HWFRS recognise that BESS and Solar Energies are a fundamental part of the UK’s move towards a sustainable energy system. In the UK, approval for the majority of BESS installations takes place through the Local Authority planning process.

For information about Solar Farms please click here or our FAQs on BESS and Solar applications here

Whilst Local Authorities are not required to consult HWFRS as part of the planning process, we encourage early and continuous engagement from applicants, designers and planners to help us provide advice and support – please email us at bconsult@hwfire.org.uk

HWFRS’s expectations align to professional BESS Guidance from the National Fire Chiefs Council. Although this guidance is intended for Fire & Rescue Services, its content is ‘based upon a range of supporting materials including academic research, national and international standards, case studies, and industry guidance’ which will help designers, owners and applicants understand how to mitigate the risks around fire. BESS generally

The guidance indicates that a comprehensive risk management process must be undertaken by operators to identify hazards and risks specific to the facility and develop, implement maintain and review risk controls. From this process a robust emergency response plan can be developed. The guidance has been developed with the safety of the public and emergency responders in mind, and recognises that the ultimate responsibility for the safe design and running of these facilities rests with the operator.

Before you apply for planning permission

At the outset of your project please get in touch with our Fire Safety consultation team by emailing bconsult@hwfire.org.uk in order for us to discuss your application, design and plans with you before any submissions are made.  This will enable us – if necessary – to work with you prior to submission in order help you to check your project meets the requirements set out in the NFCC Guidance before submitting it to the planning authority.

Prior to submitting an application please provide us the following information

• Provide an outline how your proposed site meets the recommendations contained in the NFCC Guidance for Fire and Rescue Services
• Where applicable, please provide details of how you will deal with risks that may arise as a result of your proposal deviating from the NFCC Guidance, or other international design codes and industry best practise
• Provide us a detailed diagram/plan of the site with how the BESS units will be laid out relative to each other
• Who is at risk at the proposed site in the event of thermal runaway
• Evidence that site geography has been considered (e.g. prevailing wind conditions)
• Your intended fire strategy in the event of thermal runaway (e.g. controlled burn with boundary cooling or internal water suppression)

Your application proposal should have considered/demonstrate the following

• 1. Effective identification and management of hazards and risks specific to the siting, infrastructure, layout, and operations at the facility.
• 2. Impact on surrounding communities, buildings, and infrastructure.
• 3. Siting of renewable energy infrastructure so as to eliminate or reduce hazards to emergency responders.
• 4. Safe access for emergency responders in and around the facility, including to energy storage infrastructure and firefighting infrastructure.
• 5. Provision of adequate water supply and firefighting infrastructure to allow safe and effective emergency response. (e.g. flow rates, static tanks, hydrants, fire mains). See p.8 of the NFCC Guidance for further information. Water UK also provides guidance for the use of water for firefighting
• 6. Vegetation sited and managed so as to avoid increased bushfire and grassfire risk.
• 7. Prevention of fire ignition on-site.
• 8. Prevention of fire spread between site infrastructure (solar panel banks, wind turbines, battery containers/enclosures).
• 9. Prevention of external fire impacting and igniting site infrastructure.
• 10. Provision of accurate and current information for emergency responders during emergencies.
• 11. Effective emergency planning and management, specific to the site, infrastructure and operations.
• 12. Owner to have a comprehensive Emergency Response Plan, showing full understanding of hazards, risks, and consequences.

A copy of Hereford and Worcester Fire and Rescue Service’s position on Battery Energy Storage Systems (BESS) can be downloaded here.

For the NFCCs Grid Scale Battery Energy Storage System planning guidance for FRSs, click here.

As the project nears completion

As the project nears completion we will need the following information, as set out in the NFCC Guidance. The provision of this information enables us to compile the basis of a Site Specific Risk Information (SSRI) intel assessment. This will then be used to formulate an emergency response plan which can be made available to our operational response crews.

(Note: due to the rapidly changing nature of the technology HWFRS recognises that the procurement of technology may be left until the later stages of a project.)

However, please provide the following information:

1. The battery chemistries being proposed:

For example: Lithium-ion Phosphate (LFP), Lithium Nickel Manganese Cobalt Oxide (NMC)). 

We need this because:

• battery chemistries will directly affect the heat released when a cell goes into 
  thermal runaway
• battery chemistries will influence vapour cloud formation.
• an understanding of the battery chemistry is useful when requesting scientific 
  advice during an incident.

