“If my company was installing a solar ‘farm’, would the Environmental Impact Assessment regulations expect me to declare the presence of Battery Energy Storage Systems?”

Yes, if your company is installing a solar farm with Battery Energy Storage Systems (BESS), Environmental Impact Assessments (EIAs) will likely require you to declare the presence of the BESS. 

Environmental Impact Assessments are mandatory for large-scale developments, including solar farms with BESS, to evaluate potential effects on air, water, noise, biodiversity, and ecological systems.  The presence of BESS significantly increases the scope of these assessments due to specific risks such as:

Fire and explosion hazards from lithium-ion batteries, which can release toxic fumes and cause thermal runaway. 

Groundwater contamination from potential chemical leaks or firewater runoff.

Noise pollution from cooling systems, inverters, and transformers. 

Visual and landscape impacts from additional infrastructure. 

Waste management considerations, especially at end-of-life.

As highlighted in multiple sources, including Dentons and UL, BESS projects must undergo detailed assessments covering these environmental and safety risks.  Furthermore, the UK government is actively moving to integrate BESS into the Environmental Permitting Regulations (EPR), which will formalize requirements for pollution control, fire safety, and waste management.  This regulatory shift reinforces the need to disclose BESS in EIAs. 

In summary, declaring the BESS is not optional—it is a critical part of the EIA process to ensure compliance, risk mitigation, and public transparency. 

“What important factors should I be aware of should the Battery Energy Storage Systems be removed from the design?”

Removing Battery Energy Storage Systems (BESS) from your solar farm design simplifies the Environmental Impact Assessment (EIA) but introduces other critical considerations:

Grid Stability and Intermittency

Without BESS, the solar farm’s output becomes fully intermittent—generating power only during daylight hours. This can exacerbate grid imbalances, especially during evening demand peaks (“duck curve”), requiring backup from fossil fuel plants or grid-scale storage elsewhere. 

Reduced Land and Environmental Footprint

Eliminating BESS removes risks tied to battery systems: fire hazards, chemical leaks, and toxic waste at end-of-life. This reduces the EIA’s scope, particularly around pollution control, firewater runoff, and hazardous waste management.

Lower Capital and Regulatory Burden

BESS often triggers stricter permitting, especially for systems over 50MW (previously classified as Nationally Significant Infrastructure Projects in the UK). Removal streamlines approval and reduces compliance costs related to battery-specific regulations. 

Energy Export Limitations

Without storage, excess daytime generation may be curtailed if grid demand or transmission capacity is insufficient, reducing project efficiency and revenue potential. 

Environmental Trade-offs

While BESS adds complexity, it enhances renewable reliability. Removing it may indirectly support continued reliance on non-renewable peaker plants, offsetting some carbon benefits.