Working smarter
3. Do you consider that current resourcing issues are impacting on the use of processing agreements? Please explain your view.
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Please explain your view
Properly scrutiny is paramount. The time it takes to do this properly should not be an issue.
12. How do you think a Planning Hub could be resourced?
Please explain your view
A substantial rise in planning fees.
Planning fees
13. Do you agree that planning fees should increase annually in line with inflation? Please explain your view.
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Please explain your view
Why would it be otherwise? Everything increases in line with inflation.
14. Is a calculation based on the 12 month Consumer Price Index the most appropriate mechanism? Please explain your view.
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Please explain your view
This is a standard government benchmark
16. What would be your preferred approach to how planning fees are set in the future?
Please explain your view
Major and National developments are all commercial and should bear the brunt of a rise in planning fees.
18. What other processes that support the determination of a planning application could authorities be given powers to charge at their discretion?
Please explain your view
The local authority must be given the power to charge the applicant for their use of external consultants.
20. Do you agree with the principle that authorities should have discretionary powers to increase fees for a proposal on an unallocated site within the development plan? Please explain your view.
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Please explain your view
More work will be required which may also involve the use of external consultants.
Resourcing other parts of the system
22. Do you agree with the types of appeals that should incur a fee? Please explain your view.
Please explain your view
Whilst all applications should incur a fee, EIA developments and those contrary to the Development Plan should incur a fee proportionate to the extra scrutiny required for determination of such applications.
23. Do you agree that setting the fee for applying to appeal the refusal of planning permission (to either DPEA or the planning authority) is set as a percentage of the original planning application fee? Please explain your view.
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Please explain your view
It should be proportionate.
24. If a percentage of fee approach to appeal charging was considered most appropriate, what level do you consider would be most appropriate to reflect volume of work by Directorate for Planning and Environment (DPEA) or the Local Review Body (LRB)? Please explain your view.
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10%
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20%
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30%
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40%
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Other
Please explain your view
In an effort to stop appealing being an automatic response to any refusal, charging a high percentage of the original fee may make applicants think twice about appealing.
28. Should the current threshold of 50MW for applications for electricity generation which are to be determined by authorities be altered? Please explain your view.
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Yes
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No view
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No
Please explain your view
Currently, 118MW is now the average capacity of a wind farm in the planning system. This means that Scottish Ministers will shortly be determining all wind farm (and other renwable energy) applications. As many of these developoments are on public land, that is a gross conflict of interest as the Scottish Government stands to benefit from rent and business rates from those developments. Planning officers and Councillors know their own area better than Ministers in Edinburgh and should be allowed to make more decisions. Local decision making also allows and encourages more people to get involved in the planning system. The rise in threshold must also be accompanied by an increase in the ability of communities to influence planning decision as outlined in Petition PE1864
29. Should different thresholds apply to different types of generating stations? Please explain your view.
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Yes
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No view
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No
Please explain your view
The acreage of land being used should be a consideration.
30. What would be the resource implications of increasing the threshold for the determination of applications for onshore electricity generating stations?
Please explain your view
Greater use of external cconsultants may be required for complex applications.
32. Should we introduce a new category of development for applications for hydrogen projects? If so, how should these fees be set/calculated? Please explain your view.
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Yes
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No view
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No
Please explain your view
Green hydrogen applications are complex and dangerous. They require an understanding of planning concepts, chemistry and health and safety. The definition of green hydrogen requires provision of a new dedicated renewable power source. These applications will in all probability be accompanied by other renwable generating components which will also requiring consent. Inland applications are also consume vast quantities of public water (not suitable as drought periods may be likely due to climate change) whilst coastal applications with desalination plants will consume even more electricity and produce potential adverse change to the marine environment.
33. Are there different considerations for hydrogen production when compared with proposals which are concerned only with storage and distribution? Please explain your view.
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Yes
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No view
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No
Please explain your view
See question 32. Hydrogen storage and distribution alone is more likely to be related to fossil fuel production. Health and Safety requirements will be different.
34. Do you agree that the standard £100 which applies to most prior notification and approval applications is appropriate? Please explain your view.
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Yes
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No
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Little assessment is required but the fee must increase in line with inflation.
Cumulative impact
34. Do you agree that the standard £100 which applies to most prior notification and approval applications is appropriate? Please explain your view.
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Yes
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No view
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No
Please explain your view
Little assessment required but must increase in line with inflation.
About you
Are you responding as an individual or an organisation?
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What is your organisation?
Organisation
Scotland Against Spin