Review of permitted development rights - phase 2 consultation

To meet climate change reduction targets a significant change is required to the electrification of transport, cars in particular, and the supporting infrastructure will need to be deployed efficiently and quickly to react. The works envisaged as PD are relatively minor and unlikely to have any significant amenity impacts and will free up local authority planning departments, which are already under resourced, to deal with larger more complex applications, particularly renewable and sustainable developments which will also be required if Scotland is to achieve its Net Zero carbon emissions target. As mentioned in the report deployment of this infrastructure will be largely by commercial developers and for the required investment to take place, some incentives to deployment will be required. A simplified planning process to aid deployment would be such an incentive.

As above this is unlikely to have any great adverse amenity or visual impact and would be a greater encouragement to commercial investment in the infrastructure if it could be more clearly marketed via nameplates.

Answer would be based on same reasons as outlined in response to Q1 for wall mounted units.

As per answer to Q2, but probably more important in respect of free standing units for marketing and investment purposes.

Concur with the reasons outlined in the consultation that would not be a significant amenity impact.

Agree with views outlined in consultation in terms of limited amenity impacts, but adding to the sustainability of the development and reducing the demand on an already overloaded electricity distribution network in many locations.

Concur with reason outlined in consultation and will allow contingency to the development of the infrastructure.

It would seem sensible to regain more control in more sensitive areas, but these are so wide ranging that this will have a significant impact on deployment of the infrastructure in some areas such as the Highlands whereby there are numerous designations and there will be less of a commercial demand. To encourage commercial deployment some incentive might be required, such as the early days of radio base station deployment for mobile phones in the Highlands & Islands between Vodafone & O2. It could be possible to introduce a prior approval process with a default approval and deemed consent for such development to allow local planning authorities to have the control in particular locations where such PDR might have a negative impact, but where it would not it would be less of a drain on their resources and a quicker process for developers who would not required to await a lengthy determination.

Seems a sensible approach, to allow development but limit height to that which is unlikely to have a detrimental impact on amenity.

Yes would safeguard residential amenity and public safety.

Any such clarification under Class 30 would be helpful, as at present there is ambiguity.

Yes, similarly to telecommunications this will be a fast moving evolving technology and market, so flexibility to adapt will be crucial so not to delay the required private investment in the deployment of the infrastructure.

As above this will be critical to the deployment of the infrastructure, which will be reactive and not proactive if largely reliant on commercial developers and operators without any Government subsidy. Commercial developers will not invest in this unless there is a commercial return and we are not at the point where there are sufficient EV's on the roads to make large scale investment in the infrastructure viable yet. When that time is reached it is imperative that developers have the required rights to implement PDR to deploy their infrastructure. As outlined other forms of regulation and statute exist to ensure amenity and safety implications are safeguarded and the planning system should not be used to duplicate such other controls. As further outlined however careful consideration of how this is structured within the PDR is required.

As outlined above if current regulation and statue do not cover all aspects required, further regulation might be required. However local authorities and other agencies are already overloaded and under resourced so any further regulatory burden has to be considered on these already stretched resources and any delays to deployment that might result.

In certain areas conflict may arise between residents parking via permit schemes and EV charging locations, so some form of licencing/interaction might be required. Other considerations will need to be in relation to safety of all road users and pedestrians and in particular street clutter and impacts on persons with disabilities and the visual impact of the wider streetscene given all other competing street furniture and advertising in some areas.

Electricity and other statutory undertakers and service providers will need to have at least their current level of access and PDR, but in particular mains power will be required to EV units, so further PDR's to DNO's might be a consideration. Currently powers exist through the Roads Act & New Roads & Streetworks Act and Planning Acts that are sometimes confusing so a simplification of the regulatory process, or perhaps production of clear guidance on the interactions should be considered.

This will make the conversion at pace much easier and they will have a similar function in planning terms so limiting physical change and using PDR is a very sensible approach.

None. Those outlined in the consultation seem sensible.

N/A This section has little relevance to SSE Renewables and as such we would not wish to comment.

Particularly in relation to the deployment offshore renewable development across the UK, Scottish ports should not disadvantaged by not having the same PDR's as English ports.

The key benefit is that PDR's are available more widely to the agents of development and not just those define as statutory undertakers by the relevant legislation. It also clarifies PDR's are available for services and facilities provided they relate to an operational capacity, but excludes ancillary types services unless wholly within port curtilage. It also provides for prior approval procedure but has exceptions for limited scales of buildings and emergency type PDR's for efficient running of the port.

It should be brought into alignment with the English PDR for the reasons outlined above that give greater flexibility for ports to operate and accommodate an ever increasing need to support the renewables industry, particularly in respect of offshore wind development and to support the supply chain for the wider renewables industry. Given the ambitious targets set for both onshore and offshore wind by 2030 greater flexibility for expanding development at ports will be critical.

Masterplan Consent Areas in theory would be useful, but this will rely on development being included within the Masterplan and the subordinate legislation introducing these is yet to be evoked. They will rely on Masterplans being produced and will need to follow a process and such masterplans may not be developed quickly enough and at all port locations required for the expansion of the renewables industry to meet the targets. They will not therefore provide the same flexibility that a relaxation of current PDR's would and as such should not be solely relied upon. If Scottish ports, particularly those close to the border with England are not to lose out to English ports in respect of the proposed offshore projects currently in development and those in the future the PDR's need to be aligned.

No views