{ "_comment": [ "Every approval a project needs, who grants it, and whether the public can see it.", "", "Researched and each URL fetched on 2026-08-25. Two layers that are widely", "assumed to apply were checked and DO NOT normally apply; they are listed", "under not_normally_required rather than shown as gates, because rendering", "an approval a project never needed as 'missing' invents a problem.", "", "'public' is what the public can see, not whether the approval exists:", " full a register exists and a reader can check it", " partial existence and headline facts are public, the terms are not", " none genuinely commercial or security information, never published", "", "Every row carries a source_url, including the 'none' rows: a reader who", "is told something is private is owed the place that says so. Where the", "register itself is reachable, 'url' points at it and the site links the", "words rather than printing a register's name as plain text.", "", "Two dates, because they are different claims: 'as_of' is when the law and", "the registers were researched, 'urls_checked' is when every URL in here", "was last fetched and answered." ], "as_of": "2026-08-25", "urls_checked": "2026-08-26", "layers": [ { "key": "planning", "name": "Planning permission", "granted_by": "The local council", "public": "full", "where": "the council's planning register", "url": null, "applies_when": null, "applies": {"always": true}, "source": "Section 69, Town and Country Planning Act 1990; article 40, Town and Country Planning (Development Management Procedure) (England) Order 2015", "source_url": "https://www.legislation.gov.uk/ukpga/1990/8/section/69", "note": "Every council keeps its own register. There is no national one, so each project has to be checked on its own council's website." }, { "key": "eia_screening", "name": "Environmental assessment decision", "granted_by": "The local council", "public": "full", "where": "the council's planning register, filed alongside the application", "url": null, "applies_when": "any site over half a hectare", "applies": {"always": true}, "source": "Schedule 2, paragraph 3(a), Town and Country Planning (Environmental Impact Assessment) Regulations 2017 — threshold 0.5 hectare", "source_url": "https://www.legislation.gov.uk/uksi/2017/571/schedule/2", "note": "Nearly every grid-scale site is over the half-hectare mark, so the council can be asked to decide whether a full environmental assessment is needed. The usual answer is that it is not. The developer can also skip the question and submit an assessment anyway, so no screening decision on file does not mean the site avoided one." }, { "key": "grid_connection", "name": "Grid connection agreement", "granted_by": "The network company (NESO for the national grid, or the regional network operator)", "public": "partial", "where": "the connection registers show the size, the status and the date, but never the terms", "url": "https://www.neso.energy/data-portal/transmission-entry-capacity-tec-register", "applies_when": null, "applies": {"always": true}, "source": "NESO Transmission Entry Capacity register (16 fields, checked 2026-08-25) and the regional Embedded Capacity Registers", "source_url": "https://www.neso.energy/data-portal/transmission-entry-capacity-tec-register", "note": "The registers say a project has a connection, how big it is and when it is due. What it costs, what it has to put up as security and what happens if it misses a milestone are not published anywhere." }, { "key": "generation_licence", "name": "Generation licence", "granted_by": "Ofgem", "public": "full", "where": "Ofgem's public register", "url": "https://epr.ofgem.gov.uk/", "applies_when": "only above 50 MW", "applies": {"min_mw": 50}, "source": "Class A exemption, Schedule 2, Electricity (Class Exemptions from the Requirement for a Licence) Order 2001", "source_url": "https://www.legislation.gov.uk/uksi/2001/3270/schedule/2", "note": "Below 50 MW a project is exempt automatically. It does not apply for the exemption, does not tell anyone it is relying on it, and no register of exempt sites exists — so having no licence is the normal state, not a gap." }, { "key": "section_36", "name": "Scottish Ministers' consent", "granted_by": "The Scottish Government", "public": "full", "where": "the Energy Consents Unit register", "url": "https://www.energyconsents.scot/ApplicationSearch.aspx", "applies_when": "Scotland only, above 50 MW", "applies": {"nations": ["Scotland"], "min_mw": 50}, "source": "Section 36, Electricity Act 1989. Batteries are still generating stations in Scotland: the 2020 orders that took them out of the national regime cover England and Wales only", "source_url": "https://www.legislation.gov.uk/ukpga/1989/29/section/36", "note": "The