Response 283985167

Back to Response listing

2.1 Domestic Renewables: Solar energy equipment

1. Do you agree with the proposed permitted development rights for solar panels attached to domestic properties in conservation areas?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Don't know
Please comment in support of your answer
It is important to balance the need for green energy with the aesthetic of our built environment. Giving permitted development rights beyond what we have already risks upsetting that balance. I would suggest that a Green Energy application could be formulated so that the balance is tested for each case on its merits. The application cost should be limited to covering costs only.

2. Do you agree with the proposed permitted development rights for the installation of solar panels on outbuildings ancillary to, and within the curtilage of, a dwellinghouse?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Don't know
Please comment in support of your answer
No, as above.

2.2 Domestic Renewables: Air source heat pumps

3. Do you agree with the proposed amendments to permitted development rights for air source heat pumps?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Don't know
Please comment in support of your answer
I agree in principal, however would add a requirement for equipment to emit less than agreed amount of noise at the boundary. Older heat pumps can be noisy an this will affect the amenity ogf neighbours. By limiting noise at the boundary the owner can choose a suitable location.

2.3 Domestic Renewables: Ground and water source heat pumps

4. Do you agree that classes 6D and 6E should be amended to include reference to the installation etc of pipework and associated connections required to operate a ground or water source heat pump?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Don't know
Please comment in support of your answer
similar to air source, equipment should have an agreed noise level at the boundary.

2.4 Domestic Renewables: Free-standing wind turbines

5. Do you agree with the proposed amendments to permitted development rights for free-standing domestic wind turbines?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Don't know
Please comment in support of your answer
All seems reasonable.

6. Do you agree with the current list of designated areas where the permitted development rights do not apply, noting that the list does not currently include national parks or National Scenic Areas?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Don't know
Please comment in support of your answer
I think it unfair to exclude those living in these areas as tests exist through planning notification. Allow all to be included, but reject those what may cause an issue.

2.5 Domestic Renewables: Wind turbines attached to a dwelling

7. Do you agree with the proposed new permitted development rights for wall or roof-mounted wind turbines attached to a dwellinghouse?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Don't know
Please comment in support of your answer
In principal its fine, but again noise at the boundary should be limited.

2.6 Domestic Renewables: Flues for certain heating systems

8. Do you have any comments on the potential removal of permitted development rights for flues for wood burning stoves (including wood burners and log burners), biomass boilers and biomass heating systems?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Don't know
Please comment in support of your answer
Biomass is not an efficient heating type when you look at whole life cycle carbon data. We should be phasing this out as it is just another fad.

9. Noting that current permitted development rights (PDR) cover the installation, alteration or replacement of flues, should any removal of these PDR be limited to installation of new flues, or also prevent existing flues being altered or replaced under PDR?

Please comment
Yes.

3.1 Non-Domestic Renewables: Solar panels

10. Do you agree with the proposed amendments to class 6J permitted development rights for solar panels attached to non-domestic buildings?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Don't know
Please comment in support of your answer
Allow commercial buildings to get as much solar as they can. What are the CAA and airports views on the distances, can a non-reflective finish be obtained if reflection is the issue?

11. Do you have any comments on the potential to amend the current restrictions that apply to solar panels on non-domestic properties (class 6J) and solar canopies in parking areas (class 9M) within 3km of airports and technical sites associated with civilian and military air traffic services?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Please comment in support of your answer
Car park solar is the simplest and safest type of install and is used widely in the EU. Also allows us Scots to get rain cover when parking,

12. Do you agree with the proposed new permitted development rights for solar panels within the curtilage of non-domestic buildings?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Don't know
Please comment in support of your answer
Subject to the same tests being applied to buildings which neighbour domestic households as for domestic installations.

3.2 Non-Domestic Renewables: Solar canopies in parking areas

13. Do you agree with the proposal to extend the Class 9M permitted development rights to allow these to apply to solar canopies generally, rather than only those for which the primary use is charging of electric vehicle?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Don't know
Please comment in support of your answer
eassist type of install, no reason to not allow this.

14. Do you agree that any extension of Class 9M permitted development rights to be for the purposes of producing electric power generally, should not have a maximum power generation capacity?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Don't know
Please comment in support of your answer
Power output will be limited by our ageing national grid......

3.3 Non-Domestic Renewables: Air source heat pumps

15. Do you agree with the proposed permitted development right for air source heat pumps on non-domestic buildings?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Don't know
Please comment in support of your answer
Yes, subject to noise issues for building users and at the boundary being applied. As we strive to use natural ventilation an open window will be an issue if a pump is too close.

3.4 Non-Domestic Renewables: Ground source and water source heat pumps

16. Do you agree with our proposed amendments to class 6I permitted development rights for ground and water source heat pumps on non-domestic buildings?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Don't know
Please comment in support of your answer
Seems reasonable. Again noise from equipment to be limited.

4. Thermal Efficiency: Replacement windows

17. Do you agree with the proposed permitted development rights for replacement windows of domestic buildings located in conservation areas?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Don't know
Please comment in support of your answer
Would the replacement be subject to a Building Warrant and therefore to adhere to the technical standards for safety and energy efficiency?

18. Do you have any comments on the conditions that we propose the permitted development rights for replacement windows would be subject to?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Please comment in support of your answer
As above subject to technical handbook and relevant BS's.

19. Do you agree with the proposal to align non-domestic buildings with domestic buildings, as regards permitted development rights for replacement windows? Are there any types of non-domestic building that should be excluded?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Don't know
Please comment in support of your answer
Keep it simple.

