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

The Scottish Regulators Strategic Code of practice places a clear onus on regulators and on statutory consultees to be proportionate and enabling. We welcome any discussion over where and why assessment requests may be disproportionate in relation to national and local planning policies. Onshore Wind Sector Deal working groups are working on this particularly in relation to EIA and with a strong focus on proportionality, so we suggest the proposed short-term working group has regard to this work to avoid duplicated effort.

Our inputs are primarily governed by statutory timescales but we acknowledge it is a useful project planning tool to allow developers and Local Authorities to set milestones and manage inputs and outputs

There are efficiencies and increased certainty to be gained by developers providing the right information of the right quality at the first point of application - some issues with delays in planning timescales can be incomplete information to proportionate assessment requests. This requires all involved to be clear at the earliest stages what is required for a particular application – clarity on the guidance to be applied and making that guidance easily accessible to all involved in the system.

Clear alignment of multiple consents under one assessment banner ie a single Environmental Statement for all rather than multiple piecemeal assessments could help streamline and align the consenting processes for some large and complex development. We support the standardisation of core Conditions between DPEA, ECU and Planning Authorities where these are applicable

NPF4 places the climate and nature emergencies at the forefront of the function of the planning system and it is therefore imperative that a) planning authorities have sufficient staffing levels to deal with applications within acceptable timelines and that b) those staff have both a basic grounding on climate adaptation and biodiversity issues if we are to move away from “business as usual”, and access to more expert sources of advice for more complex climate and biodiversity issues. Strongly support planning apprenticeship and practice approach, and for the proposals to ensure mandatory training of elected members.

see above

Strongly Agree though not necessarily the same as the building standards hub. – ideally this would be new resource available to all the LAs and able to flexibly deploy where the need was greatest. We welcome the suggestion in the consultation document that providing technical expertise and advice on biodiversity could be a key priority for a hub. There is an essential need to include biodiversity and climate adaptation skills into the planning system to facilitate the step change required and promoted by NPF4

Probably within SG or as part of the Improvmeent Service . It needs to be sufficiently close contact to the Planning Authorities to ensure it can learn from their experiences whilst not being a further drain on an authorities resources.

It is likely that a hub will need to be used as a tool to deploy resource in specific types of complex casework rather than across the whole planning system (unless it were to be used as the central source for biodiversity expertise other than the complex cases) . Work could be carried out to identify specific sectors such as renewables or aquaculture which are most likely to benefit from the approach and therefore charging sectorally seems more equitable. However this runs the risk of increasingly complex and layered charging structure , and the potential for confusion alongside any other proposed fee increases. It might be that there will be very few householder or indeed housing applications that would need input from the hub for example and therefore would not be fair to incorporate into general planning fees.

resourcing costs need to be addressed within fees.

no view

no view

A “whole pre-app service” including the input from statutory consultees could be considered in order to maximise economies of scale and minimise administrative costs as this seems to be the area where an additionally chargeable service could add value

This would add certainty to the system and manage expectations of all engaged in it.

Some development types are more clearly subject to development plan allocation than others. For example renewables proposals are not subject to allocation while housing is. The principle proposed here would therefore affect some sectors more than others. Anything that reinforces a plan led system is to be welcomed but should be applied fairly. The basic test still has to be whether the decision has been made with regard to the development plan, not just the specific allocations in it

There is a need to consider the planning service “in the round” in relation to all those involved and consider efficiencies in public sector investment to digital services. We agree that aspects such as allowing direct participation of statutory consultees in accessing applications would be useful and have been considering such issues as part of our digital innovation working on InformedDECISION. https://www.informed.com/solutions/informeddecision/ However to truly achieve efficiencies and economy of scale some consideration of the feasibility of system integration between decision makers and statutory consultees is needed. It isn’t something that individual local authorities or individual statutory consultees can solve and requires joint effort guided by Scottish Government..

As set out in the consultation document, the generation capacity of individual windfarm applications has increased significantly in recent years while the threshold has remained the same. Increasing the threshold would allow planning authorities to determine a greater proportion of applications, any appeals against refusals would be determined by DPEA reporters who have discretion to decide on the method for consideration. This has the potential to reduce the number of inquiries, reduce resource demands on consultees who currently participate in inquiries and speed up decision making. On the other hand ECU are separated from the local politics of local authority decision making

One consequence may be a greater degree of pressure on planning authorities, but for many cases planning officers are already providing consultation responses to ECU on these windfarms. However, we would also note that referring back to the idea of a planning hub, there is a clear opportunity to focus planning resource input through the hub regardless of where the threshold is set

no view

From an environmental perspective the primary difference in consideration from other storage and distribution uses is that there is a substantial water requirement for hydrogen production which is not returned to the natural hydrological system. There are few other storage and distribution uses where this is the case.

no view

no view

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Planning Hub

no comment

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Darren Hemsley

NatureScot