RTPI Scotland's Response to 'Draft Energy Strategy and Just Transition Plan' Consultation

Chapter 1 - Introduction and vision

1) What are your views on the vision set out for 2030 and 2045? Are there any changes you think should be made?

Please give us your views:

The Royal Town Planning Institute (RTPI) is the professional body, learned institute and key stakeholder representing the planning system and planning professionals in the UK and Ireland. The purpose of planning is to ensure that the development of land in our cities, towns and rurally is undertaken in the long-term public interest – an approach that, in light of the climate and nature emergency, is synonymous with the goals of sustainable development. RTPI Scotland supports the overall vision set out by the 2030 goals and 2045 vision presented above. However, we note that National Planning Framework 4 (NPF4) is only referenced four times within the document, with no comprehensive inclusion or discussion of its importance to delivering this
mid to long-term vision. NPF4 sets out Scotland’s spatial strategy to delivering the ambitious decarbonisation of the Scottish economy towards a greater renewables mix, whilst balancing the need to improve climate resilience, foster biodiversity regeneration and move towards places for wellbeing across the country.

NPF4’s specific spatial principles aim to foster this:

- Just Transition
- Conserving and recycling assets
- Local Living
- Compact Urban Growth
- Rebalanced Development
- Rural Revitalisation

NPF4’s national developments reflect these in its range of projects.

There are strong linkages between NPF4, the Draft Energy Strategy and Just Transition plan and the Infrastructure Investment Plan (IIP; which is only mentioned twice within this draft). The Draft Energy Strategy and Just Transition Plan’s ambition for additional renewable energy through on- and offshore projects across solar, hydro, wind and marine and energy storage will require expression through these six spatial principles, particularly in the rural context. Additionally, the 2030 vision for a 20% reduction in car kilometres and phasing out of traditional petrol and diesel vehicles will require a move to greater local living, investment in decarbonised public and active travel options and a focus on compact growth in urban centres to move facilitate more 20-minute neighbourhoods. RTPI Scotland policy briefing paper on 20-minute neighbourhoods [1] provides a discussion on the benefits and opportunities of embedding this approach to local living and how it relates more broadly.

 

Outside of the Scottish context, the Institute wishes to highlight the relevance of The Republic of Ireland’s National Development Plan 2021-30 [2] and National Planning Framework [3] which sit within the country’s Project Ireland 2040 [4]. These provide a coherently aligned structure in providing vision, spatial strategy, and a public capital investment plan for delivery across an analogous range of national developments and outcomes to Scotland’s net-zero 2045 vision. Thus, RTPI Scotland believes the draft should lay out the strategic and delivery-focused connections between policies across this draft, NPF4 and the IIP to give a greater coherence of spatial strategy and investment needed to achieve the draft’s vision.

(1) https://www.rtpi.org.uk/research/2021/march/20-minute-neighbourhoods/#_ftn26
(2) https://www.gov.ie/en/publication/774e2-national-development-plan-2021-2030/
(3) https://www.gov.ie/pdf/?file=https://assets.gov.ie/246231/39baaa8c-48dc-4f24-83bd-84bbcf8ff328.pdf#page=null
(4) https://www.gov.ie/en/campaigns/09022006-project-ireland-2040/

Chapter 2 - Preparing for a just energy transition

 

2) What more can be done to deliver benefits from the transition to net zero for households and businesses across Scotland?

Please give us your views:

As described in our response to Question 1, a delivery-focused approach to the transition to net zero should be undertaken that embeds the 20-minute neighbourhood concept and a place-based approach.

RTPI Scotland’s aforementioned policy briefing paper discusses place-based partnerships which will be required to successfully operationalise 20-minute neighbourhoods. This will require the collaborative work across a wide range of stakeholders in the public sector, private sector, third sector and in the communities themselves. Consideration of 20-minute neighbourhoods needs applied to a range of public-sector decision-making areas such as planning, Community Planning, asset management, street maintenance, investment, health and education service provision. RTPI Scotland believes that there is a clear opportunity to deliver the spatial benefits of a just transition and decarbonised energy networks through and alongside 20-minute neighbourhoods using new place-based ways of working embedded in the NPF4, and through the operationalisation of the Place Principle and through new approaches to community engagement through Local Place Plans, a new provision set out in the Planning (Scotland) Act 2019.

