Chapter 10
96) Do you agree with the approach to planning for energy and water infrastructure in policy W1? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree, what alternative approach would you suggest?
The RTPI fully endorses the approach set out in Chapter 10, with the clear recognition of the importance of improving energy and water infrastructure. We note our response to Q6(a), 7(a) and 15(a) regarding infrastructure considerations, highlighting further opportunities to strengthen the role of infrastructure planning in the planning system. Regarding this policy area in particular, the RTPI is aware of the need to more closely align the approach in Chapter 10 with the relevant suite of National Policy Statements. Furthermore, we would wish to understand how W1(1) would engage with and interact with principles set out in DM7(1), acknowledging the latter is targeted towards decision making, but also that there is a clear overlap with plan preparation. As set out elsewhere in our response we would welcome the inclusion of reference to the role of statutory consultees in regard to W1(1).
We would again wish to see a clear role for statutory consultees in this policy and would also wish to see specific reference to grid operators and water companies and regulators in the preparation of local plans.
97) Do you agree with the amendments to current Framework policy on planning for renewable and low-carbon energy development and electricity network infrastructure in policy W2? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI welcomes the amendments to the policy, especially with the inclusion of reference to electricity network infrastructure, with grid capacity constituting one of the significant barriers to decarbonising electricity generation. Grid capacity also has an important role in enabling housing delivery and economic development, especially with the recent growth in data centres, which require considerable energy to operate. In order to deliver the target of clean power by 2030, the RTPI would recommend amending W1(2)(a) to include a requirement for the development plan to positively identify areas which are most suitable for renewable and low carbon energy development and electricity network infrastructure.
98) Do you agree with the proposed approach to supporting development for renewable and low carbon development and electricity network infrastructure in policy W3? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree, and any changes you would make to improve the policy.
The RTPI welcomes the substantial weight for such development through contributing to energy security, economic development and achieving net-zero ambitions. The transition to net-zero is going to require significant upskilling of our planning workforce in order to meet the specific challenges brought around by such development types. We do raise some concerns over the lack of detail for the purposes of decision making. This would include, for example, the lack of a clear objective test to assess likely significant environmental effects and balance these against benefits. We note the significantly more detailed approach taken to a national decision-making policy for energy in Scotland regarding Policy 11 of the National Planning Framework 4. We do note the impending guidance on planning for onshore wind, which will partially address this concern. Such guidance may be usefully supplemented managing a wider range of other development types, including Battery Energy Storage Systems. We would welcome clarity over how W3(2) would be applied in regard to S(5)(j).
99) Do you agree with the proposed approach to supporting development for water infrastructure in policy W4? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
No further comment.
