Fees charged for applications under the Electricity Act 1989: analysis of consultation responses

3. Other Issues Raised By Respondents

3.1 Other points raised by respondents, either in the 23 responses to question 8, which asked "do you have any other comments", or elsewhere in their responses beyond the scope of the foregoing questions, include the following. They are listed in descending order of number of respondents raising each point. The number in brackets next to each indicates the number of respondents making the point. It should be noted that some respondents repeated the same point across responses to more than one question.

• There would be a negative impact on the development pipeline / deployment / progress to targets (7)
• Implementation should be delayed / there should be a grace period (6)
• The proposed fees would be disproportionately high (5)
• Planning authorities should receive greater remuneration (4)
• There should be a second consultation on revised proposals (4)
• More information on Energy Consents Unit/Marine Scotland Licensing and Operations Team resource requirements is needed (4)
• These substantial increases would be contrary to the policy support in the Energy Strategy / Onshore Wind Policy Statement (3)
• The Partial Business and Regulatory Impact Assessment within the consultation is insufficient (3)
• The proposed scoping payments would be disproportionately high (2)
• There is a lack of detail of service improvements which would be delivered / more details would be helpful (2)
• Service improvements should be made to provide greater certainty around timely determination (2)
• Greater scoping out of non-significant effects would improve the service (2)
• Justification of the proposed increases is weak or insufficient (2)
• Consultation is being carried out in isolation of other planning related work by Scottish Government - Planning (Scotland) Bill, reviews of NPF and SPP (2)
• Small scale grid connection costs could increase 2 or 3 times / consumers would face impacts (2)
• There would be negative impacts on community benefit and / or community ownership (1)
• Further phasing of payments should be considered (1)
• The fee categories and bands should be reconsidered (1)
• Service agreements or fixed timelines for determination should be introduced (1)
• There should be a review of resourcing for energy consents services in planning authorities (1)
• Variation fees should be substantially lower than applications (1)
• There should be two or more tiers of variation fee (1)
• Further cost reduction should be explored by the Energy Consents Unit/Marine Scotland Licensing and Operations Team (1)
• There should be a consultee to advise on social and economic impact (1)
• The Scottish Government should indicate whether further fees will be introduced relating to advice provided to the Energy Consents Unit/Marine Scotland Licensing and Operations Team by government internal functions such as SNH and SEPA (1)
• The Scottish Government should clarify if it has the intention of imposing fees for obtaining additional licences such as the license to disturb European Protected Species (1)
• When the Scottish Government is undertaking consultation on measures that affect its own finances it should carry out a genuine consultation exercise and it should be open minded about making changes (1)
• The Scottish Government should become more proactively involved in negotiation of radar mitigation (1)
• The Scottish Government should help to organise a landbank available for developers, to ensure that removed forestry is replanted in better suited locations (1)
• The fee regime should be index-linked to the RPI going forward (1)
• The proposed fee increases will have the greatest effect on small businesses, and may discourage or prevent potential start-ups or projects from coming forward (1)