2. The battery form factor (e.g. cylindrical, pouch, prismatic)

3. Type of BESS e.g. container or cabinet

4. Number of BESS containers/cabinets

5. Size/capacity of each BESS unit (typically in MWh)

6. How the BESS units will be laid out relative to one another.

7. A diagram / plan of the site.

8. Evidence that site geography has been taken into account (e.g. prevailing wind conditions).

9. Access to, and within, the site for fire and rescue service assets

10. Details of any fire-resisting design features

11. Details of any:

• fire suppression systems
• on site water supplies (e.g. hydrants, EWS etc)
• smoke or fire detection systems (including how these are communicated
• gas and/or specific electrolyte vapour detection systems
• temperature management systems
• ventilation systems
• exhaust systems
• deflagration venting systems

12. Identification of any surrounding communities, sites, and infrastructure that may be impacted as a result of an incident.

^{The above list and information taken from the NFCC Guidance  ‘Grid Scale Battery Energy Storage System planning’}

Lastly…

Please do not forget to notify HWFRS by email when

• Site construction begins

 So that we can update our system and make crews aware of site access location(s).

• Following delivery of the initial phase of BESS containers

So that we can update our system of the potential increased risk at the site.

• Project completion/activation

So that our Operational Response crews can complete a Site Specific Risk Information (SSRI) visit and align our operational response with the applicant’s emergency response plan (ERP).

BESS with permanent buildings

Where the proposed BESS site is being designed with permanent buildings, the consultation would be reviewed in the normal manner against Approved Document B: Volume 2: Buildings other than dwellings 2019 edition which includes vehicle access and facilities for firefighters. 

If this is the case, HWFRS would expect to receive plans and documentation including fire risk assessments by email at bconsult@hwfire.org.uk

Design of your solar farm

To ensure fire and rescue services can access your site in the event of a fire or emergency, your planning application should show that you have considered the following:  

What solar farms should consider

1. The provision of a detection and monitoring system capable of: 
   –   24/7 monitoring
   –   the identification of potential failure conditions 
    –   able to shut-down and isolate affected inverters, panels and arrays  
2. Site operators should have a 24/7 emergency response procedure that enables HWFRS to seek specialist advice from on-site personnel already in attendance.
3. The application must identify (a) any surrounding communities, sites or infrastructure that may be impacted as a result of an incident; (b) any others who may be at risk in the event of a fire.
4. PV panels – there is adequate separation between PV panels, inverters and any other buildings or structures in order to limit fire spread and enable permanent vehicular access for firefighting.
5. Arrays – provide and ensure there is adequate separation between arrays in order to limit fire spread and allow permanent vehicular access for firefighting
6. Provide safety and isolation information on-site for use by fire crews.
7. Sufficient water should be available for firefighting. Where on-site fire hydrants are provided, these should be maintained and periodically tested by the operator.
8. Plan drawings should be provided showing the site design including safe access routes for fire appliances to enter and manoeuvre within the site (including turning circles). HWFRS expectations is that access routes will meet the typical fire and rescue access route specifications given in Section 15 of ADB Vol 2.
9. An alternative access point and approach route has been/will be provided and maintained to enable appliances to approach from an up-wind direction.

Solar farms and generating capacity

Solar farms usually require planning permission. The size of a solar farm will determine which body decides the application. For example, in England: 

• Solar farms with a generating capacity below 50 megawatts (MW) need planning permission from the Local Planning Authority (LPA).
• Solar farms with a generating capacity above 50 MW need development consent from the Secretary of State for Energy Security and Net Zero, because they are nationally significant infrastructure projects’ (NSIPs). ‘*

*Taken from Research Briefing – 20 May 2024 ‘Planning for solar farms’ – House of Commons Library