5.1 Electricity Undertakings: Overview

20. Do you agree that class 40 permitted development rights should be amended to clarify that they can be applied by statutory undertakers for the purposes of ‘smart meter communications’ and the ‘distribution’ and ‘interconnection’ of electricity as well as its ‘generation’, ‘transmission’ and ‘supply’?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Don't know
Please comment in support of your answer
Who will regulate this. It seems to be the case that the grid and electric companies make things up as they go along, so some king of reporting and certification must ne included.

5.4 Electricity Undertakings: Substation infrastructure

21. Do you agree with the proposed amendments to the provisions of class 40 permitted development rights which relate to new or replacement substations?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Don't know
Please comment in support of your answer
Limit noise output at the building envelope.

5.5 Electricity Undertakings: Communications Lines

22. Do you agree with the proposal to allow the replacement of communications lines in National Scenic Areas and Sites of Special Scientific Interest under class 40 permitted development rights provided that the design, height or position of the replacement line matches the original?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Don't know
Please comment in support of your answer
I would propose that any replacement or new lines be installed underground. The technology exists and the cost is minimal. I would also consider banning all new where a suitable secure internet connection can be used negating the need for any infrastructure at all for communications purposes.

23. Do you have any thoughts on the potential to provide for the installation or replacement of communications lines of a greater length than 1,000m under class 40? If so, do you have a view on an appropriate alternative threshold?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Please comment in support of your answer
All new to be via secure internet with no built infrastructure allowed.

5.6 Electricity Undertakings: Site Investigation Works

24. Do you agree with the proposal to extend the range of site investigation works that can be carried out under class 40?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Don't know
Please comment in support of your answer
All works to be subject to a desktop archeological study scrutinised by Archeology Scotland and where appropriate the works to be attended by an Archeologist. Other relevant sudies as required for the location such as habitat for badgers etc.

All works require to be fully reinstated.

25. Do you consider that there are any designated areas where permitted development rights for certain site investigation works should be restricted? Should there be any limitations on the scale of certain intrusive site investigation works permitted, for example, the size of trial pits?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Don't know
Please comment
If the work is required then carry it out, but safely and using the studies noted in the answer to 24. Deep excavations require security.

5.7 Electricity Undertakings: Fences, gates, walls and other means of enclosures

26. Do you agree with the proposed introduction of specific permitted development rights enabling electricity undertakers to erect, construct, maintain or improve gates, fences, walls or other means of enclosure up to 3m in height?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Don't know
Please comment in support of your answer
Seems sensible.

5.8 Electricity Undertakings: Development of Operational Land

27. Do you agree with the proposed removal of prior approval requirements that apply to certain works under class 40 permitted development rights?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Don't know
Please comment in support of your answer
Planning should always be consulted and have a say in the aesthetic.

28. Please provide any further views you may have on the proposals in Chapter 5 on the permitted development rights associated with electricity undertakings.

Please comment
Permitted development should be limited to small scale standard building types which have been approved. There should never be the opportunity to sidestep the planning system.

6.1 Reverse vending machines

29. Do you agree with the proposed amendments to permitted development rights for reverse vending machines?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Don't know
Please comment in support of your answer
Local authorities should be charged with providing suitable locations within their areas be it town, village or city. There are so many vacant shops that they could easily be combined into RVM areas where yo could return all manner of recyclables at once. Having to travel at least 400m to dispose of different recycling is plain daft, especially for those with mobility issues.

6.2 Temporary use of land: Shooting ranges

30. Do you have any comments on the potential exclusion of the use of land as a target shooting range from class 15 PDR (permitted development right)? If such a change were taken forward, do you have views on the potential justification for exempting the activities discussed in paragraphs 6.2.4 and 6.2.5?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Don't know
Please comment
"6.2.2 It has been brought to our attention that these provisions might be used to establish temporary firing ranges comprising the provision of fixed targets associated with the use of firearms."

The above quotation shows the lack of understanding. The the whole point of the exemption is to allow the use of the land for shooting if the owner sees fit. Shooting is substantially less dangerous than many sports and seems to be targeted by name rather than any fact based argument. Noise is a statutory nuisance controlled by current legislation.

There is no justification for removing target shooting from the permitted use based on it being a fixed target, noise is noise is noise, however 28 days a year is no great issue when your neighbor may be learning to play the drums day in day out.....

If anything the PDR could be altered to have the 28 days limited to a max of two days in any seven and say before 8am till max 8pm, or sunset, whichever is earliest. Society should be encouraging lawful pursuits, not trying to wipe them out.

Adding this to the other consultations on energy seems to be a bit strange. It should be a stand alone subject....

7. Assessment of Impacts

31. What are your views on the findings of the Update to the 2019 Sustainability Appraisal Report at Annex A?

Please comment
Reverse vending and firing ranges should not have been added, they should have been separated from the main emphasis of the Report. Things will only get clouded by having these included.

32. Do you have any comments on the partial and draft impact assessments undertaken for Phase 3?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Please comment
There is no mention of the impact that removal of the PDR for shooting ranges would have on those who participate or those businesses which may be associated. This is a disgrace. The amendment should be removed an the Scottish Government should start a proper, above board, consultation to firstly establish if these is an issue (it appears that there is not given the wording used) and then address any remedies which may be available. Leaving out any assessment of impact on shooting is shoddy work to say the least.

33. Do you have any suggestions for additional sources of information on the potential impacts of the proposals that could help inform our final assessments?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Please comment
SCTA
SSRA
SRA
Scottish Shooting

Try talking to them about noise and, safety and THEN consult with the wider community from a position of knowledge rather than ignorance.

About you

What is your name?

Name
Iain Dawson

Are you responding as an individual or an organisation?

Please select one item
(Required)
Radio button: Ticked Individual
Radio button: Unticked Organisation