A place-based approach is about considering all aspects of a place when considering an intervention. The Place Standard tool provides a simple framework to structure conversations about place. This includes both physical and social elements of place structured around 14 themes. RTPI Scotland have called on the NPF4 to embed “Place and Wellbeing” themes from the Place Standard Tool to provide an evidenced, consistent framework for Scotland [1]. As a national level “Place and Wellbeing” policy requirement they provide a simple, understandable remit for how place impacts behaviour change to improve health and wellbeing, reduce carbon emissions, and improve biodiversity. The themes are valuable for their contribution to all aspects of place, especially interventions underpinning 20-minute neighbourhoods. They are simple, already well understood and all sectors with an interest in place are already using them. RTPI’s 2021 research paper ‘Place-Based Approaches to Climate Change’ [2] gives evidence of how this partnerships approach is developing in its potential to address climate resilience alongside the social and economic transitions needed to reach net-zero and develop coordinated strategies that maximize co-benefits and provide joined up, long term visions for the transition which maximise environmental and social benefits.

(1) RTPI Scotland (2020) 10 Big Ideas for National Planning Framework 4 - RTPI Scotland response to Scottish Government’s call for ideas. May. Available
here: https://bit.ly/3lqSD3S
(2) https://www.rtpi.org.uk/media/8105/2place-based-approaches-to-climate-change_final.pdf

3) How can we ensure our approach to supporting community energy is inclusive and that the benefits flow to communities across Scotland?

Please give us your views:

RTPI Scotland believes planners hold a fundamental role in engaging communities on the future development of their areas. This is especially important in preparing Local Development Plans where communities can look at and discuss the types of developments deemed to be acceptable, where they should be, and the infrastructure needed to support them.

However, the Institute would like to stress that successfully undertaking proactive, collaborative and meaningful community engagement is a highly resource intensive statutory function and therefore careful consideration is needed as to how planning authorities can be effectively resourced to do so. RTPI Scotland believe there is a clear opportunity for enhancing public engagement through emerging Local Place Plans (LPPs). LPPs will help planners to communicate strategic overarching considerations and allow communities to plan priorities for net zero interventions, conveying detailed local understanding. Planners can in turn bring the vital links to other departments, agendas and organisations that help to navigate the system and turn community aspirations into reality. For LPPs to succeed there needs to be funding set aside to support communities to develop them. There is currently no designated funding in place to support them to do this, although their success may well depend on this. It has been estimated that each LPP could cost between £10,000 - £30,000 each [1].

Alongside LPPs, the CARES (Community and Renewable Energy Scheme) from the Scottish Government provide funding and knowledge to assist local communities through the initial process of shared ownership schemes but have been identified to not go far enough in providing support. Communities rely on local volunteers’ time and limited funding to undertake such schemes and the contractual discussions with developing partners, providing a barrier based on local resourcing rather than infrastructure. RTPI Scotland defers to Scottish Renewables and Community Energy Scotland for further discussion regarding CARES. Therefore, RTPI Scotland believes that providing a greater and more comprehensive resource to communities for the development of LPPs and facilitating CARES would be a beneficial step in ensuring that community energy is fostered in an inclusive and locally beneficial manner.

(1) RTPI Scotland (2019) Financial Implications of Implementing the Planning (Scotland) Act 2019. August. Available here: https://bit.ly/3uRbtFT

 

4) What barriers, if any, do you/your organisation experience in accessing finance to deliver net zero compatible investments?

Please give us your views:

No comment.

 

5) What barriers, if any, can you foresee that would prevent you/your business/organisation from making the changes set out in this Strategy?

Please give us your views:

No comment.

6) Where do you see the greatest market and supply chain opportunities from the energy transition, both domestically and on an international scale, and how can the Scottish Government best support these?

Please give us your views:

No comment.

 

7) What more can be done to support the development of sustainable, high quality and local job opportunities across the breadth of Scotland as part of the energy transition?

