planning consent in the
UK, but a further 12GW may be needed by 2021. Given the importance that battery storage
has on the future energy mix, and the (expected) increasing need for operating companies
to plan future battery storage installations, and for local authorities to review and approve
plans, industry sees the need for 'just in time' guidance addressing this.
This publication provides guidance covering various aspects of planning a battery storage
facility. It provides an overview of battery types, planning regulations in the UK, and
information on safety issues that should be considered during planning and risk assessments.
It is intended to be concise and reflect current practice and knowledge in this fast-changing
sector.
The guidance is intended for:

- operating companies, to help plan and assess risk, and
- local authorities, to help them ask the right questions when making planning
decisions.
The information contained in this document is provided for general information purposes
only. Whilst the EI and the contributors have applied reasonable care in developing this
publication, no representations or warranties, expressed or implied, are made by the EI or
any of the contributors concerning the applicability, suitability, accuracy or completeness of
the information contained herein, and the EI and the contributors accept no responsibility
whatsoever for the use of this information. Neither the EI nor any of the contributors shall
be liable in any way for any liability, loss, cost or damage incurred as a result of the receipt or
use of the information contained herein.
The EI welcomes feedback on its publications. Feedback or suggested revisions should be

submitted to:
Technical Department
Energy Institute
61 New Cavendish Street
London, W1G 7AR
6
1 INTRODUCTION
Our electricity networks currently operate on a 'just in time basis' as electricity generation
must continually match electricity demand (including losses through inefficiencies). Power
system planners and system operators have several options to balance supply and demand.
The ability to store electricity and release it later provides a useful technical and commercial
tool to assist balancing.
Electricity can be stored in many ways including:

−− electrochemical solutions such as batteries;
−− pumped hydroelectric storage, and
−− mechanical flywheels.
This guidance note considers planning for battery energy storage only. Some other storage
systems share similar characteristics and the methodology of this note may be extended to
other technologies, such as supercapacitors and electrolyser/fuel cell combinations.
The focus of this guidance note is network connected mid-scale and larger scale installations
with a suggested minimum threshold of 500 kW or 250 kWh. The note covers the current
interest in the many types of lithium-ion cells but also includes important aspects of other
commercial battery types including lead acid, flow batteries and high temperature batteries.
There are many large-scale battery systems already installed and operating; this guide is
written with reference to these existing examples.
This note excludes planning for small scale domestic battery energy storage applications
and battery storage in mobile applications, such as electric vehicles and other transport
applications. Developers, operators and installers of small- and mid-size electrical energy
storage systems will find useful information in other publications, including the Institution
of Engineering and Technology (IET) Code of practice for electrical energy storage systems.
1.1 AUDIENCE
This publication provides guidance to site owners and developers planning to build battery
energy storage, and to local authorities and others who have responsibility for granting
planning permission or other consent. It is intended to help all audiences understand the
risks and mitigations that should be in place.
It should prompt informed and relevant risk assessments for site owners and developers
and contains information that should be examined by planning authorities before granting
permission.
While care has been taken to provide accurate and up-to-date information, this document is
for guidance only and users are recommended to take professional advice in the development
or assessment of any project.
7
2 BATTERY ENERGY STORAGE TYPES
Switch Room 1 × 5 MW
To DNO
module
Sub MV trans
CT/
PT
LV trans
Comms
hub P&C
M SM
HVAC & fire suppression
I&C room
High voltage cable

P&C Protection relays and battery
Communication link control software
M Meter CT/ Instrument a.c./d.c. converter (physically

PT transformers separate from batteries)
Settlement
SM Meter Battery string (e.g. 16 × units each of 22 × cells)
Figure 1: Typical components within a grid scale battery installation
2.1 WHAT IS A BATTERY?
In common use, a battery refers to an electrochemical device which supplies electrical

energy. A primary battery converts electrochemical energy to electrical energy. The precise
terminology, used for example in international standards, is that a battery is one or more
electrochemical cells.
An electrochemical cell converts electrochemical energy to d.c. Two or more cells arranged in
series or parallel form a battery. A cell or battery may require a cell or battery management
system (BMS) to ensure safety and reliability. A secondary (or rechargeable) battery is a
reversible device that converts electrochemical energy to electrical energy and vice versa. In
this document, the term battery, unless otherwise stated, refers to a secondary battery.
2.2 WHAT IS A BATTERY STORAGE SYSTEM?
A battery energy storage system includes a BMS, and often a power conversion system (PCS)
for conversion of d.c. to a.c. and vice versa. A battery energy storage system, especially
for large-scale installations, may include many other components, such as transformers,
switchgear, PCSs, battery management, heating or cooling as well as fire management,
suppression or firefighting, and other safety or security, equipment.
8
2.3 TYPES OF BATTERIES IN USE
The lead acid battery has been for many years the predominant type of electrochemistry used
for large-scale electricity storage, both in the UK and worldwide. Lead acid is relatively low
cost, is nearly completely recyclable and has a well-established history.
The lithium-ion family of batteries has been commercially available for more than 20 years.
The common secondary battery types that are used for commercial mid-scale and large-scale
storage systems, presently and expected over the next five years, are shown in Table 1.
Other battery types include nickel cadmium, which is not currently used for environmental
reasons, and nickel metal chloride which has ceased large-scale commercial production. Many
new battery technologies (including aluminium ion, lithium sulfur) are under development,
but are not expected to be in widespread use during the lifetime of this document.
The specific chemistry of the battery is important for the planning process because the
chemicals released in the event of an accident will determine the level and nature of the risk
and how it must be mitigated. For example, it is not sufficient to simply state 'lithium-ion'
in the planning application, as each type has widely different characteristics, particularly
with regard to fire resistance, fire and explosion propagation, performance, efficiency and
resilience to ambient conditions.
All battery types require some form of BMS to ensure safety and reliability during operation. In
general, batteries should not be overcharged or over-discharged. For some systems the BMS
needs to monitor individual modules or cells to prevent thermal runaway and consequential
catastrophic failure. The BMS should be of high integrity and is often provided with third-
party certification.
9
Table 1: Battery chemistry types
Type Examples Description Characteristics Applications

