Scottish Government

The Royal Town Planning Institute in Scotland

Email to ian.mitchell3@scotland.gsi.gov.uk

6 March 2006

Dear Ian

Comments on draft SPP6 from RTPI Scotland

My apologies for the delay in sending these comments to you. I hope that they may still be of assistance in helping you take forward your work on SPP6.

Paragraph 1 might be expanded to give a few more details of the stated policy for example noting the aims of ' taking full advantage of renewable potential at affordable cost to consumers whilst ensuring safeguarding of the natural heritage' and the key objectives of reducing carbon emissions, diversifying the energy mix; enhancing manufacturing capacity; increasing public awareness and support etc thus placing the policy at the heart of the Executive's work on sustainable development and climate change and giving a wider picture than that presented by a single target.

The lifespan of the SPP is given as 5 years. This is a short timescale and inevitably the main focus will be on current technologies and practice. However, five years does take the timespan beyond 2010 and therefore it will be important for the SPP to include some forward looking policy proposals beyond that date. Paragraph 4 might be adjusted to distinguish between achieving 2010 and 2020 targets and to better reflect the SE strategy document. ' Securing a Renewable Future: Scotland's Renewable Energy' (page 6) which notes that whilst established technologies of onshore wind and hydro will play a major part in achieving the 2010 target, beyond that ' the key to Scotland's renewable future to the full is likely to lie in our ability to promote the development of new technologies such as offshore wind, biomass, wave and tidal power'.

It might be helpful to expand on the related policy context for offshore development of marine renewables (wave tidal and offshore wind) at this point. Whilst it is accepted that these developments will not be covered by the SPP, local planning authorities will need to address onshore aspects of such developments and it will be important to encourage them to have regard to developments in waters adjacent to their area. It would be helpful if related guidance on marine renewables could be produced at some point so that some indication might be given of the output that might be expected to be achieved from offshore renewables based on where the electricity will come ashore. We consider that the SPP should reflect the National Planning Framework, which identified marine energy potential areas, and link to proposed wider marine spatial planning policies.

Paragraph 5 mentions actions to increase renewable heat capacity and on-site renewable energy developments. This is then taken up in paragraph 32. It might be helpful to have a separate heading of 'on-site developments' or to combine this material with that under the heading of 'Other Issues' with slightly more discussion of the issues covered by PAN 45. This section should encourage positively expressed policies in development documents on the use of on-site renewable energy such as solar panels, biomass heating, photovoltaic cells, and combined heat and power schemes in new residential, commercial or industrial developments Additional guidance may be required in the form of an updated PAN in the near future given the review of the GPDO and the proposed Private Bill on micro-renewables. In addition, the RTPI considers that policies will be needed to address the urban design consequences of on-site technologies.

General policy principles might also note the important linkages with other policy areas in particular housing, transport and energy conservation.

The RTPI agrees with a locational and criteria based approach to site selection as set out in the draft and considers it will be important to encourage local authorities to consult with neighbouring authorities particularly in view of the need to consider cumulative impacts. We agree with the formulation of indicative and reviewable targets, taking into account the full range of options, with reference to offshore developments; and with reference to grid planning considerations.

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