Please give us your views:

Scotland’s Just Transition to a net-zero economy is a crucial to ensure that “we [d]on’t let history repeat itself” in regard to the long-lasting social, economic and health & well-being impacts experienced during the country’s deindustrialisation as mentioned in the Just Transition Commission report [1] as a prerogative to “maximises the economic and social opportunities, while managing the risks”. RTPI Scotland that this headline aim strongly aligns to the long-term public interest, and supports the development of sustainable, high quality and local job opportunities throughout Scotland to facilitate an energy transition and future network development.

RTPI Scotland understands that a key component to facilitating this is the Climate Emergency Skills Action Plan (CESAP), which focusses on construction and energy sectors. However, it is clear from our perspective that a well-resourced, staffed, and upskilled planning sector that is agile and able to fulfil the planning and consenting needs of future energy infrastructure, whilst balancing sustainable development for other needs within the NPF4 is crucial.

Whilst planning doesn’t directly constitute part of the energy sector, it is in clear interface in providing the consenting regime for infrastructure across the country, and the NPF4 focusses on the national spatial priorities, national developments, and policy 11 for energy which direct development key to achieving net-zero by 2045.

RTPI Scotland maintains that to successfully deliver the sustainable, equitable and decarbonised future vision for Scotland, the planning system needs the appropriate provisions, including up to date and clear policy; suitable resources; and fit for purpose consenting procedures. This is especially important when considering the diminished resourcing context of planning authorities with recent research from RTPI Scotland [2] showing that:

• Nearly a third of planning department staff have been cut since 2009
• Planning authorities’ budgets have diminished in real terms by 42% since 2009
• In 2020 local authorities only spent 0.38% of their total net revenue budgets
• Planning application fees only cover 66% of their processing costs
• There are 91 new and unfunded duties in the Planning (Scotland) Act, which could cost between £12.1m and £59.1m over 10 years

Research has also showed that planning has demographic and succession challenges with a limited staffing pipeline. Only around 8% of staff in planning authorities are under 30 and there is an estimated replacement demand of between 680 - 730 planners over the next 15 years. Combined with many experienced, senior staff leaving the profession over recent years, there is risk that a staffing and skills shortage may grow over time if not addressed adequately. Given this RTPI Scotland wishes to stress the need to invest in initiatives to promote planning as a career and widen access to the profession through establishing apprenticeships and financial assistance to students particularly from under-represented backgrounds. This connects with RTPI Scotland’s business case calling for the introduction of planning apprenticeships in Scotland to address the declining staffing pipeline into the planning sector, and particularly local planning authorities, which creates a medium to long-term risk to the efficacy of Scotland’s planning and consenting regime for all energy projects.

(1) Scottish Government; Just Transition Commission (2021) Just Transition: A Fairer, Greener Scotland. Available here:
https://www.gov.scot/binaries/content/documents/govscot/publications/strategy-plan/2021/09/transition-fairer-greener-scotland/documents/transition-fairer-greener-scotland/transition-fairer-greener-scotland/govscot:document/transition-fairer-greener-scotland.pdf
(2) RTPI Scotland (2021) Resourcing the Planning Service: Key Trends and Findings 2021. June. Available here: https://bit.ly/3s5h4Yc

 

 

8) What further advice or support is required to help individuals of all ages and, in particular, individuals who are currently under-represented in the industry enter into or progress in green energy jobs?

Please give us your views:

No comment.

 

Chapter 3 - Energy supply - Scaling up renewable energy

9) Should the Scottish Government set an increased ambition for offshore wind deployment in Scotland by 2030? If so, what level should the ambition be set at? Please explain your views.

Please give us your views:

RTPI Scotland cannot comment on the level of offshore wind deployment ambition, but the institute believes that it is an integral part of Scotland’s energy mix and the decarbonisation of energy production to reach the target of 75% emissions reduction by 2030 as set out in Scotland’s 2018-2032 Climate Change Plan. As part of the developing ambition for off-shore wind deployment, we believe that clear strategy regarding the on-shore infrastructure required to receive and transmit this energy source is needed. RTPI Scotland is currently working on a New Ways of Working paper that will cover the upskilling of Scotland’s planning sector to facilitate an effective consenting regime for renewable energy infrastructure.

 

10) Should the Scottish Government set an ambition for offshore wind deployment in Scotland by 2045? If so, what level should the ambition be set at?

Please explain your views:

We refer to our answer to Question 9.