Lithium-ion Several battery types exist A cell where the lithium ion moves Different battery types can be Ideal for short
(Li-ion) including: from a carbon-based electrode to designed for optimum power density, duration (~ 1
−− Lithium nickel a metal oxide electrode through an physical footprint, degradation, fire hour), high power
manganese cobalt electrolyte of a lithium salt in a solvent. resistance etc. reasonably robust to applications,
(NMC or MNC) Cells can be cylindrical, prismatic or high and regular charge cycling. but recent cost
pouch type, enabling different physical The choice of format and reductions show
−− Lithium cobalt oxide
arrangements. arrangement impacts energy and that longer
(LiCoO2)
power density and options for durations can be
−− Lithium iron phosphate Each chemistry type has different cost-competitive
(LiFePO4) performance characteristics and so cooling.
against other
−− Lithium ion manganese there are different consequences in Catastrophic failure can lead to fire technologies.
oxide battery (LiMn2O4, the event of failure or explosion and release of toxic
Li2MnO3, or LMO) Many installations use NMC. LFP has materials.
a lower energy density but is regarded
10
as safer than the other chemistry
types.
Lead Acid PbSO4 Lead and lead sulfate electrodes with Low cost, long proven history, Largely Suitable for a
electrolyte sulphuric acid, either as recyclable. Low power density and variety of grid
liquid or as a gel. Several variations toxic materials. Explosion risk if applications.
including flooded, valve regulated, gel overcharged due to build-up of
type and bipolar. hydrogen.
Flow Many different types Electrolytes are stored outside the Low performance degradation of Generally suitable
batteries using different electrolytes electrochemical cell, and flow through performance from charge/discharge for longer
including vanadium flow the cell during the charging and cycling. Low fire risk. durations of up to
battery (V/V) and zinc discharging process. 8 hrs.
bromide (Zn Br) flow
battery.
High Sodium sulfur (NaS) Sodium and sulfur electrodes High energy and power density. Suitable for a
temperature separated by a ceramic electrolyte Cell temperature of approx. 300 °C variety of grid
mitigated by insulation. Performance applications.
not affected by ambient temperature.
Figure 2: A standalone 250 kW 500 kWh ZnBr battery system
Figure 3: The inside of a 6 MW, 10 MWh lithium-ion battery system operated by UK

Power Networks at Leighton Buzzard
Figure 4: A multi container lithium-ion battery storage project
11
3 NAVIGATING THE PLANNING REGIME – A UK EXAMPLE
Planning
Generation England Scotland Wales Northern Ireland jurisdiction
Project size
Town and Country Town and Town and Country Planning Local planning
< 5MW Planning Act 1990 Country Planning Planning Act 1990 as (Northern ireland) authority
(Scotland) Act amended by planning Act 2011: Local (Except
1997 (Wales) Act 2015 > 10 MW in
Planning Wales, Welsh
< 10 MW Some projects, (Northern Ireland) Assembly
determined by Welsh Act 2011: Major > 30 MW
Ministers instead of local Northern
planning Planning Ireland,
< 30 MW (Northern Ireland) Department of
Act 2011: Major Infrastructure)
UK Planning Act 5 3b of Electricity Act Currently UK Central

2008 1989 and s57 of Town Government Government:
< 50 MW
and Country (Scotland) Post 2019 Welsh England –
planning Act 1997 Assembly UK Government:
and amendments incl. Scotland –
Planning etc. (Scotland) Scottish
< 350 MW < 350 MW UK Ministers
Act 2006
Planning Act Wales –
2008 Welsh Assembly
Figure 5: UK planning regime for generation projects (at a glance)
All development is subject to compliance with planning legislation (Department of Local

Government and Communities, Plain English guide to the planning system), although there
are many exemptions that can be applied. There are also different regulations that cover
specific circumstances, such as National Parks or developments of a hazardous nature. It is
important to identify which planning regime would apply to a specific energy storage project.
Although there may be some similarities between projects, care should be taken to comply
not only with the planning legislation, but also to ensure that a risk analysis covers the whole
system development.
3.1 THE PLANNING BACKGROUND
Planning processes are highly sensitive to the legal jurisdictions covering the project location.
These may be national, regional or local laws, under the federal, county/state or municipal
authority. Most likely there will be a mixture of all of these, covering different aspects. This
guide is written using example storage projects in the UK, but clearly developers must adhere
to relevant local process and therefore enlisting local expertise is highly recommended. An
early task is to identify the authority having jurisdiction for the project in the area where the
project is to be located and to understand their requirements. Even within the UK, there
are significant variations in the planning and consenting procedures and care is required to
ensure compliance with legislation and regulation.
Many development projects in England and Wales are authorised under the Town and
Country Planning Act 1990 (TCPA). However certain projects are consented using alternative
authorisation. Developments in the electricity industry are often covered under the Electricity
Act 1989, which gives development rights to companies which hold a generation, transmission
or distribution licence. This exemption is often used to authorise minor changes to power
12
stations, substations and the like, subject to limitations, restricting the height of any new
structures to less than 9 m and excluding substantial changes to the overall site.
New installations are required to either seek planning approval through the TCPA process, or,
for larger generation installations, to apply using the process under the Planning Act 2008
(PA). Electricity storage is considered to be generation. The planning treatment for generation
projects varies in accordance with the generating capacity of the project. In England,
generation projects below 50 MW are determined by the local planning authority (LPA) and
projects above 50 MW are determined by the Planning Inspectorate advising the Secretary
of State under the Planning Act 2008. There are variations in the thresholds for projects in
Wales, Scotland and Northern Ireland. Some larger energy storage sites might require new
overhead transmission lines, for which the relevant planning legislation is determined by
voltage1. As the threshold for consent by the LPA is 50 MW for generation projects, in recent
years this has determined the upper capacity limit for storage projects.
In many cases, the planning legislation is yet to catch up with the development of new
technology. For example, the TCPA use-class definition (The Town and Country Planning (Use
Classes) Order 1987 No. 764) does not yet define a specific class that covers energy storage.
Some applications have been made either under B1 (light industrial), B2 (general industrial) or
B8 (industrial storage and distribution centres). In the case of B8, applicants have reasonably
argued that electricity storage comes under the umbrella of general industrial storage. B8 is
also most appropriate when the battery is an uninterruptable power supply (UPS) for a data
centre. Many planners have treated standalone energy storage as sui generis (in a class of
its own) which slows the planning process down; more so because referees will usually be
unfamiliar with energy storage technology.
In the UK, The Department for Business, Energy and Industrial Strategy (BEIS) has stated that
storage projects should be considered as a subset of generation. This means that development
consent is required for storage projects above 50 MW2, indicating that many storage projects
have been treated for planning applications as if they are a generation project. At the time
of writing, changes to the licensing regime for electrical energy storage are being considered
by The Office of Gas and Electricity Markets (Ofgem) (Ofgem, Upgrading our energy system:
Smart systems and flexibility plan) and the implications are not yet known. It is not clear
whether co-locating storage with an existing generation plant (such as solar or wind)
increases the output capacity of the project. The main area of uncertainty is the procedure
for deciding whether the project is below or above the current 50 MW threshold which refers
larger projects to the planning Authority. Both developers and planners will be aware that
this threshold does not necessarily represent a boundary between what is and is not visually
or environmentally acceptable and that the situation can change in the future.
Different procedures apply in Scotland, Wales and Northern Ireland:
In Scotland, the devolved administration authorises generation projects over 50 MW whilst

those below 50 MW are sent to the relevant LPA. However, the planning legislation is specific
to Scotland: the Town and Country Planning (Scotland) Act 1997 and the Planning etc.
(Scotland) Act 2006.
1 Lines of 132 kV and above are deemed a Nationally Significant Infrastructure Project and covered by the Planning
Act 2008, others are covered by the Electricity Act 1989.
2 At the time of publication, the UK government is conducting consultation as to whether to retain the 50MW
NSIP capacity threshold that applies to standalone storage projects, but to place projects under local planning
control where the capacity threshold is reached through composite projects including storage and another form
of generation. In the UK, a statutory consultation is now underway covering changes to electricity licensing for
electricity storage.
13
In Wales, onshore projects up to 10 MW are covered by the UK TCPA 1990 and are administered
by the relevant LPA. Currently, any project between 10 and 50 MW is also covered by the UK
TCPA but is judged a 'development of national significance' (DNS) and so is assessed by the
Welsh Assembly rather than the LPA. Projects over 50 MW are deemed 'nationally significant
infrastructure projects' (NSIP) and so administered by the UK government. However, following
the devolutionary Wales Act 2017, the threshold for NSIP will be raised from 50 MW to 350
MW from 2019 onwards. Thus, after this date, any project above 10 MW but below 350 MW
is deemed a DNS and will be administered by the Welsh Assembly.
Northern Ireland uses a three-tier approach introduced by the Planning (Northern Ireland) Act
2011 that determines whether jurisdiction lies with either:
−− the LPA – in Northern Ireland the LPA is the local council, or
−− the central Northern Irish Assembly, specifically its Department of Infrastructure.
According to categories specified by the Planning (Development Management) Regulations

