Battery Energy Storage Systems (BESS) Position Statement

1. Issue identification

BESS capture energy in times of low demand and provide almost instantaneous support to the National Grid at times of high demand. They do this by taking energy generated by renewable sources and storing it in batteries.

BESS use lithium-ion batteries. When managed correctly these batteries can be operated safely and the likelihood of problems are low. However, when faults do occur, these batteries can pose a significant fire risk due to thermal runaway. Thermal runaway occurs when a battery generates heat faster than it can dissipate it. This can result in the rapid production of large volumes of toxic and explosive vapours and lead to explosion and fire. When lithium-ion batteries burn they produce oxygen, the chemical reaction in the battery continues to produce heat, and various fuels are also present. This means that these fires are very difficult to extinguish as water cannot access the battery cells meaning thermal propagation from cell to cell continues. Furthermore, if a fire occurs, it may reignite even in the absence of oxygen, making these fires particularly dangerous for both the public and for firefighters.

Though rare, BESS fires are challenging to extinguish and can continue to burn from several hours to several days. A fire in Liverpool, in 2020, lasted 3 days.[1] Smoke plumes from fires can also harm air quality. However, trying to extinguish fires using water can result in large volumes of contaminated fire-water runoff which can have a long-term impact on the environment. As a result, the prevailing view when it comes to firefighting tactics is to adopt a ‘controlled burn’ to minimise runoff whilst protecting the surrounding area from flame and heat impingement. This decision is often taken based on the battery chemistry and site specific plan, and taken in consultation with the Environment Agency.

The UK Battery Strategy sets out that the Faraday Institution and Bloomberg NEF models estimate that BESS could provide 10-20GW of capacity to the UK grid by 2030, and 30-35GW by 2050, representing the largest installed capacity compared to other storage technologies. In their models of total demand, the Faraday Institution and Bloomberg NEF estimate around 5-10GWh demand for grid storage by 2030.[2]

2. National Fire Chiefs Council (NFCC) position

NFCC recognises the need for BESS to support the UK Government strategic objectives of energy independence and security, whilst the country is transitioning to an environment that is less reliant on fossil fuels. However, this transition is outpacing safety standards and regulation, leading to potential increased fire safety risks as a result. This is a real concern for NFCC and fire and rescue services (FRSs).

Whilst some local FRSs are being engaged by BESS developers as part of local authority planning processes, this is inconsistent across the country and NFCC holds concerns that there are no duties on the bodies receiving FRS comments to respond, or to demonstrate how any FRS concerns have been satisfied or addressed.

Further, NFCC is concerned about the lack of research on best practice firefighting tactics in response to a BESS fire incident.

3. Recommendations

In addition to the recommendations set out in NFCC’s Fire Risks in Energy Technologies position statement, NFCC calls on the UK Government and Devolved Administrations to minimise BESS fire safety risks by:

Creating 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 pre planning and operational response in the event of a fire.
Including BESS in the Environmental Permitting Regulations 2016 at the earliest opportunity and ensuring that equivalent regulations are established for Scotland[3] and Northern Ireland[4].
Ensuring that FRS concerns and advice are taken into account and responded to when they are engaged about fire safety risks in BESS planning applications.
Investing in a programme of continuous research on best practice firefighting tactics for fire incidents involving BESS to inform FRS training and operational guidance.

4. Supporting evidence

BESS fire safety concerns

The Renewable Energy Planning Database (REPD)[5] tracks the progress of UK renewable electricity projects over 150kW. It provides, as far as possible, an accurate and comprehensive snapshot of projects, and of progress across the technology sectors, through the following stages of the planning system:

inception
planning
construction
operation
decommissioning

To enhance national grid reliability and sustainability, the number of BESS sites in the UK is increasing. According to the REPD, as of January 2025, there are more than 100 BESS in the UK, of which around half are standalone, and half co-located with renewable energy projects such as solar and wind farms. Scotland in particular has seen an increase of co-located project including wave and most notably hydrogen. Further, circa 90 BESS sites are currently under construction, 700 BESS sites have planning permission granted, and 518 BESS planning applications have been submitted.[6]

Whilst thermal events and incidents involving BESS in the UK are relatively rare, there have been failures within BESS across the world. These failures are recorded in the Electric Power Research Institute (EPRI) Failure Event Database.[7] A research briefing published by the House of Commons Library sets out concerns about fire risks and how fires can be prevented.[8]

The design of BESS facilities can help to prevent fires and ensure accessible and effective FRS operational response in the event a fire does occur. Design of BESS facilities could include spacing out battery units in BESS facilities and providing measures to decrease the likelihood of fire spread. Other safety features that can be included in the design of BESS facilities include gas and fire detectors, explosion control systems, and water supplies for emergency services in case a fire does occur. [9]

Learning from the BESS site in Liverpool that caught fire, a research paper on the incident by Electric Power Research Institute (EPRI) identified that there has been a shift in system design across the industry since 2018 to improve safety with some newer system designs using smaller, modularised cabinets with a few racks of batteries. These cabinets are accessible from the outside, so firefighters do not have to enter a container if firefighting is required. This system layout also limits damage because of thermal runaway and allows a more targeted emergency responder approach in the event of a fire.[10]

An overarching framework supported by technical standards and UK guidance on the design and safety of deployment of BESS is needed. There is limited guidance presently available, namely NFCC’s BESS guidance[11] and the Health and Safety Guidance for Grid Scale Electrical Energy Storage Systems produced by Frazer-Nash Consultancy.[12] NFCC’s guidance is also often mistakenly seen as prescriptive rather than a set of initial considerations for FRSs. Developing an overarching framework supported by technical standards and guidance in a way that considers the needs of all stakeholders is therefore necessary.