 

11) Should the Scottish Government set an ambition for marine energy and, if so, what would be an appropriate ambition?

Please explain your views:

As discussed in our answer to Question 9, RTPI Scotland cannot comment on the ambitions for deployment of marine energy, but the institute believes that it is a part of Scotland’s energy mix for the future to achieve a 75% reduction in emissions by 2030, and net-zero by 2045. Furthermore, discussion of the onshore planning and consenting implications for energy infrastructure related to marine energy expansion is notable, and RTPI Scotland will follow the implications of this on the planning sector.

 

12) What should be the priority actions for the Scottish Government and its agencies to build on the achievements to date of Scotland’s wave and tidal energy sector?

Please give us your views:

RTPI Scotland reiterates its response to Questions 9 and 10, acknowledging that discussion of the onshore planning and consenting implications for wave and tidal energy infrastructure is needed to ensure that development is balanced and doesn’t conflict with other spatial principles or priorities.

 

13) Do you agree the Scottish Government should set an ambition for solar deployment in Scotland? If so, what form should the ambition take, and what level should it be set at?

Please explain your views:

As discussed in our answer to Question 9-12, RTPI Scotland cannot comment on the ambitions for deployment of solar energy, but the institute believes that it is a part of Scotland’s energy mix for the future to achieve a 75% reduction in emissions by 2030, and net-zero by 2045.

 

14) In line with the growth ambitions set out in this Strategy, how can all the renewable energy sectors above maximise the economic and social benefits flowing to local communities?

Please provide further details:

RTPI Scotland believes that maximising the economic and social benefits of renewable energy sector growth could be facilitated through a range of routes:

- Share Ownership
- Local job opportunities and apprenticeships expanded through CESAP (see answer to Question 7).
- Place principle and 20-minute neighbourhoods: incorporating alignment between new renewable energy sector and spatial ambitions of Scotland’s settlements

Shared Ownership models are vital to this buy-in due to their greater local acceptance by communities and ability to offset the impacts of renewable projects on the landscape - good practice principles for which are available online [1]. Support from the public for onshore wind is growing with a recent poll showing 70% of respondents supportive of its deployment [2]. However, awareness and knowledge of the potential in community energy and shared-ownership schemes, as well as the opportunities to get involved, is highlighted as a barrier.

Schemes such as CARES (Community and Renewable Energy Scheme) from the Scottish Government provide funding and knowledge to assist local communities through the initial process of shared ownership schemes but have been identified to not go far enough in providing support. Communities rely on local volunteers’ time and limited funding to undertake such schemes  and the contractual discussions with developing partners, providing a barrier based on local resourcing rather than infrastructure. RTPI Scotland defers to Scottish Renewables and Community Energy Scotland for further discussion regarding CARES.

As discussed in our response to Questions 2 and 3, Local Place Plans (LPPs) are a central focus for community engagement as implemented in the Planning (Scotland) 2019 Act. This new type of community-led plans provides opportunities for communities to develop proposals and ideas for the development of where they live. LPPs can help community planning and land-use planning achieve better outcomes for communities. RTPI Scotland note that the recently published Local Place Plans – ‘How To’ Guide: Literature Review and Final Report was silent in regards to the role they could play in renewable energy developments. This signals a locus within the planning system to develop awareness of the potential in community energy and shared-ownership schemes and a formal mechanism for consultation and planning could occur. Thus, if combined with a rigorous site assessment process to make sure the land is suitable for development, LPPs have the advantage of being developed at a more granular level with local community buy-in about the types of development that are needed and the best locations for the proposals.

However, RTPI Scotland wishes to convey the need for strategic resource allocation to achieve a more formalised approach to community energy both in its direct financing, but also the resourcing of the planning sector to undertake growing duties emerging from the Planning (Scotland) 2019 Act. We reference the answer to Question 4 regarding the skills, staffing and resourcing concerns that need to be addressed to allow for the most successful delivery of energy infrastructure across Scotland.

(1) Scottish Government (2019) Community benefits from onshore renewable energy developments. May. Available here: https://bit.ly/3CzBz33
(2) Department for Business, Energy and Industrial Strategy (2021) Public Attitudes Tracker: Wave 37. May. Available here: https://bit.ly/39t2EIA

 

 

15) Our ambition for at least 5GW of hydrogen production by 2030 and 25GW by 2045 in Scotland demonstrates the potential for this market. Given the rapid evolution of this sector, what steps should be taken to maximise delivery of this ambition?

