RTPI response to DESNZ’s consultation on scheme design for Bill Discounts for Transmission Network Infrastructure
About the RTPI
At the Royal Town Planning Institute (the RTPI), we champion the value of planning in building thriving places and communities. With over 27,000 members worldwide, we support planners at every stage of their career: raising professional standards, shaping planning policy, and proudly awarding chartered status, the highest professional accreditation in UK planning.
For over a century, we have empowered planners to deliver positive impact: creating healthy, inclusive, economically and environmentally sustainable places. As the voice of the profession, we advocate, support, and lead with purpose, professionalism, and passion.
Consultation response
- Do you have any views on infrastructure in scope of the scheme?
The RTPI disagrees with the principle of supplying bill discounts to those households near infrastructure, regardless of the type of infrastructure. We are concerned that introducing bill discounts carries the risk of creating the perception that planning consent can be ‘bought’. A key principle of planning obligations is that they are directed towards the public good, and schemes providing financial incentives for private individuals are inappropriate in planning terms.
The RTPI does, however, support the inclusion of appropriate and proportionate community benefits which can ensure that communities share in the social, environmental and economic benefits of infrastructure schemes.
Answers to the below questions should be considered with the above caveat in mind.
- Do you have any views on including certain types of capacity upgrades to existing transmission infrastructure?
No comment.
- Do you agree to the proposed approach to determining eligibility for the scheme?
Yes/No/Not sure (Please explain)
Partially. It makes sense to tie the eligibility to the property, and to any property paying an electricity bill. Timestamping the eligibility zone so new properties are potentially excluded makes sense in terms of estimating the cost of supplying bill discounts over a ten-year period (because the number of properties - and thus households - would be fixed) but it is not clear if this is the reason for the timestamping.
The consultation document states: “the infrastructure should be new in relation to a property”. The impact of above-ground electricity transmission infrastructure in an area for local residents is continuous and is not constrained to the initial building or introduction of said infrastructure. To this end, new properties that are built after the eligibility zone is defined should be eligible for bill discounts, because they would still be impacted by the transmission infrastructure.
- Do you have any views on the method of mapping the eligibility zone and identifying eligible properties?
Designating a fixed geographical area and basing eligibility using distance from the Limits of Deviation makes sense in ensuring a clear and consistent approach. As in our response to question 3, we would question why new properties are excluded from benefits through timestamping. We commend an approach that prioritises consistency and clarity and understand that timestamping would allow the total outlay of benefits to be determined at an early stage of project delivery. The consultation document could be clearer in outlining the purpose of the proposed approach and acknowledging that new properties would still be impacted by above-ground transmission infrastructure.
- Are there any functions you think we should ensure the scheme administrator can deliver?
It is important that the governance structures are robust and transparent, with clearly defined roles and accountability embedded from the start.
Given the importance of the scheme administrator role, it is important that the government provides further details on what kind of oversight and accountability is in place regarding the decisions taken by the administrator.
- Do you agree with the proposed approach to considering eligibility for the opt-in scheme? Are there any other household living arrangements we should consider? Please provide any reasoning to support your response.
Yes, I agree
Yes, I agree but there are other households to consider
No, I disagree
Yes, we agree with the proposed approach.
- Do you have any views on how we can maximise reach to communities with scheme communications, particularly those who will need to opt in to benefit?
Community engagement should be done at as early stage as possible, ensuring meaningful engagement with communities and the building of a relationship between them and the project developers. There should be clear guidance that details the principles underpinning proper engagement and the outcomes that good engagement would achieve.
- Do you agree that direct Bacs payment should be the primary delivery method for successful opt-in recipients, and that we should continue to explore alternative delivery options for exceptional cases?
Yes I agree/No, I disagree (Please explain)
Yes, we agree that direct Bacs payments make sense as the primary delivery method for opt-in recipients, but at the same time, alternative delivery options should be explored.
- Do you agree we should include multiple occupancy buildings in scope of the bill discount scheme? If yes, do you agree that delivery should be via an intermediary receiving the benefit and being mandated to pass the £250 to residents in equal shares? If not, do you have a view as to which option strikes the best balance between ensuring they benefit, without compromising deliverability or adding disproportionate cost and complexity?
Yes, I agree with all multi-occupancy building scope and delivery proposals
Yes, I agree multiple occupancy buildings should be in scope, but I do not agree with the proposed design details.
No, I think multiple occupancy buildings should be excluded. (Please explain)
Yes, we agree with the multi-occupancy building scope and delivery proposals.
- Do you agree that all other household types who are eligible but will not receive automatic bill discounts (e.g. eligible households on commercial meters) should apply for the scheme individually?
Yes, I agree/No, I disagree (please explain)
Yes, we consider this appropriate, as long as there is appropriate support for those more vulnerable households without digital capabilities and in need of extra assistance.
- Do you agree with the principles for verifying applicant eligibility for the scheme? Do you have any suggestions for how we can balance the need to verify eligibility and reduce burden on both the scheme administrator and households?
Yes, I agree/No, I disagree (please explain)
Yes, we think these principles are appropriate.
- Do you agree that electricity suppliers should deliver the scheme to their eligible traditional pre-payment meter customers by offering vouchers, with no redemption-related requirements?
Yes, I agree/No, I disagree (please explain)
Yes, this seems appropriate given the way pre-payment meters operate, and would allow those on these traditional meters to still have access to the scheme.
- Are there any considerations we should take into account when assessing options to deliver the scheme to eligible pre-payment meter customers?
No comment.
- Do you agree with the proposed distribution of costs across suppliers to fund the scheme? Please provide evidence to support your answer wherever possible.
No comment.
- Do you agree with the outlined proposals for supplier failure?
No comment.
- Do you agree with introducing a de minimis threshold for the bill discount scheme? Please provide evidence to support your answer wherever possible.
Yes/No/Not sure (please explain)
No comment.
- Do you consider that licensed electricity suppliers should be allowed to recover costs from the scheme to contribute to the costs they incur for their role in delivering the scheme? Please provide clear evidence in your answer (for example evidence of administration costs used to fund other schemes).
Yes/No/Not sure (please explain)
No comment.
- Do you agree with the proposed payment and reconciliation timings, including for an initial reconciliation payment? Please provide evidence wherever possible to support your response.
Yes, I agree/No, I disagree (please explain)
No comment.
- Do you agree with the rationale for intervention and the market failures we have identified? Are there any points we have missed?
Yes, I agree/No, I disagree (please explain)
No comment.
- Do you agree with the impacts that have been identified? If not, explain why with supporting evidence.
Yes, I agree/No, I disagree (please explain)
No comment.
- Do you think there are other impacts that have not been identified? If yes, what other impacts are there that have not been included? Please provide supporting evidence.
No, there are no other impacts/Yes, there are other impacts (please explain below)
No comment.
- Please provide any data and evidence on whether this policy is likely to reduce delays to transmission network build.
No comment.
- Are there any groups you expect would be uniquely impacted by these proposals, such as small and micro businesses or people from protected characteristics? If yes, which groups do you expect would be uniquely impacted? Please provide supporting evidence.
Yes/No (please explain)
No comment.
