Balancing green: battery storage and preserving the Green Belt

Could a decision to approve a battery storage site on the Green Belt signal a trend towards prioritisation of green energy strategy over and above the protection of the Green Belt? 
 
At no’d. para. 51 of a decision on Conrad Energy (Developments) II Limited’s appeal against the refusal of planning permission by Staffordshire Moorlands District Council for a battery storage site at Armshead Farm, Werrington nr. Stoke-on-Trent the Inspector said:
 
“Noting the substantial weight to be given to the Green Belt harm in terms of its impact on openness and having carefully considered any other harm that has been identified, I find that the acceptability of the proposed scheme is finely balanced. Due to the limited harm I have found in relation to the openness of the Green Belt, notwithstanding the substantial weight attributed to it, and considering the potential for other harm to be mitigated or addressed through the development or attached conditions, I find that, on balance, the benefits in favour of the proposal, when considered cumulatively and individually, would clearly outweigh the limited Green Belt harm and other identified harm.”
 
What is the potential for this decision to be applied universally to any battery storage site in the Green Belt? 
 
Will the fine balance, identified by the Inspector, in future be weighted in favour of a developer because of the governments evolving energy strategy?
 
At no’d. para. 31 the Inspector had noted:
 
“The Government has set out in its British Energy Security Strategy 2022 its support to ensure a more flexible, efficient energy system by encouraging all forms of flexibility with sufficient large-scale, long-duration electricity storage to balance the overall renewable energy system. Battery storage sites, such as that proposed in this case, form a key part of the systems and infrastructure which utilise renewable energy and improve the efficiency of supply. Furthermore, such facilities provide a means to reduce waste arising from losses between demand and supply. Accordingly, support for such energy storage development is clearly set out by the Government’s energy strategy and the Framework.”
 
Each planning application will inevitably turn on its merits and it is noteworthy that the Inspector considered all five purposes of the Green Belt identified in Paragraph 143 of the National Planning Policy Framework (December 2023), namely:

• whether the proposal would be inappropriate development in the Green Belt, having regard to the Framework and any relevant development plan policies;
• the effect of the proposal on the purposes and openness of the Green Belt;
• the effect of the proposal on the character and appearance of the surrounding area, with particular regard to landscape character;
• the effect on the proposal on the living conditions of nearby residents with regard to outlook, noise and lighting; and
• whether any harm by reason of inappropriateness, and any other harm, would be clearly outweighed by other considerations, so as to amount to the very special circumstances required to justify the proposal.

In this case, the decision turned on the existence of very special circumstances and, whilst the development was undeniably inappropriate in the Green Belt, the Inspector decided that the potential benefits from the battery storage facility outweighed any harm to the Green Belt.
 
There will continue to be cases where the impact on the Green Belt is inappropriate and is not outweighed by the potential benefits from battery storage facilities but, as successive governments’ energy strategies continue to evolve, they may become less common.