Please give us your views:

RTPI Scotland is not able to comment on the specifics of hydrogen production targets and market creation. However, RTPI Scotland is currently developing a workforce strategy and paper on ‘New Ways of Working’ that both discuss the need for the Scottish planning sector to identify developing and future models of renewables infrastructure to ensure that knowledge and skills remain up-to-date given the rapid evolution of the sector. This is to ensure that planning is not perceived as a ‘barrier’ to energy infrastructure development and to maintain an agile consenting regime.

RTPI Scotland wishes to make clear the complexity of reasons why planning is framed as a ‘barrier’, referring to our response to Question 7 outlining the resourcing issues and demographic/succession challenges facing the planning sector, with a limited staffing pipeline putting the system at risk of delayed planning permissions and a delayed consenting regime. This also involves the loss of key skills regarding specialist areas of consenting such as renewables.

 

16) What further government action is needed to drive the pace of renewable hydrogen development in Scotland?

Please give us your views:

As discussed in our response to Questions 7 and 15, the resourcing issues and demographic/succession challenges facing the planning sector, with a limited staffing pipeline, put the pace of all renewable energy deployment at risk of delayed planning permissions and a delayed consenting regime. This also involves the loss of key skills regarding specialist areas of consenting, as is the case for renewable hydrogen development. Thus, RTPI Scotland believes that government action is needed to provide adequate resource for the planning sector to ensure that is not a barrier to the timely consenting of new renewables projects in Scotland.

 

17) Do you think there are any actions required from Scottish Government to support or steer the appropriate development of bioenergy?

Please give us your views:

No comment.

 

18) What are the key areas for consideration that the Scottish Government should take into account in the development of a Bioenergy Action Plan?

Please give us your views:

No comment.

 

19) How can we identify and sustainably secure the materials required to build the necessary infrastructure to deliver the energy strategy?

Please explain your views:

RTPI Scotland cannot comment on the specifics of a procurement strategy identified in this question. However, as discussed in our response to Questions 1 and 2, the Institute believes that the example of The Republic of Ireland’s Project Ireland 2040 strategic vision and policy structure provides a clear case of good practice which Scotland can take influence from. From this form of integrated structure and investment plan, an approach to the sustainable procurement of materials for an infrastructure first approach could take place.

 

Chapter 3 - North Sea oil and gas

20) Should a rigorous Climate Compatibility Checkpoint (CCC) test be used as part of the process to determine whether or not to allow new oil and gas production?

Please give us your views:

No comment.

 

21) If you do think a CCC test should be applied to new production, should that test be applied both to exploration and to fields already consented but not yet in production, as proposed in the strategy?

Please explain your views:

No comment.

 

22) If you do not think a CCC test should be applied to new production, is this because your view is that:

Not Answered

Please explain your answer:

No comment.

 

23) If there is to be a rigorous CCC test, what criteria would you use within such a test?

Not Answered

Please explain your answer:

No comment.

 

Should a CCC test take account of energy security of the rest of the UK or European partners as well as Scotland? If so, what factors would you include in the assessment, for example should this include the cost of alternative energy supplies? :

No comment.

 

Should a CCC test assess the proposed project's innovation and decarbonisation plans to encourage a reduction in emissions from the extraction and production of oil and gas? :

No comment.

 

 

In carrying out a CCC test, should oil be assessed separately to gas? :

No comment.

 

24) As part of decisions on any new production, do you think that an assessment should be made on whether a project demonstrates clear economic and social benefit to Scotland? If so, how should economic and social benefit be determined?

Please explain your views:

No comment.

 

25) Should there be a presumption against new exploration for oil and gas?

Please give us your views:

No comment.

 

26) If you do think there should be a presumption against new exploration, are there any exceptional circumstances under which you consider that exploration could be permitted?

Please explain your views:

No comment.

 

Chapter 4 Energy demand - Heat in buildings

 

27) What further government action is needed to drive energy efficiency and zero emissions heat deployment across Scotland?

Please give us your views:

No comment.