The need to address safety and environmental concerns related to BESS

The rapid deployment of BESS projects has highlighted environmental concerns including risk of fire and explosions, impacts on air quality because of the build-up of gases during a BESS fire, groundwater contamination from chemical leaks and contaminated firewater runoff and noise.[13]

BESS should be included within the Environmental Permitting Regulations 2016 at the earliest opportunity. This will help ensure that BESS facilities are designed to minimise environmental impacts, robust risk assessment and management by operators and that waste management and pollution control measures are in place.[14]

In addition, NFCC is of the view for the need for both flooding and environmental impacts to be considered, to ensure incidents that could affect the environment are taken into account at the planning stage.

The role of FRSs in protecting against BESS fire safety risks in planning applications

BESS projects support UK energy infrastructure and are approved through planning, regulated by the Health and Safety Executive, rather than through the Building Regulations consultation process (unless there are ancillary buildings on site which may be covered) and as such FRSs are not a statutory consultee, and are not seeking to become one.

Fire and Rescue Authorities remain a statutory consultee for Nationally Significant Infrastructure Projects and NFCC continues to support this decision.

In August 2023, the Department for Levelling Up, Housing and Communities (DLUHC), now referred to as the Ministry of Housing, Communities and Local Government (MHCLG) amended the Planning Practice Guidance for Renewable Energy.[15] As a result of this revision, both planners and developers are encouraged to engage with the local FRS and, as such, each FRS should encourage early dialogue regarding BESS proposals.

However, there is no statutory requirement for developers to give credence and adhere to the guidance.[16] Further, at present, there is no duty on parties receiving comments from a FRS to demonstrate how they have addressed or responded to concerns raised. As FRS comments are critical to supporting life safety, it would seem appropriate that their comments should be given higher regard, with requirements on recipients to ensure any comments are satisfactorily resolved.

FRS operational response challenges in relation to BESS fires

Another challenge for FRSs is deploying best practice firefighting tactics in response to a BESS fire incident. Whilst there are a range of tactical approaches and different equipment available, there is ‘no one size fits all’ approach to most effectively extinguish, or control, a fire caused by lithium-ion batteries.

Water is commonly used but often struggles to cool internal battery cells (as water cannot access the battery cells, especially in high energy density cabinet-based systems), and produces contaminated water runoff. Reignition risks mean water application may need to continue for days. A major issue is the lack of reliable data and evidence on the most effective firefighting methods, which hinders understanding of fire risks and safe practices.

In addition to ensuring that BESS facilities are designed with firefighter access and safety in mind, a well-funded, cross-sector research program is recommended to develop and share best practices for tackling BESS fires.

References

[1] Electric Power Research Institute (EPRI) Failure Event Database

[2] UK Battery Strategy – p. 65

[3] The Scottish Government’s Energy Consents Unit (ECU) is responsible for granting planning permission for large-scale energy projects, including battery energy storage systems (BESS). The ECU reviews applications and assesses their potential impact on the environment and communities before making a decision. We understand the regulation of BESS has been proposed for consultation in England and Wales and depending on the outcome of that consultation consideration could be given by the Scottish Government to amendments to Environmental Authorisations (Scotland) Regulations 2018 (EASR) to ensure alignment

[4] The Northern Ireland Environment Agency (NIEA) should consider how to establish an equivalent permitting regulations in Northern Ireland

[5] Renewable Energy Planning Database (REPD)

[6] Renewable Energy Planning Database: quarterly extract – GOV.UK

[7] Electric Power Research Institute (EPRI) Failure Event Database

[8] Battery energy storage systems (BESS) – House of Commons Library

[9] Key Challenges for Grid‐Scale Lithium‐Ion Battery Energy Storage – Huang – 2022 – Advanced Energy Materials – Wiley Online Library

[10] Carnegie Road Energy Storage System Failure Response, Recovery, and Rebuild Lessons Learned

[11] NFCC BESS Guidance

[12] Health and Safety Guidance for Grid Scale Electrical Energy Storage Systems

[13] House of Commons Research Briefing on Battery energy storage systems 19 April 2024

[14] On 26 August 2025 the Department for Environment, Food and Rural Affairs (DEFRA) published a consultation on including BESS within the Environmental Permitting Regulations 2016

[15] Renewable and low carbon energy – GOV.UK