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Increased Fees for Major Developments
Local Authorities
Falkirk Council: The proposal to charge higher fees for major developments to more accurately reflect the cost of determining them is welcomed.
Glasgow City Council: The SE's proposals for processing major applications and increasing the fees for processing them would introduce a two-tier system of assessing applications. This may requires some local authorities to re-organise the operation and staffing of their development management function.
Non Departmental Public Bodies
Scottish Water: We have reservations about linking the fee to the real cost of the application solely relating to our tag as 'bad neighbours'. We would not want to be unduly penalised on the one hand whilst being held up as a pivotal provider of essential services on another. We hope that in practice common sense would enable the planning system to support investment in the wastewater infrastructure in the public interest, but are concerned that the likely prevalence of applications considered as "bad neighbour" could conflict with this strategic objective. We would seek further clarity in this area to understand the potential impact this could have on Scottish Water's investment programme.
Development Industry
Manor Kingdom Group: The proposed requirement to increase fees is mentioned throughout the White Paper to compensate for the additional workload for negotiating and processing major developments. Manor Kingdom would welcome further clarification as to the likely fee level increases regrettably we are not confident that increased fees will result in a better service. Manor Kingdom supports Homes for Scotland's belief that consideration should also be given to a scheme of refunds of planning fees where planning authorities fail to perform within set and agreed timetables.
Muir Group: The proposal to increase fees requires clarification as to the likely level of increase and it is important that any increase provides a better service.
Other Businesses
Association of Electricity Producers: The increase in application fees must be accompanied by an increase in efficiency and quality of service within the planning authorities. Developers are not necessarily opposed to the increase in fees, provided they bring demonstrable improvements to the process. The methodologies behind the increase in fees should be transparent.
British Aggregates Association: We do not welcome the suggestion that the level of fees should be raised "for major applications to reflect the costs of processing them more closely". No doubt this would apply to all mineral planning applications. Aggregate quarries have recently been made subject to the aggregate levy which according to HM Treasury is an environmental tax. It would seem completely unfair to increase planning fees across the board for mineral applications when not all mineral operations are subject to the aggregate levy. It would make more sense if proceeds of the aggregate levy, or the aggregate levy sustainability fund, were ploughed back into improving minerals planning. Simply increasing fees on top of the aggregate levy would seem like a double whammy to small rural businesses.
British Energy: With regard to application fees being increased to reflect higher costs this appears a reasonable proposal but we would wish to see further details before making comment.
Confederation of UK Coal Producers: CoalPro understands the argument in favour of higher fees for major applications. However, any increase in fees must be moderate, proportionate and genuinely related to costs. A well prepared major application is not necessarily more time consuming to deal with than
lesser ones. When proposals are brought forward, they should be the subject of a separate consultation
SITA ( UK) Ltd: The Company notes the proposal to link the extent of a planning application fee more closely to the real cost of processing the application. It feels that hypothecation should be introduced with regard to the increased fees that would result from such a regime to ensure that monies generated are used to improve resources within determining departments, and not committed to unrelated works.
Tarmac Ltd: The scale of fees would obviously be a concern particularly in light of the substantial costs already associated with EIA.
Tesco Stores Ltd: Linking the application fee to the real cost of processing major applications is acceptable in principle but applicants would need to see increased investment in planning services, and the quality of development control improve.
WBB Minerals: Modernising the system should not be used as a mechanism for increasing the planning fees without proper justification and evidence to support any increase. Where is the research which demonstrates that current fees do not already reflect the true cost? Who is to determine the fees? Are they to be set locally or nationally?
Professional Organisations
Institute of Civil Engineers Scotland: The revised level of fees should reflect the amount of additional work that the developer may have had to undertake already as part of the processing agreement
SSDP: The Society would greatly welcome a means of "ring fencing" fee income so that planning authorities can use the income from planning applications to resource its Development Control function.
Voluntary Organisations
Scottish Renewables Forum: On fees, if they are likely to rise how will the Scottish Executive ensure value? What benchmarks will be used and what regulations will there be in governing the use of that money? The effectiveness of the proposed refund of half the application fee where the parties are unable to reach a processing agreement within the 28-day period is questionable. In a lot of cases, because of the complexity of renewable applications, applications will go over the 4-month period. This effectively forces the developer to choose between going for the fee refund or working constructively with the local authority to resolve outstanding issues. Most developers will probably avoid the appeal route and the potential additional very significant cost of a (almost inevitable) public inquiry. The financial benefit of recouping half a planning fee would be insignificant in comparison to these costs. If fee refunds are to be used as a sanction, unreasonable planning authorities may simply not negotiate a processing agreement in the first place as this is the "cheap" option ( i.e. half price).
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