 

Chapter 4 Energy demand - Energy for transport

 

28) What changes to the energy system, if any, will be required to decarbonise transport?

Please give us your views:

RTPI Scotland greatly welcomes further efforts to decarbonise transport in relation to the energy system. Whilst we cannot comment on technical aspects of this, we wish to make note that encouragement of more sustainable transport options such as public transport and active transport is vital to this. As discussed in our response to Questions 1 and 2, RTPI Scotland believes that greater connection to NPF4’s spatial strategy and principles for local living, 20 minute neighbourhoods and the development of better active transport networks is vital for the reduction of car kilometres in this draft strategy.

 

29) If further investment in the energy system is required to make the changes needed to support decarbonising the transport system in Scotland, how should this be paid for?

Please give us your views:

No comment.

 

30) What can the Scottish Government do to increase the sustainable domestic production and use of low carbon fuels across all modes of transport?

Please give us your views:

No comment.

 

31) What changes, if any, do you think should be made to the current regulations and processes to help make it easier for organisations to install charging infrastructure and hydrogen/low carbon fuel refuelling infrastructure?

Please explain your views:

RTPI Scotland provided a response to the Government’s 2022 Phase 2 Consultation on the Review of Permitted Development Rights in Scotland, in which we raised that there is difficulty in finding the right balance between simplifying the consenting regime to support delivery of EV charging to meet net-zero targets whilst still undertaking the necessary checks and controls to protect public and private interests. The consenting regime and delivery environment for EV charging installation is complex and planning has been cited as a key factor in the slow roll-out of such technology[1]. However, RTPI Scotland are aware of concerns from stakeholders that extending permitted development with the removal of restrictions in the specified areas currently listed in Class 9E(3) could result in insensitive development that could have either individually or cumulatively have a significant negative impact on the character and appearance of certain areas. Therefore, we take the perspective that a balanced approach to any changes in charging and refuelling infrastructure regulations should be taken so that unintended consequences of overconcentration, local character impact, and conservation issues.

(1)https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1065576/taking-charge-the-electric-vehicle-infrastructure-st

 

 

32) What action can the Scottish Government take to ensure that the transition to a net zero transport system supports those least able to pay?

Please give us your views:

As discussed in our response to questions 1 and 28, the decarbonisation of transport in Scotland involves a modal shift towards the use of more public and active transport. The National Transport Strategy 2 (NTS2) [1] and Transport Scotland’s Draft Fairer Scotland duty Assessment for reducing car use for a healthier, fairer, and greener Scotland’ [2] provide a research-led policy based on the following figures:

- Those on lower incomes are less likely to use cars, with 19% of those with annual household incomes under £10,000 using car daily, compared with 62% of those with annual household incomes over £50,000
- Those on lower incomes are more likely to use bus than those on higher incomes, with 51% of those with household incomes up to £10,000 per annum having used the bus in the past week, compared with 27% of those with household incomes over £50,000 per annum
- There are similar rates of walking amongst all income groups, with 32% of those with annual household incomes under £10,000 walking for transport daily, compared with 29% of those with annual household incomes over £50,000

Additionally, the NTS2 vision is to:

- Reduce Inequalities;
- Take Climate Action;
- Help deliver inclusive economic growth;
- Improve our health and wellbeing.

Acknowledging these findings alongside the NTS2 vision and national 2030 vision for a 20% reduction in car kilometres and phasing out of traditional petrol and diesel vehicles, a move to greater local living, investment in decarbonised public and active travel options and a focus on compact growth in urban centres is vital to ensuring that those least able to pay for transport are able to live healthy, dignified lives and that the transition to a wellbeing economy is inclusive so that “we [d]on’t let history repeat itself” as occurred through the period of deindustrialisation in Scotland.

As discussed in previous questions, NPF4 provides the spatial strategy to achieving local living, compact urban growth and facilitating 20-minute neighbourhoods that promote more inclusive forms of transport, and the health & wellbeing outcomes of active transport.

Resultantly, RTPI Scotland believes that continued support for the development of the most equitable forms of transport networks is continued and that the fair duty assessment is continued to monitor the inclusivity of developing infrastructure to those with lower annual incomes and hard-to-reach communities.