same battery gets a national record in Scotland and only a local one in England." }, { "key": "dco", "name": "Development consent order", "granted_by": "The Secretary of State, on the Planning Inspectorate's recommendation", "public": "full", "where": "the national infrastructure planning register", "url": "https://national-infrastructure-consenting.planninginspectorate.gov.uk/project-search", "applies_when": "England, solar over 100 MW", "applies": {"nations": ["England"], "min_mw": 100, "techs": ["Solar"]}, "source": "Infrastructure Planning (Onshore Wind and Solar Generation) Order 2025, which raised the solar threshold from 50 MW to 100 MW on 31 December 2025. Standalone batteries were taken out of this regime in 2020 and are decided by the council at any size", "source_url": "https://www.legislation.gov.uk/uksi/2025/694/made", "note": null }, { "key": "land", "name": "Rights over the land", "granted_by": "The landowner", "public": "none", "where": "the rent, the length of the lease and what happens at the end are private between the developer and the landowner", "url": null, "applies_when": null, "applies": {"always": true}, "source": "Land Registry titles can show that a long lease exists, but never its terms, and there is no free bulk route to them — a title costs £3 a time", "source_url": "https://www.gov.uk/search-property-information-land-registry", "note": null }, { "key": "finance", "name": "Money and a buyer for the power", "granted_by": "Lenders, investors and whoever buys the electricity", "public": "none", "where": "never published", "url": null, "applies_when": null, "applies": {"always": true}, "source": "Companies House charges name a project's secured lenders, free and to anyone, but never the price or the conditions. The Capacity Market register would name anyone holding security over a project; it sits behind a sign-in (emrdeliverybody.com, checked 2026-08-26), so it is not a source a reader can follow", "source_url": "https://find-and-update.company-information.service.gov.uk/", "note": "This is usually the last gate, and the one nobody outside the deal can see. A project can hold every permission it needs and still not be built because this one has not closed." } ], "not_normally_required": [ { "name": "Hazardous substances consent", "why_not": "The Health and Safety Executive's position is that lithium-ion batteries are articles rather than substances, so a normal battery site does not need this consent and is not covered by the major-hazard rules. It bites only where a site stores something else in bulk, such as diesel for backup generators.", "source": "HSE position, quoted in the Scottish Government's planning guidance on battery storage", "source_url": "https://www.gov.scot/publications/planning-guidance-battery-energy-storage-systems/pages/5/", "contested": "Some published safety research argues large lithium-ion sites should be caught by the rules on substances generated when a process goes wrong. That is an open argument, not the current position." }, { "name": "Fire and rescue service sign-off", "why_not": "The fire service is not a statutory consultee on battery storage planning applications. Its guidance says so in terms. Many developers consult it anyway and publish an outline safety plan, but no approval is being given and none can be withheld.", "source": "National Fire Chiefs Council, grid-scale energy storage planning guidance, December 2025", "source_url": "https://nfcc.org.uk/our-services/building-safety/grid-scale-energy-storage-system-planning-guidance-for-fire-and-rescue-services/", "contested": "A Battery Energy Storage Systems (Fire Safety) Bill would make fire authorities statutory consultees. It is not law." }, { "name": "Building regulations approval", "why_not": "Battery sites are not dealt with through building regulations, except for ancillary buildings such as site offices. There is no public record of building control decisions at project level in any case.", "source": "National Fire Chiefs Council guidance, as above", "source_url": "https://nfcc.org.uk/our-services/building-safety/grid-scale-energy-storage-system-planning-guidance-for-fire-and-rescue-services/", "contested": null }, { "name": "Environmental permit", "why_not": "Grid-scale batteries are not currently covered by environmental permitting. The government consulted on bringing them in during August 2025 and has not published a response.", "source": "Environment Agency public registers, checked 2026-08-25; no battery storage class in scope", "source_url": "https://environment.data.gov.uk/public-register/view/index", "contested": "If the consultation lands, this becomes a real approval with a public register." } ] }