FAQs relating to BESS and Solar sites

Can HWFRS prevent a Solar Array/BESS site being approved?	Hereford & Worcester Fire & Rescue Service (HWFRS) has no authority to approve or decline planning permission for Solar Arrays or Battery Energy Storage Systems (BESS) sites. This decision, in the majority of cases, lies with the Local Authority or National Infrastructure Planning. HWFRS will endeavour to provide consultation during this process, however there is no statutory requirement to do so
The planning application doesn’t include all the necessary information. Will HWFRS object because of this?	This is often an ongoing process and not all information is available in the early stages of planning and design. As part of our response to planning applications, we will often request a wide range of additional information be provided to HWFRS as part of the planning process. Information requested and received will be able to support our observations during the planning process. It will also provide a basis for design/build stage with the aim of developing a fire management plan (FMP) and emergency response plan (ERP) suitable for the site.
BESS sites are unsafe. Whose responsibility is it to make the development safe?	The safe design and running of these facilities rests with the operator. HWFRS will aim to provide technical advice on fire safety requirements to the relevant parties and ensure compliance with fire safety legislation throughout the planning and design phase of the project. Throughout any consultations, we use the NFCC Grid-Scale Battery Energy Storage System Planning Guidance for FRS, which serves as the basis and starting point for any discussions we have with developers regarding BESS. HWFRS places safety issues associated with lithium-ion batteries, including BESS, as a high priority. We have spent significant time understanding these issues and applying that understanding to proposed BESS developments. Should a site be developed, HWFRS gathers Specific Risk Information (SSRI) by our operational response crews, where grid-scale BESS forms part of our pre planning in accordance with the arrangements required under Section 7(2)(d) of the Fire and Rescue Services Act (2004).
The site is accessed by narrow roads. How would HWFRS get there in an emergency?	HWFRS will always aim to work with developers to ensure suitable facilities for safe access to the site is provided. Access routes in our rural areas vary in width, as do the dimensions of HWFRS fire appliances. However, our highly trained and experienced appliance drivers are capable of accessing a vast majority of the road network in order to reach all types of buildings and infrastructure sites. Our crews are equipped with a range of tools and trained in various tactics, enabling them to adapt to diverse situations and incident types.  HWFRS personnel conduct risk assessments, and fire crews may also carry out familiarisation visits to ensure they can safely navigate non-standard or narrow routes. This ensures vehicles can manoeuvre through rural lanes and reach a site in an emergency as part of our Site Specific Risk Information (SSRI) Process. HWFRS conduct SSRI visits by our operational crews. Grid-scale BESS developments are included in our pre-planning in accordance with the arrangements required under Section 7(2)(d) of the Fire and Rescue Services Act (2004). This ensures we are aware of and prepared to respond to incidents that may occur.
Will there be adequate water supply for firefighting?	For any BESS development, we work with developers to ensure that, as a minimum, water supplies for boundary cooling purposes are available to deliver no less than 1,900 litres per minute for at least two hours. This can be supplied via hydrants or above-ground water tanks.  The available water supply forms one of the considerations for the tactics selected by the Incident Commander. If nearby water supplies are not deemed adequate for the preferred tactics, HWFRS has the ability to supply water to the incident ground with bulk water carriers, high-volume pumps and hose layers. Grid-scale BESS developments are included in our pre-planning in accordance with the arrangements required under Section 7(2)(d) of the Fire and Rescue Services Act (2004). This ensures we are aware of and prepared to respond to incidents that may occur.
I have concerns about the environmental impact of a fire	The NFCC guidance states “Suitable environmental protection measures should be provided. This should include systems for containing and managing water runoff.” Any potential environmental damage must be mitigated against in the event of an emergency response and be supported with a robust emergency response plan. While HWFRS will endeavour to provide consultation in line with this guidance, the onus of environmental containment lies solely with the site operator/owner.  The statutory consultee best placed to advise on this is The Environment Agency.
What is your assessment of the potential risks posed by BESS installations located in areas with narrow lanes, weight-restricted bridges, and poor access for high-capacity appliances?	HWFRS recognises the safety issues linked to lithium-ion batteries, including BESS, as a risk within our Community Risk Management Plan. We’ve dedicated considerable time to understand these challenges and applying that knowledge to proposed BESS developments. Every site is different and comes with its own risks and challenges. We conduct our own risk assessment for each one, taking into account a variety of factors, including access arrangements. If we identify that access may be an issue, then we will work with the developer to ensure suitable arrangements are put in place. Our plans will take account of those arrangements. As sites are developed, our operational response crews create Site Specific Risk Information (SSRI) documents. SSRI documents provide detailed information about unique hazards, access points, utilities, and other relevant features of a site. They are designed to equip our operational crews with immediate, practical information to support tactical planning and emergency response. SSRIs play a vital role in enhancing preparedness and ensuring the safety of both the public and our personnel. For grid-scale BESS, developing an SSRI is a key part of our proactive planning in line with Section 7(2)(d) of the Fire and Rescue Services Act 2004.