(1) https://www.transport.gov.scot/media/47052/national-transport-strategy.pdf
(2)https://www.transport.gov.scot/media/50881/draft-fairer-scotland-duty-assessment-a-route-map-to-achieve-a-20-per-cent-reduction-in-car-kilometres-by-2030.pdf

 

33) What role, if any, is there for communities and community energy in contributing to the delivery of the transport transition to net zero and what action can the Scottish Government take to support this activity?

Please give us your views:

RTPI Scotland believes that communities across Scotland play an integral part in the delivery of net-zero across all sectors and to ensure that development is reflective of community perspectives, incorporates community knowledge of place, and fosters community buy-in to new projects. We believe this is a vital link in planning for the long-term public interest.

As discussed in our response to questions 3 and 14, Local Place Plans (LPPs) formed from the Planning (Scotland) Act 2019 function as community-led local plans, incorporating local perspectives on areas requiring improvement such as sustainable travel. An example of public engagement relating to this is the Sustaining Choices project run by Planning Aid Scotland, which uses a place-based approach with communities to publish a Sustainable and Active Travel Action Plan for their community with short-, medium- and long-term actions. This is funded by the Paths for All ‘Smarter Choices, Smarter Places’ initiative. Alongside CARES provided through Local Energy Scotland Consortium, these provide examples of what is currently being done. These forms of engagement form an important part of place-based partnerships between anchor organisations and offer a model for the planning and eventual delivery of sustainable transport transitions to decarbonise the sector and change behaviour away from car-based transit.

As described in responses to previous questions, such projects are resource-intensive for volunteers, third sector organisations and LPAs. RTPI Scotland believes that Scottish Government could provide greater resource streams to support these ambitions.

 

34) What, if anything, could be done to increase the reuse of electric vehicle batteries in the energy system?

Please give us your views:

No comment.

 

Chapter 4 Energy demand - Energy for agriculture

 

35) What are the key actions you would like to see the Scottish Government take in the next 5 years to support the agricultural sector to decarbonise energy use?

Please give us your views:

No comment.

Chapter 4 Energy demand - Energy for industry

 

36) What are the key actions you would like to see the Scottish Government take in the next 5 years to support the development of carbon capture, utilisation and storage (CCUS) in Scotland?

Please give us your views:

No comment.

 

37) How can the Scottish Government and industry best work together to remove emissions from industry in Scotland?

Please give us your views:

No comment.

 

38) What are the opportunities and challenges to CCUS deployment in Scotland?

Please give us your views:

No comment.

 

39) Given Scotland’s key CCUS resources, Scotland has the potential to work towards being at the centre of a European hub for the importation and storage of CO2 from Europe. What are your views on this?

Please explain:

No comment.

 

Chapter 5 Creating the conditions for a net zero energy system

 

40) What additional action could the Scottish Government or UK Government take to support security of supply in a net zero energy system?

Please give us your views:

As discussed in our response to previous questions, RTPI Scotland believes that the draft does not provide a strong linkage to NPF4, which provides the spatial expression, strategy and policy for Scotland’s ongoing transformation to a net-zero energy system. We wish to highlight the relevance of The Republic of Ireland’s Project Ireland 2040 which shows coherent policy linkages between long-term strategy and capital investment.

RTPI Scotland believes that a similar approach that develops more coherent linkages between energy, spatial strategy, place-based working and investment would be beneficial to the strategy and developing the long-term ambitions for energy security.

 

41) What other actions should the Scottish Government (or others) undertake to ensure our energy system is resilient to the impacts of climate change?

Please give us your views:

No Comment.

 

Chapter 6 Route map to 2045

 

42) Are there any changes you would make to the approach set out in this route map?

Please give us your views:

As discussed in our response to question 7, RTPI Scotland believes that addressing the skills and resourcing constraints facing the planning sector is vital to achieving the route map for net zero energy transformation by 2045. This could fit appropriately within the Green Jobs skills transition or fund, given the nature of planning within sustainable development. Compared to other sectors, the planning system requires a smaller aggregate investment and skills pipeline with a 15 year staffing demand of 680-730 planners shown in the Future Planners report [1] and other resourcing issues:

• Nearly a third of planning department staff have been cut since 2009
• Planning authorities’ budgets have diminished in real terms by 42% since 2009
• In 2020 local authorities only spent 0.38% of their total net revenue budgets
• Planning application fees only cover 66% of their processing costs
• There are 91 new and unfunded duties in the Planning (Scotland) Act, which could cost between £12.1m and £59.1m over 10 years

(1) https://hopscotland.files.wordpress.com/2022/07/future-planners-project-report-uploaded-15th-july-2022.pdf

 

 

43) What, if any, additional action could be taken to deliver the vision and ensure Scotland captures maximum social, economic and environmental benefits from the transition?