2015, any project below 5 MW is classed as a 'local' development and presided over by
the LPA. Projects between 5 MW and 30 MW are classed as 'major': they remain the LPA's
decision, but must be subject to a pre-application consultation with the local community,
commensurate with project size and complexity. Any project exceeding 30 MW is deemed of
regional significance. It still must undergo a suitable public consultation, but is adjudicated
by the Department of Infrastructure.
The Ofgem Tier 2 Low Carbon Networks Fund (LCNF) project Smarter Network Storage
2013–2016 lead by UKPN involved design and operation of 6 MW/10 MWh lithium-ion
battery in Leighton Buzzard, UK. The publicly available project reports, particularly, SNS1.2
Design and planning considerations for large-scale distribution-connected energy storage
include much about the planning process for large-scale storage projects.
ifferent legislation applies in other countries, and prevailing attitudes to energy storage
D
may affect the planning process. For example, in Australia the recent draft standard DR
AS/NZS 5139:2017 dramatically restricts deployment of lithium-ion in buildings because of
fire safety concerns. There can be restrictive planning procedures at a more local level. For
example, New York City, in the USA, restricts the deployment of grid scale battery storage
due to concerns of the New York Fire Department over of the use of lithium-ion batteries
in areas of high population density.
14
4 WHAT SHOULD BE CONSIDERED DURING RISK

ASSESSMENT AND PLANNING APPLICATIONS?
This section includes various aspects that should be considered by site owners when risk
assessing and planning a battery storage facility, and by LPAs when reviewing planning
applications.
4.1 SITE SELECTION
−− Location of the battery: a basic appreciation of the site, including the battery
and the PCS, switchgear, transformers, metering and the like. The site appreciation
should consider any restrictions applying to the site, both within the allocated area,
or outside the fence line. Abnormal events, for example flooding risk, can create
significant hazards and it may be necessary to raise batteries and other equipment
above ground level for this reason3. The project also includes work up to the point
of connection to the electrical network, and any additional works required outside
the site boundary. If the project is to be co-located with other renewable assets, such
as a solar or wind installation, the area for the site appreciation should be increased.
−− The choice of the type of structure to house the batteries and ancillary equipment
has multiple implications for the planning and consenting process. To date, most
large battery storage projects have either been housed in purpose-designed buildings
or ISO-style shipping containers (ISO 668:2013). ISO container projects are quick to
build, often low cost and are inherently modular. Access to individual containers
(unless containers are extensively stacked) offers the option to increase the energy or
power of the project later if this option is included in the original design. Adequately
spaced containers may mitigate overall fire risk. However, containers have a larger
net physical footprint and are perceived to have more adverse visual impact than an
existing or new building. Building projects can be designed to fit the surroundings
and thus planning permission may be easier to obtain. Some projects have been
developed in low-cost, barn-like structures on agricultural sites. Changing the use of
an existing farm building does not normally require planning permission, although
developers should always check with the LPA. Regulations and legal requirements
must be checked before considering installation of new equipment in an existing
building.
−− Capacity of the required electrical network connection, voltage at point of
connection and timescale for connection: grid connection timescales vary; they
heavily depend on status and forward evolution of the local network and can be in
excess of 18 months. Larger projects may affect the transmission network, directly or
indirectly, and so require the distribution company to liaise with the system operator.
The applicant should provide the status of the connection application to the relevant
network operator(s) and demonstrate how connection timescales will be managed.
3 A battery project at Leighton Buzzard was installed in a building raised on stilts to allow flood waters to pass safely
underneath.
15
4.2 ISSUES FOR DESIGN AND PLANNING APPLICATIONS
−− Site access for construction, maintenance and decommissioning: the size and
weight of the installation can be significant, for example lithium-ion batteries can
have mass in excess of 6 tonnes per MWh.
−− Site security: for example, prevention of theft or vandalism. The project type (free
standing, installed in shipping containers or similar enclosures, or installed in an
existing or new building) will impact on installation, maintenance, relocation, visual
appearance, safety and noise.
−− On-site vehicular parking for the construction phase and ongoing maintenance
access and facility staff.
−− Ownership of the land and any third-party rights to the land, including public
access.
−− Noise (see 4.5).
−− Visual impact and its management: multi-MW energy installation will be physically
large and its visual impact will need to be considered in the planning process:
−− A 10 MW (5 MWh) battery storage project's approximate footprint is
750 m2. A 100 MW (100 MWh) lithium-ion project's approximate footprint is
10 000 m2. A 50 MW (300 MWh) sodium sulfur system has a footprint of
14 000 m2.
−− Container-based projects are usually housed within standard (8 ft 6 in high),
high cube (9 ft 6 in high) or modified ISO containers and may be stacked but,
due to spacing and access requirements, may cover twice as much area as a
building project.
−− The point of connection to the electricity grid will also have some impact
on the planning for the project. A cable joint connection underground
would have little visual impact unlike a tie-in to an overhead line or a tower.
Connection to 132 kV and above require sub-stations (sometimes loop-in –
loop-out) requiring significant equipment.
−− Some battery projects will be located on brownfield or greyfield sites where
a new development will have a positive visual impact. Project developers can
mitigate their visual impact for example by planting shrubs and trees around
the perimeter.
4.3 SPECIFIC ENERGY STORAGE CONSIDERATIONS
−− Battery energy storage may be used for single or multiple purposes. Planning
applications require the applicant to describe how the intended development will be
used. The use(s) of the energy storage may also determine the rateable value of the
project with implications on the project's rate of return.
−− Power and energy rating which impact on layout, requirements for network
connection, and its intended and alternative applications. The connection application
to the distribution network operator needs to be carefully aligned with the future
operation profile of the battery. Crucial elements to consider are:
−− connection voltage (important for the power rating of the battery);
−− both import and export ratings (MW). In general, symmetric capacities are
recommended;
16
−− ramp rate (MW/sec) to indicate the speed of response the network will have
to expect, and
−− power swing (MW).
Any constraints indicated by the distribution network operator in their grid connection offer
should be carefully assessed by the developer to ensure they would not affect the battery
storage business case.
−− Choice of battery technology and specific chemistry: the Control of Substances
Hazardous to Health Regulations 2002 (COSHH) cover the use of substances hazardous
to health. The choice of energy storage type, in conjunction with its location, may
determine the requirement for environmental impact assessment (EIA)4, integrated
pollution prevention and control (IPPC)5 or variations, accounting not only for the
energy storage medium, but also for the rest of the plant and its interactions with
other adjoining or adjacent installations. For example, the presence of fuel tanks
or chemical stores could, in combination, take an installation over a threshold limit
set by the Control of Major Accident Hazards (COMAH) Regulations, Dangerous
Substances (Notification and Marking of Sites) Regulations 1990 (NAMOS)6, and
Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)
Regulations. Developers should calculate the total mass of active materials on the
sites and refer to the limits given in the legislation. Because battery storage involves
chemical/electrochemical reactions, the materials in the charged and uncharged states
should be considered. Some battery systems produce hydrogen at certain points in
the charge cycle and this possibility should be included in the analysis. Developers
should also check that in the event of a fire, explosion or other event, the total
mass of released by-product materials is below the threshold limits. Compliance with
the Batteries Directives (see references) and associated legislation and regulations
which cover the import, use and recycling of the batteries is essential. There is also
legislation covering the transport of batteries7 and removal of waste batteries. This
may influence the choice of route and selection of carrier for the delivery of batteries.
−− Choice of supporting equipment, often referred to as the balance of plant.
Consideration should be given to any size and noise implications and the chemical
hazards associated with the balance of plant.
−− The application should also consider associated civil engineering or building
works associated with the electrical connection, such as cable trenches, cable ways,
bunding and blast walls for transformers.
4 In the UK, covered by The Town and Country Planning (Environmental Impact Assessment) Regulations 2017 No.
572, UK Parliament, available at http://www.legislation.gov.uk/uksi/2017/571/introduction/made
5 In England and Wales: European Community (EC) Directive 2008/1/EC1 on Integrated Pollution Prevention and
Control (the IPPC Directive), since superseded by Directive 2010/75/EU, https://eur-lex.europa.eu/legal-content/EN/
TXT/?uri=CELEX:32010L0075
In Scotland: The Pollution Prevention and Control (Scotland) Regulations 2012, No. 360 Scottish Parliament,
available at http://www.legislation.gov.uk/ssi/2012/360/contents/made,
In Northern Ireland: The Pollution Prevention and Control (Industrial Emissions) Regulations (Northern Ireland)
2013, No. 160, available at http://www.legislation.gov.uk/nisr/2013/160/contents/made
6 This includes the notification of sites holding over 25 tonnes of lithium-ion chemistry batteries
7 For example UN 3090 is for lithium-ion batteries. Trained drivers are required for the transport of hazardous goods
such as batteries.
17
4.4 CONSTRUCTION CONSIDERATIONS
−− Compliance with the Construction, Design and Maintenance Regulations

