EIR Request - Keith-Area BESS Safety and Cumulative Records

Request 101004044868

Please treat this as a request for recorded information under the Environmental Information (Scotland) Regulations 2004 and, for any information falling outside those Regulations, under the Freedom of Information (Scotland) Act 2002.

The request concerns grid-scale battery energy storage systems in and around Keith. Please search records held from 1 January 2021 to the date of this request.

To assist your search, the projects and site names currently known to us are:

1. Section 36 Blackhillock BESS / Zenobe — ECU00003404; Moray reference reported as 22/00067/S36. It is included here only for safety, emergency, cumulative, engagement and consolidated multi-project records outside the Blackhillock-only categories already requested.

2. Drum Farm Energy Storage System / RES — 49.9MW; 22/00715/APP.

3. Westerton Road BESS / Keith Renewables Limited — 49.9MW; approved in March 2023; please confirm the final planning reference.

4. Greener Grid Park, 10 Westerton Road — 24/00263/SCN.

5. Land at Gibston Farm / Blackhillock FlexPower BESS — 349MW; ECU00005237; Moray reference reported as 25/00043/S36.

6. Kedrum BESS / RE Projects Development Ltd — proposed 150MW; ECU00006393; Aberdeenshire Council ENQ/2026/0802. This is an Aberdeenshire and Scottish Ministers matter, not a Moray planning application. It is listed only to identify cross-boundary or cumulative records held by Moray Council.

7. Any BESS proposal recorded under the names Coldhome Farm or Netherton Farm. Please state whether either is a separate project or another name/address for a project already listed.

8. Any other grid-scale BESS project recorded within the Keith and Strathisla Community Council areas or otherwise identified by the Council as being in or immediately around Keith.

A. Existing multi-project register or structured data

Please provide any existing spreadsheet, database export, GIS layer, internal tracker or other structured record held by the Council that identifies more than one BESS project in Moray or brings together BESS projects in and around Keith.

This section asks only for an existing consolidated or multi-project record. It does not repeat the Blackhillock-only approved plans, archived records, GIS or red-line boundaries, permitted-development plans, or implementation or status records already requested under Council reference 101004036230.

Where those fields are already held, please include:

• project and site name;

• location;

• developer or applicant;

• Moray Council and Energy Consents Unit reference;

• proposed MW and MWh capacity;

• application stage and current status;

• key application, consent, construction and operational dates; and

• direct planning-register or Energy Consents Unit links.

If no consolidated record is held, please confirm that. This part of the request does not require the Council to create a new dataset or map.

B. Publicly accessible planning and safety records

For each named project within Moray, and for any Kedrum material actually held by Moray Council, please provide direct public links to the following records. Where a record is held but is not accessible online, please provide an electronic copy.

For Blackhillock, this section is limited to the safety, emergency, pollution and incident-response records listed below that fall outside the categories already requested. If a document is already being handled under 101004036230, please cross-refer rather than reproduce it:

• the current or approved Battery Safety Management Statement, Battery Fire Safety Statement, fire-risk assessment, Emergency Response Plan, or equivalent document;

• plans or documents showing emergency-vehicle access and circulation, firefighting-water provision, battery and transformer spacing, distances from occupied buildings, and firewater or contaminated-runoff containment;

• any assessment of thermal runaway, explosion or vapour-cloud effects, toxic smoke or gas, off-site consequences, evacuation or cordon requirements;

• substantive formal consultation responses or recorded advice from SFRS, Police Scotland, SEPA, Environmental Health or the Council’s emergency-planning function;

• decision notices, planning conditions and condition-discharge approvals concerning fire safety, emergency planning, water pollution, drainage or incident response; and

• any current public warning, resident communication or community emergency information held for the site.

I am not seeking personal data or security-sensitive tactical detail. If such material appears within a record, please provide a redacted copy or the non-sensitive remainder and identify the exception relied upon.

C. Cumulative emergency and environmental planning

Please provide any recorded assessment, briefing, report, meeting note or substantive correspondence held by the Council that considers the combined or cumulative implications of more than one BESS development around Keith, including any consideration of:

• emergency-service access and response capacity;

• firefighting-water availability;

• contaminated firewater and effects on drains, soils or watercourses;

• toxic smoke, gas or vapour and off-site receptors;

• evacuation or cordon planning;

• construction and operational access where incidents or road closures overlap;

• cross-boundary effects or coordination concerning Kedrum BESS, Keith or the Moray boundary; or

• the need for multi-agency exercising or a community emergency plan.

Please provide existing records only; no new assessment is requested.

D. Public engagement and local benefit records

For each named project, please provide or link to any held material below, excluding any Blackhillock record already being handled under 101004036230:

• pre-application consultation report and recorded attendance or response totals;

• neighbour-notification or public-notice record, including the method and geographic extent of notification where recorded;

• number of public representations received, separated into objections, support and neutral comments where already recorded; and

• planning obligation, Good Neighbour Agreement, community-benefit agreement, developer contribution or community-fund record, including the value and duration where held.

I recognise that consultation attendance and representation totals do not measure the number of residents who were actually aware of a proposal. I am requesting only the figures already held.

E. Westerton Road decision and March 2023 discussion

Please provide direct links or electronic copies of:

• the officer report, minutes and decision notice for the March 2023 decision on Keith Renewables Limited’s Westerton Road BESS;

• the exact planning reference and present development status;

• any publicly available recording or transcript of the relevant Planning and Regulatory Services Committee discussion; and

• any recorded Police Scotland or SFRS advice held by the Council that informed discussion of a possible cordon, evacuation or “let it burn” response.

F. Kedrum cross-boundary records

For Kedrum BESS, ECU00006393 / ENQ/2026/0802, please provide any held:

• notification, consultation, referral or substantive correspondence received from or sent to Aberdeenshire Council, the Energy Consents Unit, the applicant, SFRS, Police Scotland, SEPA or another authority;

• planning, environmental-health, roads, emergency-planning or public-health record considering possible effects on Keith, Moray residents, Moray roads or services, or the Moray boundary;

• record considering Kedrum alongside BESS or other major energy developments within Moray; and

• record of a decision that Moray Council did not need to comment, consult or hold further information.