Investing in Planning: a consultation on resourcing Scotland’s planning system

No view.

The Ministerial Foreword is noted. Points such as: “In the coming year I will do all I can to bring people together to find solutions, so that planning can facilitate change, rather than being perceived as a barrier to investment,” and “ ……. now is the time to find creative solutions to resourcing challenges, including new ways of working in partnership with industry as well as communities,” are welcomed and appreciated. Seafood Shetland is also pleased to see this acknowledgement: “Rural and island areas need a planning system that recognises their specific and unique circumstances. We must recognise the importance of delivering housing and supporting rural business in our rural island areas, enabling us to tackle the challenges of depopulation.” Seafood Shetland is the representative body for shellfish aquaculture producers in Shetland, enjoying 100% membership in the area which accounts for 80% of Scotland’s mussel production.

No view

No view.

No view.

Seafood Shetland recalls that sharing expertise across local authorities most involved in fish farming, was favoured by industry. It is understood that councils processing fish farm applications do liaise but it is suggested that Scottish Government encourage and promote such activity, especially in respect of fish farming. More efforts to share expertise, knowledge and resource between local authorities would assist to promote consistency, processing times and costs.

See answer to question 9. A ‘Virtual Hub’ for expertise in planning for fish farming could be established very quickly if the five local authorities most involved in this activity were encouraged to enter into a more formal agreement to share resources, while being supported in doing so by the Scottish Government.

See answer to question 10. Option iii – within a host authority – would appear most logical.

No view.

Seafood Shetland holds the view that there is no valid relationship between the cost of processing planning applications and the rate of inflation, especially that of CPI. Mindful that the bulk of the processing cost is accounted for by man hours/labour, a more reasonable index would be wage inflation applicable in the public sector.

No, this is not an appropriate mechanism. See response to question 13.

Planning fees should continue to be set by Scottish Government to ensure parity, consistency and full transparency Scotland-wide.

Seafood Shetland holds the view that fee setting powers should not be devolved to planning authorities.

Seafood Shetland does not support this proposal.

Seafood Shetland does not support planning authorities being given powers to charge at their discretion but if a refund can be requested, applicants ought to be made aware of the circumstances whereby a refund may be requested.

Sites for fish farms are also not allocated in the Development Plan so should have been included in the list in Paragraph 91. If this proposal was implemented there would need to be a specific exemption for aquaculture/fish farming developments.

However, Seafood Shetland holds the view that whatever scheme is chosen, the fees should be kept as low as is possible for the shellfish sector, while being determined and set centrally and not locally.

See answer to question 22.

See answer to question 22.

See answer to question 22.

The introduction of the e-planning service, i.e. the ability to submit applications digitally online, aimed to achieve a number of objectives including: less cost, for example, through a reduction in paper processing; increasing public and consultee accessibility to planning information online; facilitating applicants and others to engage in the process; and making the entire process more efficient and, hopefully, swift.

Seafood Shetland holds the view that proposing introduction of a ‘service charge’ for submitting applications online is a retrograde and regressive step. It is far more costly for local authorities to process paper applications than those submitted electronically; consequently the proposal is considered somewhat illogical.

No view.

No view.

Seafood Shetland considers that the standard £100 is appropriate, encouraging uptake and industry participation. Any proposed increase will serve as a deterrent to current practice.

No view.

Seafood Shetland considers that the paper’s proposal to accept the change in methodology but reducing the unit fee from £200 to £100 per 0.1 Ha. would appear to be a reasonable compromise in the circumstances. However, the definitive area must only account for the area occupied by the shellfish growing equipment on the surface of the water. For the quoted example of 5 x 220m twin–headline longlines at 20m spacing with 30m end moorings, the fee should take account of the area occupied by the growing equipment only i.e. 220m (20x4) = 1.76 Ha. @ £100 per 0.1 Ha. = £1,760. It is of vital importance that the fee is not subject to varying interpretations by planning authorities as to that which constitutes the boundary of the development. Seafood Shetland seeks Scottish Government assurance that it will oversee guidelines, such that certainty for applicants can be assured and that the position encountered post April, 2022 is avoided in future.

The proposed fee of £100 per 0.1 Ha. - as measured and applied in the quoted example at Q37 - is reasonable and fair and would be far more closely aligned to the Scottish Government’s objectives when it amended the Fee Regulations in 2022, in relation to shellfish farming developments.

Seafood Shetland considers that the standard £100 is appropriate, encouraging uptake and industry participation. Any proposed increase will serve as a deterrent to current practice.

No view.

Seafood Shetland considers that the paper’s proposal to accept the change in methodology but reducing the unit fee from £200 to £100 per 0.1 Ha. would appear to be a reasonable compromise in the circumstances. However, the definitive area must only account for the area occupied by the shellfish growing equipment on the surface of the water. For the quoted example of 5 x 220m twin–headline longlines at 20m spacing with 30m end moorings, the fee should take account of the area occupied by the growing equipment only i.e. 220m (20x4) = 1.76 Ha. @ £100 per 0.1 Ha. = £1,760. It is of vital importance that the fee is not subject to varying interpretations by planning authorities as to that which constitutes the boundary of the development. Seafood Shetland seeks Scottish Government assurance that it will oversee guidelines, such that certainty for applicants can be assured and that the position encountered post April, 2022 is avoided in future.

The proposed fee of £100 per 0.1 Ha. - as measured and applied in the quoted example at Q37 - is reasonable and fair and would be far more closely aligned to the Scottish Government’s objectives when it amended the Fee Regulations in 2022, in relation to shellfish farming developments.

No view.

No view.

No view.

Ruth Henderson

Seafood Shetland, Lerwick, Shetland, ZE1 0LL.