(CDM): by law, CDM regulations require all projects where construction work will
last longer than 30 days, where there are more than 20 workers at a time or more
than 500-person days, to notify the Health and Safety Executive (HSE). Irrespective of
this, it is good practice for all involved in a battery project to comply with the spirit
of the CDM and ensure that an adequate management plan is in place to cover the
design construction, operation, maintenance and decommissioning of the project.
Because the operation and maintenance of a battery project will be dependent on its
use and duty cycle, it is important, and a legal requirement, that the application of
the battery system, and any changes in its applications, are defined at the beginning
of the process and recorded in the project file.
−− Site access during construction (equipment delivery, construction equipment
access): impact on a given locality is very site-specific and is affected by rural or
urban locations and by the existence (or otherwise) of communication routes (roads,
rail, seaports). The amount of civil works required will depend upon ground quality
and the type of building works required will depend upon options to reuse existing
facilities if these are available.
−− Use of building materials: comparisons should be made between indoor versus
outdoor insulations and the quality of the building fabric on a brownfield site
(resistance to wind, rain, water or noise).
−− Noise and other disruption: the project will necessitate extra vehicles and so
frequency and time-of-day of deliveries should be considered in relation to extra
traffic, disruption and noise. Consideration of construction and installation works
practices in relation to time-of-day (working hours) and number of working days
(including working at weekends) should be made, as well as considering provision of
storage of materials during construction.
−− Construction timescales: time required for construction and installation works
will clearly vary with the scale, rating and complexity of a project. But often many
elements are pre-constructed in containers with the main impact being on the roads,
cranage, storage and site operatives. Typically, a 5 MW battery energy storage plant
may take four to six months to build and a larger 50 MW system may take eight to
12 months.
4.5 OPERATIONAL CONSIDERATIONS
−− Noise from electrical equipment and cooling: although battery storage systems do
not contain significant moving parts, battery PCSs emit a whine due to fast electrical
switching, flow batteries require pumps, and various items of plant will require fans
for active cooling. For example, a forced-air-cooled 1 MW PCS could have a sound
level up to 75 dBA (average value at 1 m from object). This 'base value' could easily
change (up or down) due to an alternative cooling medium. Similarly, other ancillary
systems (particularly transformers) can vary in noise output due to the cooling design
adopted (natural or forced, air, oil or water) and have the characteristic 100 Hz hum.
A baseline noise survey must be carried out before planning so that any additional
noise when operational can be objectively measured.
18
−− Harmonic current emissions associated with power inverter systems may have
operational impacts on the plant itself as well as on other plant and equipment in the
area. This will be considered in the application for network connection and is covered
in the Energy Networks Association (ENA) Engineering Recommendation G5/4-1.
−− Heating and cooling: the source of air or water for heating and cooling is important
as it impacts on the condition of the system. Sites close to the coast may have high
salinity air which would be detrimental to the system. The discharge of cooling air
should take into account neighbouring areas.
−− Maintenance requirements: the developer should consider how to provide
maintenance over the operational lifetime. This includes the possible need for storage
of materials or equipment onsite, the need for site access for specialist equipment,
and the possibility of replacing large modules (e.g. containers).
−− Fire safety and emergency procedures: the developer, owner and operator should
prepare a fires safety and emergency plan which will contain, but not be limited to,
the ingress and egress routes to buildings, access routes for emergency vehicles, fire
management and compliance with fire safety legislation8.
4.6 FIRE RISKS
The UK's Regulatory Reform (Fire Safety) Order 2005 places the burden of fire safety on the
owner and operator of an installation. The fire and rescue services are not obliged to give
consent or agreement as to the safety of an installation. If an installation does not have
an adequate fire safety plan and precautions, the responsible owners or operators will be
prosecuted. This has implications for landlords who have leased space to energy storage
operators as well as the Directors of the ultimate holding companies operating storage.
The fire risk from a battery installation covers damage to the energy storage medium, as well
as the ancillary equipment, and the buildings or containers. Fire could start in the energy
storage medium itself (such as the battery) or it could be started elsewhere and then spread
to any other combustible materials (including the battery). Additional hazards could include
fire spreading to other parts of the same installation or adjacent property. For example, a fire
on a battery installed on a power station or industrial site could spread to fuel tanks. The
hazards from fires are complex, and need to include the effects of flame, heat, smoke and
products of combustion on the installation and other properties.
Fire engineers can model the impact of fire on an installation, considering a range of possible
ignition scenarios and the local environment and the modelling will support and inform the
development of the fire protection safety case. This is dependent on the provision of accurate
information from battery manufacturers concerning maximum allowable temperatures
before fire propagation can be assumed to occur and the heat released by a burning battery.
The response to a fire on a battery storage project will differ, depending on the battery
chemistry, the site location and local environment and method of installation. For small
installations it may be prudent to let the fire burn itself out, but for larger installations fire
quenching using an extinguishing material will be a better course of action. The products of
combustion and the effect of water or other extinguishing materials on battery and other
electrical materials must be assessed.
8 In the UK, The Regulatory Reform (Fire Safety) Order 2005, No. 1541, UK Parliament, available at http://www.
legislation.gov.uk/uksi/2005/1541/contents/made
19
The fire and safety plan should include a means for containment of water, or other materials
used for extinguishing the fire, but avoiding run off into the local environment. The standards
for lead acid battery rooms include sufficient primary and secondary bunding to contain
battery electrolyte and this is recommended practice for flow battery systems.
4.7 INTENDED APPLICATIONS, ASSET LIFE AND ENVIRONMENTAL IMPACT
A battery energy storage plant might be used for one or more applications, and the
applications may have a significant impact on the project's asset life and its environmental
impact. As an example, from a related industry, a small generator installed for back-up power
or peaking power may only be expected to run in exceptional circumstances, and so may be
granted planning consent on the basis of a limited number of running hours each year.
Energy storage is an enabling technology and can be used for many applications, both
connected to, and separated from, the power network. A battery energy storage plant can
be placed in the following operational states:
−− Shutdown: the system is disconnected and there is no power flow in or out and
the battery system will need to be moved to a standby state before use. (Note that
this may be different for different battery types and some systems may be able to
go from shutdown to standby or operational in seconds or less. Other systems may
require cooling or heating systems to be started, fans or pumps to be started as well
as control systems to boot up.
−− Standby: the battery is able to be charged or discharged promptly. In this state,
cooling and heating may be required, pumps and fans may be operational, meaning
that noise and emissions will be occurring, even if there is no charge or discharge
taking place.
−− Operational: the battery is charging or discharging. Note that battery storage can be
fast to operate and moving from charge to discharge can be close to instantaneous,
and so the battery can be used for regulating frequency on a cycle-by-cycle basis.
The main applications currently considered for a battery energy storage system are:
−− Dynamic frequency regulation – discharging or charging power to or from the
network to maintain system frequency on a continuous basis.
−− Static frequency regulation – discharging or charging power to or from the
network to maintain system frequency when the frequency changes outside set
limits. This means that the battery is expected to be in standby mode for most of the
time.
−− Reserve – discharging or charging power over longer time periods when for example
there is insufficient generating power.
−− Energy trading – importing and exporting power, often on a continuous basis, to
take advantage of energy price differences between time periods, to timeshift the
output from renewable generation or to reduce demand at peak periods to reduce
network connection charges. This can also include participation in capacity markets
and the balancing mechanism.
An owner/operator seeking to maximise the financial benefit of a battery system may need to
move between services as the market conditions change. Planning and consenting authorities
do not normally consider the commercial viability of projects, but they should be aware of the
constantly changing market-place in the provision of services to the electricity transmission
20
network operator and the distribution network operators and that the services provided by
these installations will certainly change during the lifetime of the asset.
The operational duties of the battery will affect the battery's lifetime to a greater or lesser
extent depending on the battery type. In general terms, the more discharge/charge cycles
that a battery undergoes, the more the overall performance is degraded and the lifetime
is reduced. For some battery types, such as vanadium flow systems, this is not regarded
as an issue, but for other types, including lead acid and some lithium systems, this decline
in performance can result in a reduction in lifetime and require early replacement or
decommissioning.
The planning or consenting authority may wish to consider the impact of the number of
running hours on the broader environment and local area, and include assessments of noise,
emissions, repairs and maintenance which will all be proportional to the operating profile of
the system.
Emissions include hydrogen and other gases from certain battery types, heat, which may
be dissipated through air cooling or water cooling and will arise as a by-product of battery
operation. Batteries, BMSs, PCSs and transformers all need to be maintained within an
appropriate operating temperature and fans, pumps and other electro / mechanical devices
may be required.
4.8 HYBRID INSTALLATIONS
The term hybrid installations could refer to either a project with multi technology energy
storage mediums or a project where energy storage is combined with another energy
installation such as wind or solar generation.
A hybrid multi technology energy storage project should be considered for planning and
consenting purposes as both two separate storage types, each with its own characteristics
under planning guidance, and also in combination. The risk and hazard analysis should
consider what impact an event on one part of the site would have on the other – for example
whether a fire or explosion in battery type A would impact on battery type B or vice versa.
Many storage installations have been developed as standalone sites, but the trend is towards
combined projects such as behind the meter demand or generation and with renewable,
particularly photovoltaics (PV) solar or wind generation. These raise similar planning
considerations – principally, care should be taken to ensure that the impact of the storage
technology on the generation technology or vice versa has been properly considered.
Currently, generation projects are given permission or consent based on their net generation
capacity. Recently, government publications (e.g. Ofgem, Smart systems and flexibility plan:
Upgrading our energy system) consider storage projects to also be classified as generation.
This may mean that adding storage to a renewable generation project moves the project out
of the LPA jurisdiction into national planning. However, planning applications and decisions
should always be taken with a complete assessment of risks and impacts, both of the facility
itself and the surrounding environment.
21
5 COMPLIANCE WITH LEGISLATION AND STANDARDS
Legislation, including the Electricity at Work Regulations 1989 Act and the Health and Safety
at Work etc Act is highly relevant in establishing the framework for planning and construction
of projects. Adhering to the relevant standards provides reassurance of best practice and may
be a requirement for insurance. There is a broad range of overlapping standards, so it is not
possible to give an exhaustive list. Standards are being developed continuously so referencing
up-to-date indexes is important. There are national standards and international standards:
those adopted by the British Standards Institution (BSI), International Electrotechnical
Commission (IEC), the European Committee for Electrotechnical Standardization (CENELEC),
or the International Organization for Standardization (ISO) for example, are likely to be
relevant. Where it exists, any harmonised international standard should take precedence.
Some commercial9 and not for profit organisations10 also produce standards or codes of
practice, often in advance of a national or international standard. In the UK, the ENA's
Engineering Recommendations are requirements of the Grid Code or Distribution Code and
so are legally enforceable requirements. Standards can be grouped by their subject matter,
as shown in Tables 2–5:
Table 2: Standards concerning specific battery type
Battery type
Standard Lithium- Lead-acid Flow Nickel High
ion batteries cadmium temperature
BS EN 62281:2017, Safety X
of primary and secondary
lithium cells and batteries
during transport
IEC 62619:2017, Secondary X
cells and batteries containing
alkaline or other non-
acid electrolytes – Safety
requirements for secondary
lithium cells and batteries, for
use in industrial applications
IEEE P1679.2, Draft Guide X
for the characterization
and evaluation of sodium-
beta batteries in stationary
applications
IEC 60896-22, The technical X
requirements for stationary
VRLA batteries
9 For example, DNVGL-RP-0043, Safety, operation and performance of grid connected energy storage systems,
published by DNV as part of the GRIDSTOR project.
10 For example, Institute of Electrical and Electronics Engineers (IEEE), and Institution of Engineering and Technology
(IET) produce standards or similar documents which are treated as de facto standards and are often considered as
requirements by insurance companies.
22
Table 2: Standards concerning specific battery type (continued)
UL 1642, Standard for X