Are HWFRS appliances currently equipped to deal with large-scale lithium-ion battery fires, particularly in isolated areas with limited or no mains water supply?	Yes, HWFRS has invested in a comprehensive range of specialised equipment and developed advanced firefighting tactics specifically for lithium-ion battery fires. This includes modern techniques like compressed air foam systems. This allows us to implement effective firefighting tactics, even when water supplies are limited. When it comes to BESS incidents, our preferred response will be to conduct a ‘controlled burn’ and allow the affected BESS unit to burn out under control, whilst using our water to prevent fire spread. We do this to reduce the impact on the environment from fire water runoff, and because lithium-ion batteries are extremely difficult to extinguish. These tactics are not unique to BESS, they are part of our normal operating procedures and are proven to work well.
Would HWFRS support a policy requiring on-site firefighting water storage or suppression systems as a minimum standard for BESS approvals?	HWFRS support the requirement for on-site firefighting water (either via storage or hydrants) in line with the NFCC guidance. In terms of suppression systems, this depends on the type of suppression system and how it effects the firefighting strategy. There are some designs where a suppression system may not be necessary and, equally, occasions where one may be integral to the safety of the site. We take a risk-based approach to these systems. The NFCC guidance emphasises the importance of appropriate fire safety measures, including water supplies or fixed suppression systems, when site-specific risk assessments identify them as necessary. While it doesn’t universally mandate these, it encourages early engagement with fire and rescue services to ensure suitable strategies are in place, particularly in remote locations. Therefore, HWFRS considers such requirements to be appropriate where justified by the risk. We support their inclusion as minimum standards in policy, provided they are applied proportionately and reflect each BESS site’s unique characteristics. The NFCC currently recommends that hydrant supplies for boundary cooling should be located close to BESS containers (while ensuring safe access during a fire) and be capable of delivering at least 1,900 litres per minute for a minimum of 2 hours.
In the event of thermal runaway or explosion, what is the typical exclusion zone HWFRS recommends around a BESS facility?	In line with NFCC Guidance, the recommended minimum distance between BESS units and occupied buildings or site boundaries is 25 metres. This applies before any mitigation measures, like blast walls, are considered. This initial safety distance is a precaution to address risks from thermal runaway, fire, or explosion, including heat, toxic gas release, and projectiles. In terms of an exclusion zone around a facility, this will depend on the extent of the fire, weather conditions such as wind direction, and the level of risk to communities (e.g. higher vulnerability locations such as hospitals or care homes). HWFRS considers such risks as part of its input under planning and will highlight any concerns. As the size of an exclusion zone may vary depending on the nature of the incident, HWFRS does not define a standard exclusion zone but instead we use our specially trained hazardous materials advisors to make an assessment on a case-by-case basis.
Has HWFRS provided any formal advice to planning authorities regarding the siting of BESS in Herefordshire or Worcestershire?	As a non-statutory consultee on BESS developments, HWFRS has not issued any formal, standalone advice specific to siting BESS in Herefordshire or Worcestershire. Instead, we use the NFCC Grid-Scale Battery Energy Storage System (BESS) Guidance to inform our responses during the planning consultation process. This nationally recognised guidance provides a risk-based framework for assessing the fire safety, environmental, and operational considerations. It helps us make consistent, evidence-based decisions for all proposed sites in our area. We also meet with planners across our local authorities to ensure advice is understood.
Would HWFRS support a precautionary policy that resists siting BESS developments in remote or rural areas until faster response capabilities, water supply, and containment measures are guaranteed?	HWFRS supports a risk-based approach to siting BESS developments. We would not take a position of resistance to siting BESS in rural areas as a standard approach, as it is possible to safely site BESS in the right rural locations. Our approach is focused on the unique nature of each site, and we will provide comments under planning with those unique factors in mind. If we feel that arrangements for minimising risk and facilitating an effective response are not suitable, then we will raise such concerns and request suitable mitigations are put in place or advise that the site location is unsuitable.
What further legislative or regulatory changes would you like to see to ensure public and responder safety around these installations?	In addition to the current arrangements under planning, we would also like to see: The creation of an overarching framework and UK standard for the safe deployment and operation of BESS. This should be supported by technical standards and include clear guidance on the design and suitable locations for BESS, taking into account potential impacts of BESS on Critical National Infrastructure, any sensitive environmental receptors, local communities, and the need to ensure effective FRS preplanning and operational response in the event of a fire. BESS included in the Environmental Permitting Regulations 2016 at the earliest opportunity. FRS concerns and advice taken into account and responded to when they are engaged about fire safety risks in BESS planning applications. There is currently no statutory requirement for developers to demonstrate how they have addressed FRS comments. We would like to see this addressed.