Please give us your views:

As described in the answer to previous questions, the purpose of planning in response to the climate emergency is to ensure that sustainable development is undertaken in the long-term public interest, and to ensure it is balanced to provide the delivery of benefits to health and wellbeing. RTPI Scotland believes that continuing to facilitate place-based approaches involving community engagement is vital to this, alongside a coherent structure of policy and strategy between energy, spatial strategy and capital investment for infrastructure.

Impact assessment questions

 

44) Could any of the proposals set out in this strategy unfairly discriminate against any person in Scotland who shares a protected characteristic?

Please explain your views:

No comment.

 

45) Could any of the proposals set out in this strategy have an adverse impact on children’s rights and wellbeing?

Please explain your views:

No comment.

 

46) Is there any further action that we, or other organisations (please specify), can take to protect those on lower incomes or at risk of fuel poverty from any negative cost impact as a result of the net zero transition?

Please give us your views:

No comment.

 

47) Is there further action we can take to ensure the strategy best supports the development of more opportunities for young people?

Please give us your views:

No comment.

 

Just Transition energy outcomes

 

48) What are your views on the approach we have set out to monitor and evaluate the Energy Strategy and Just Transition Plan?

Please give us your views:

RTPI Scotland is broadly in agreement with the approach to monitoring and evaluation in that it connects with Scotland’s National Performance Framework and a range of impact assessments. However, we believe that there is an opportunity to embed a greater evaluation of the effects the Energy Strategy and Just Transition Plan has on place, particularly given the spatial vision and outcomes of NPF4.

The Scottish Place Standard tool and place principle [1] are a vital approach to measuring the qualities that make places successful and assessing inequalities in place across the country. Alongside this, RTPI’s Measuring What Matters: Planning Outcome Research [2] provides a monitoring and evaluation toolkit for ensuring that development is sustainable and progresses towards a measuring increase in place quality and value. This iterates research by M. Carmona and the Place Alliance on the relationship between place quality and value [3]. We believe that these are useful approaches to the measurement of place-based outcomes that will be vital to a Just Transition, which could be incorporated where applicable into the consulted monitoring and evaluation approach.

(1) https://www.ourplace.scot/About-Place-Standard
(2) https://www.rtpi.org.uk/media/7323/rtpi-measuring-what-matters-planning-outcomes-research-report-november-2020.pdf
(3) http://placealliance.org.uk/wp-content/uploads/2019/03/Place-Value-and-the-Ladder-of-Place-Quality-Place-Alliance.pdf

 

49) What are your views on the draft Just Transition outcomes for the Energy Strategy and Just Transition Plan?

Please give us your views:

No comment – we refer to our response to Question 48.

 

50) Do you have any views on appropriate indicators and relevant data sources to measure progress towards, and success of, these outcomes?

Please explain your views:

No comment – we refer to our response to Question 48.

 

Strategic Environmental Assessment

51) Do you have any comments on the environmental baseline information referred to in the Environmental Report?

Please provide comments :

No comment.

 

52) Are you aware of further information that could be used to inform the assessment findings?

Please explain:

No comment.

 

53) What are your views on the assessment findings?

Please explain your views:

No comment.

 

54) Are there other environmental effects arising from the draft Energy Strategy and Just Transition Plan?

Please explain:

No comment.

 

55) Do you agree with the justification for the approach to the alternatives?

Please explain:

No comment.

 

56) What are the most significant environmental effects which should be taken into account as the draft Energy Strategy and Just Transition Plan is finalised?

Please explain:

No comment.

 

57) How can the draft Energy Strategy and Just Transition Plan be enhanced to maximise positive environmental effects?

Please explain:

No comment.

 

58) What do you think of the proposed approach to mitigation and monitoring?

Please explain:

No comment