lithium batteries
BS EN IEC 62485-2:2018, X X X X X
Safety requirements for
secondary batteries and
battery installations
CWA 50611:2013, Flow X
batteries – Guidance on the
specification, installation and
operation
IEEE P2030.3, Standard for X X X X X
test procedures for electric
energy storage equipment
and systems for electric
power systems applications
Table 3: Standards concerning energy storage systems
Name Description
IEC 62933, Electrical energy storage Currently under development, published parts covered
systems (EESS) below.
IEC 60050-601:1985, International Defines low voltage<1 kV, 1 kV < medium voltage
electrotechnical vocabulary. Chapter < 30kV and high voltage > 30 kV.
601: Generation, transmission and
distribution of electricity – General
IEC 62933-1, Electrical energy Covers the detailed terminology within the standard.
storage (EES) systems – Part 1: Notably a distinction is made between low voltage,
Vocabulary medium voltage and high voltage Electrical energy
storage systems (EESS) and residential EESS, commercial
and industrial EESS and utility EESS. (See IEC 60050 for
voltage level definitions).
IEC 62933-2-1 2018, Electrical This formally defines EESS parameters such as active and
energy storage (EES) systems – reactive power, round trip efficiency, expected service
Part 2–1: Unit parameters and life etc., and formally sets out how to verify these
testing methods – General parameters in testing.
specification
IEC 62933-4-1, Electrical energy Assesses the interaction of the EESS with the
storage (EES) systems – Part 4–1: environment across its entire life-cycle and how adverse
Guidance on environmental issues – mutual effects on the EESS/environment may be
General specification considered and mitigated.
IEC 62933-5-2, Electrical Covers risk assessment, identification and mitigation
energy storage (EES) systems of hazards, across 5 unique EESS classes based on
Part 5–2: Safety requirements electrochemistry. Expected to be published in 2020.
for grid integrated EES systems –
electrochemical based systems
23
Table 4: Standards concerning electrical installations
Name Description
IEEE 1547, Standard for interconnection and This covers all DER including Energy Storage
interoperability of distributed energy resources Systems connected at distribution level,
(DER) with associated electric power systems specifying detailed electrical performance
interfaces characteristics such as active and reactive
power and voltage control, protection, fault
ride through, islanding, communication and
testing and verification of the same.
IEEE 1584-2018, Guide for performing arc-flash Guidance for performing arc-flash hazard
hazard calculations calculations.
IEC 61936-1: 2010, Power installations A very general standard covering guidance
exceeding 1 kV a.c.- Part 1: Common rules for all common items of power system plant
with regard to insulation, protection and safe
clearances.
IEC 61000, Electromagnetic compatibility (EMC) A family of standards specifying
electromagnetic compatibility equipment in
various environments. Relevant parts are 1–2
methodology, 6–2 (industrial environments)
and 6–5 (substations).
IEC 61850, Power utility automation Standard for communication protocols used
in the automation of electricity substations.
The basic standard focuses on secondary
system communication architecture, but
further modules exist for distributed energy
resources and e-mobility.
BS 7671, Requirements for electrical National standard in the UK for electrical
installations (IET wiring regulations) installation and the safety of electrical wiring
for installations below 1.5 kV d.c. and 1 kV a.c.
IEC 60364, Electrical installations for buildings This IEC document closely mirrors BS 7671
but has minor variations to account for
international practices.
ENA Engineering recommendation G83, Although not a storage standard per se,
Recommendations for the connection of type G83 in the UK applies to any generation
tested small-scale embedded generators (up equipment connected to the network that
to 16A per phase) in parallel with low-voltage is less than 16 A per phase (i.e. 3.68 kW at
distribution systems 230 V).
This will be replaced by G98, Requirements
for the connection of fully type tested micro-
generators (up to and including 16 A per
phase) in parallel with public low voltage
distribution networks on or after 27 April 2019)
24
Table 4: Standards concerning electrical installations (continued)
ENA Engineering recommendation G59, Although not a storage standard per se,
Recommendations for the connection of G59 in the UK applies to any generation
generating plant to the distribution systems of equipment connected to the network with
licensed distribution network operators output greater than 16 A per phase (i.e.
This will be replaced by G99, Requirements for 3.68 kW at 230 V). Different sections of
the connection of generation equipment in G59 apply depending on overall power – for
parallel with public distribution networks on or example >50 kW must use G59 approved
after 27 April 2019 relays to de-energise equipment safely in the
event of a grid outage.
Table 5: Standards concerning electrical networks
Name Description
ENA Engineering recommendation Defines in high detail permissible voltage dips and flicker
P28, Planning limits for voltage caused by energisation of equipment connected to
fluctuations caused by industrial, voltages up to and including 132 kV – nominally dips
commercial and domestic should not be more than 3%.
equipment in the United Kingdom
ENA Engineering recommendation Planning limits for the degree of voltage balance in a
P29, Planning Limits for Voltage three-phase system. States that unbalance caused by
Unbalance in the United Kingdom individual loads should not be more than 1.3% but with
short-term deviations < 1 minute up to 2% allowed. In
aggregate, many loads are permitted a 2% unbalance.
ENA Engineering recommendation Specifies planning for the maximum permissible
G5/4, Planning levels for harmonics at different voltage levels. Can be summarised
harmonic voltage distortion and as percentage total harmonic distortion (THD): 5% at and
the connection of non-linear below 400 V, 4% up to 20 kV and 3% above 20kV.
equipment to transmission systems
and distribution networks in the
United Kingdom
ENA S36, Procedure to identify Very high voltage substations can cause the potential
and record “hot” substations of the local ground to temporally rise to dangerous
levels in the event of an earth fault – in addition to
obvious personal hazard this can interfere with telecoms
equipment. This standard covers how to measure and
record such hot sites.
ENA TS 41-36, Distribution The technical specification for distribution switchgear up
switchgear for service up to 38kV. to 36 kV, both cable and overhead line connected.
(Cable and overhead conductor
connected)
ENA TS 50-18, Design and Covers earthing and protection of secondary power
application of ancillary electrical system equipment, e.g. current transformers.
equipment
25
6 RISK ASSESSMENT
There should be a full consideration of risks including, but not limited to, accidental or
intentional damage and natural phenomena such as fire, weather (including snow and
ice and access during bad weather), flooding, land subsidence, flora and fauna (including
birds and mammals) and security. Note that risk assessment should be bidirectional – i.e.
include both risks to the facility and from the facility. The planning process should assess the
following risks and describe how the credible worst case has been mitigated. (Brief examples
of mitigation are given here, but clearly applicants must adhere to the relevant legislation.)
Risk Reason Example mitigation

Construction Construction related, Adherence to CDM. Contractor risk
site hazards working at height, manual assessment, adequate safety record
handling and accreditation. Appropriate
personal protective equipment (PPE).
Industrial site Slips, trips and falls, Undertake site risk assessment,
hazards manual handling, ongoing safety training of site staff,
chemical burns, appropriate PPE.
electrocution, explosion
Weather: storm, Water ingress, freeze- Ingress protection, antifreeze agents,
snow and ice thaw weathering, power system protection, adequate
electrical short circuit system earthing, lightning surge
suppression.
Subsidence and Land may be unstable Geological survey.
earthquake
Flora and fauna Effect on habitats, biotic Maintenance, adequate ingress
weathering, animals or protection.
birds nesting, animals
roaming onto site
Fire Flammable materials Fire breaks, adequate fire suppression,
clear emergency egress and ingress
routes. Fire safety drills.
Flood Electrical short circuit, Flood defence, electrical plant raised
contamination of water above flood height.
supply
Security Vandalism, theft CCTV monitoring, security alarms,
adequate lighting.
26
7 DECOMMISSIONING
Good practice, as required to comply with the CDM, includes maintenance and
decommissioning. Decommissioning is not simply a reversal of the construction process, as
it will include consideration of disposal of waste materials, compliance with the EU Batteries
Directives for recycling, and restoration of the land. The Batteries Directive creates a legal
requirement for recycling rates, and within national legislation there are requirements that
industrial batteries are returned to the distributor and sent to an approved battery treatment
operator or an approved battery exporter for treatment and recycling. The lifting capability of
any containers or battery enclosures should be checked prior to removal, and batteries and
other equipment may need to be removed from the enclosures prior to lifting.
A project developer should include a statement on decommissioning and recycling of all

equipment: the battery cells, containers, as well as the BMSs, ancillary equipment such as
switchgear and transformers and return of the site to its original condition. Many contractors
are used to dealing with the removal and repurposing or recycling of conventional electrical
infrastructure because of the high scrap value content of transformers and switchgear.
Currently, there are few systems in place for collection and treatment of advanced batteries,
particularly those of the lithium-ion family. Because lithium battery systems currently have
negative scrap value, it is important that the decommissioning plan is sufficiently well financed
to cover the full costs of decommissioning and removal from site. There is uncertainty within
the industry over the availability and suitability of recycling facilities which need to be available
within the next 10 years.
27
ANNEX A
FURTHER READING AND REFERENCES
A.1 FURTHER READING
Baxter, R. Energy storage: A nontechnical guide
EA Technology, A good practice guide on electrical energy storage
Smarter Network Storage Project, Design and planning considerations for large-scale
distribution-connected energy storage (SNS1.2)
US Department of Energy, Electric Power Research Institute, Electricity storage handbook

2016
A.2 REFERENCES
Regulations
Control of Substances Hazardous to Health Regulations 2002 No. 2677
Directive 2006/66/Ec of the European Parliament and of the council of 6 September 2006
on batteries and accumulators and waste batteries and accumulators and repealing Directive
91/157/EEC
Directive 2008/1/EC1 on Integrated Pollution Prevention and Control (the IPPC Directive)
Directive 2010/75/EU of the European Parliament and of the council of 24 November 2010
on industrial emissions (integrated pollution prevention and control)
Electricity Act, 1989 c. 29
Health and Safety at Work etc. Act 1974
Planning (Northern Ireland) Act 2011 c. 25, UK Parliament
Planning etc. (Scotland) Act 2006 asp 17, Scottish Parliament
Registration, evaluation, authorisation and restriction of chemicals,

EC Regulation No 1907/2006
The batteries and accumulators (placing on the market) Regulations 2008, No. 2164, UK
Parliament
The Construction (Design and Management) Regulations 2015, No. 51
The control of Major Accident Hazards Regulations 2015 No. 483
The Dangerous Substances (Notification and Marking of Sites) Regulations 1990
The Electricity at Work Regulations 1989 (SI 1989/635) (as amended)
28
The Planning (Development Management) Regulations (Northern Ireland) 2015 No. 71, UK
Parliament
The Planning Act 2008 c. 29, UK Parliament
The Pollution Prevention and Control (Industrial Emissions) Regulations (Northern Ireland)
2013, No. 160
The Pollution Prevention and Control (Scotland) Regulations 2012, No. 360 Scottish Parliament
The Regulatory Reform (Fire Safety) Order 2005, No. 1541, UK Parliament
The Town and Country Planning (Environmental Impact Assessment) Regulations 2017 No.
572, UK Parliament
The Town and Country Planning (Use Classes) Order 1987 No. 764
The Wales Act 2017 c. 4, UK Parliament
The Waste Batteries and Accumulators Regulations 2009 No. 890, UK Parliament
Town and Country Planning (Scotland) Act 1997 c. 8, Scottish Parliament
Town and Country Planning Act, 1990 c. 8, UK Parliament
British Standards Institution (BSI) – https://www.bsigroup.com
BS 7671 Requirements for electrical installations (IET wiring regulations)
BS EN 62281:2017 Safety of primary and secondary lithium cells and batteries during
transport
BS EN IEC 62485-2:2018 Safety requirements for secondary batteries and battery installations
Energy Networks Association (ENA) – http://www.energynetworks.org/
Engineering recommendation G5/4 Planning levels for harmonic voltage distortion and the
connection of non-linear equipment to transmission systems and distribution networks in the
United Kingdom
Engineering recommendation G59 Recommendations for the connection of generating plant

to the distribution systems of licensed distribution network operators
Engineering recommendation G83 Recommendations for the connection of type tested small-
scale embedded generators (up to 16A per phase) in parallel with low-voltage distribution
systems
Engineering recommendation G98 Requirements for the connection of fully type tested
micro-generators (up to and including 16 A per phase) in parallel with public low voltage
distribution networks (replacing G83) on or after 27 April 2019)
Engineering recommendation G99 Requirements for the connection of generation equipment

in parallel with public distribution networks (replacing G59) on or after 27 April 2019
Engineering recommendation P28 Planning limits for voltage fluctuations caused by

industrial, commercial and domestic equipment in the United Kingdom
Engineering recommendation P29 Planning limits for voltage unbalance in the United
Kingdom
29
Recommendation G5/4 Planning levels for harmonic voltage distortion of non-linear

equipment
S36 Procedure to identify and record 'hot' substations
TS 41-36 Distribution switchgear for service up to 38kV. (Cable and overhead conductor
connected)
TS 50-18 Design and application of ancillary electrical equipment
Institute of Electrical and Electronics Engineers (IEEE) – https://www.ieee.org/
IEEE P1679.2 Draft: Guide for the characterization and evaluation of sodium-beta batteries
in stationary applications
IEEE 60896-22 Stationary lead-acid batteries – Part 22: Valve regulated types – Requirements
IEEE P2030.3 Standard for test procedures for electric energy storage equipment and systems
for electric power systems applications
IEEE 1547 Standard for interconnection and interoperability of distributed energy resources
(DER) with associated electric power systems interfaces
IEEE 1584-2018 Guide for performing arc-flash hazard calculations
International Electrotechnical Commission (IEC) – https://www.iec.ch/
IEC 60364 Electrical installations for buildings
IEC 60896-22 The technical requirements for stationary VRLA batteries
IEC 61000 Electromagnetic compatibility (EMC)
IEC 61850 Power utility automation
IEC 61936-1: 2010 Power installations exceeding 1 kV a.c. – Part 1: Common rules
IEC 62619:2017 Secondary cells and batteries containing alkaline or other non-acid
electrolytes – Safety requirements for secondary lithium cells and batteries, for use in
industrial applications
UK Government – https://www.gov.uk
Department of Local Government and Communities, Plain English guide to the planning
system
Ofgem, Upgrading our energy system: Smart systems and flexibility plan
Batteries and accumulators (placing on the market) regulations: compliance and guidance
Electrical waste: retailer and distributer responsibility
Waste batteries: producer responsibility
30
Various authors
European Committee for Electrotechnical Standardization (CENELEC), CWA 50611:2013,

Flow batteries – Guidance on the specification, installation and operation
DNVGL-RP-0043 Safety, operation and performance of grid connected energy storage

systems, published by DNV as part of the GRIDSTOR project.
International Organization for Standardization (ISO), ISO 668:2013 Series 1 freight

containers – classification, dimensions and ratings
Standards Australia, DR AS/NZS 5139:2017 Electrical installations – Safety of battery systems

for use with power conversion equipment
The Institution of Engineering and Technology (IET), Code of practice for electrical energy
storage systems
Underwriters Laboratory (UL) 1642 Standard for lithium batteries
31
ANNEX B
ABBREVIATIONS AND ACRONYMS
A ampere
a.c. alternating current
BEIS The Department for Business, Energy and Industrial Strategy
BMS battery management system
BSI British Standards Institution
C celsius
CDM Construction, Design and Maintenance Regulations
CENELEC European Committee for Electrotechnical Standardization
COMAH Control of Major Accident Hazards Regulations
d.c. direct current
dBA A-weighted decibels
DER distributed energy resources
DNS development of national significance
EESS Electrical energy storage system/s
EI Energy Institute
EIA Environmental Impact Assessment
ENA Energy Networks Association
ft foot/feet (unit of measurement)
HSE Health and Safety Executive
HVAC heating, ventilation, and air conditioning
Hz hertz
IEC International Electrotechnical Commission
IEEE Electrical and Electronics Engineers
IET Institution of Engineering and Technology
in inch (unit of measurement)
IPPC Integrated Pollution Prevention and Control
ISO International Organization for Standardization
kV kilovolt
LCNF Low Carbon Networks Fund
LiCoO2 lithium iron phosphate
Li-ion lithium-ion
LiMn2O4, Li2MnO3, or LMO lithium-ion manganese oxide battery
LPA local planning authority
m meter
MW megawatt
MWh megawatt-hour
NAMOS Dangerous Substances (Notification and Marking of Sites)
Regulations 1990
NaS sodium sulfur
NMC/MNC lithium nickel manganese cobalt
NSIP nationally significant infrastructure projects
Ofgem The Office of Gas and Electricity Markets
P&C protection relays and battery control software
PA Planning Act 2008
PbSO4 lead acid
32
PCS power conversion system

PPE personal protective equipment
PV photovoltaics
REACH Registration, evaluation, authorisation and restriction of
chemicals regulations
SM settlement meter
TCPA Town and Country Planning Act 1990
THD total harmonic distortion
UPS uninterruptable power supply
V volt
V vanadium (V/V all vanadium flow battery chemistry)
Zn Br zinc bromide
33
This publication has been produced as a result of
work carried out within the Technical Team of the
Energy Institute (EI), funded by the EI’s Technical
Partners and other stakeholders. The EI’s Technical
Work Programme provides industry with cost
effective, value adding knowledge on key current
and future issues affecting those operating in the
Energy Institute energy industry.
61 New Cavendish Street
London W1G 7AR, UK
t: +44 (0) 20 7467 7100
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9781787251229
ISBN 978 1 78725 122 9

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Battery storage planning

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Copyright © 2019 by the Energy Institute, London.

ISBN 978 1 78725 122 9

Published by the Energy Institute

2 Battery energy storage types . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

3 Navigating the planning regime – a UK example . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

4 What should be considered during risk assessment and planning applications? . . 15

5 Compliance with legislation and standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

Annex A Further reading and references . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

Annex B Abbreviations and acronyms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

LIST OF FIGURES AND TABLES

Figure 1 Typical components within a grid scale battery installation . . . . . . . . . . . . . . . . . . . 9

Table 1 Battery chemistry types . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Jacob Allinson RWE

Christophe Banos EDF Renewables

Affiliations are correct at the time of contribution.

The guidance is intended for:

The EI welcomes feedback on its publications. Feedback or suggested revisions should be

Electricity can be stored in many ways including:

2 BATTERY ENERGY STORAGE TYPES

High voltage cable

M Meter CT/ Instrument a.c./d.c. converter (physically

Figure 1: Typical components within a grid scale battery installation

2.1 WHAT IS A BATTERY?

In common use, a battery refers to an electrochemical device which supplies electrical

2.2 WHAT IS A BATTERY STORAGE SYSTEM?

2.3 TYPES OF BATTERIES IN USE

Type Examples Description Characteristics Applications

Figure 2: A standalone 250 kW 500 kWh ZnBr battery system

Figure 3: The inside of a 6 MW, 10 MWh lithium-ion battery system operated by UK

Figure 4: A multi container lithium-ion battery storage project

3 NAVIGATING THE PLANNING REGIME – A UK EXAMPLE

UK Planning Act 5 3b of Electricity Act Currently UK Central

Figure 5: UK planning regime for generation projects (at a glance)

All development is subject to compliance with planning legislation (Department of Local

3.1 THE PLANNING BACKGROUND

Different procedures apply in Scotland, Wales and Northern Ireland:

In Scotland, the devolved administration authorises generation projects over 50 MW whilst

According to categories specified by the Planning (Development Management) Regulations

4 WHAT SHOULD BE CONSIDERED DURING RISK

4.1 SITE SELECTION

4.2 ISSUES FOR DESIGN AND PLANNING APPLICATIONS

4.3 SPECIFIC ENERGY STORAGE CONSIDERATIONS

4.4 CONSTRUCTION CONSIDERATIONS

−− Compliance with the Construction, Design and Maintenance Regulations

4.5 OPERATIONAL CONSIDERATIONS

4.6 FIRE RISKS

4.7 INTENDED APPLICATIONS, ASSET LIFE AND ENVIRONMENTAL IMPACT

4.8 HYBRID INSTALLATIONS

5 COMPLIANCE WITH LEGISLATION AND STANDARDS

Table 2: Standards concerning specific battery type

Table 2: Standards concerning specific battery type (continued)

UL 1642, Standard for X

Table 3: Standards concerning energy storage systems

Table 4: Standards concerning electrical installations

PCS power conversion system