Publication - Consultation analysis

Good practice principles for renewable energy developments consultation: analysis of responses

Published: 15 Apr 2019

In 2018, we reviewed and consulted on our good practice principles for: community benefits from onshore renewable energy developments, shared ownership of onshore renewable energy developments, and community benefits from offshore renewable energy developments. 

27 page PDF

344.4 kB

27 page PDF

344.4 kB

Contents
Good practice principles for renewable energy developments consultation: analysis of responses
Main Findings

27 page PDF

344.4 kB

Main Findings

Scottish Government Good Practice Principles for Community Benefits from Onshore Renewable Energy Developments

1.1 Do you consider that the revised Good Practice Principles (GPPs) will ensure that communities continue to benefit from renewable projects in a manner that is appropriate for the current and future context in which projects are developed?

Key figures

  • 41 responses (87.2%) were received for this question 
  • 33 comments obtained from respondents
Yes No Don’t Know Not Answered 
Community groups (5) 2 1 1 1
Local Authorities and other public sector (6) 4 2 - -
Trade bodies and interest groups (7) 1 5 - 1
Renewables industry (18) 9 4 2 3
Others (4) - 1 2 1
Individuals (7) 4 2 1 -
Total  20 15 6 6

Summary 

As the table above shows, almost half (48.7%) of respondents agreed with the question. 

While many of the respondents stated that they agreed with, and generally supported, the GPPs - and considered them to be a useful tool - a number of concerns were raised regarding how community benefits continue to remain voluntary. 

A sizeable minority of respondents (36.6%) did not agree. 

One of the main concerns raised (which is a common theme throughout this document) was that the £5,000 per MW figure was considered to be unsustainable by some respondents (particularly those representing the renewables industry). 

There was also debate around the word “ensure”. A number of respondents felt this could not be applied to voluntary principles and, ultimately, the responsibility will fall to communities, developers, and advisors to make sure communities continue to benefit.

Finally, those who selected “Don’t Know” made very similar points to those made above. 

1.2 The revised GPPs promotes a more flexible and evidence based approach to discussions about community benefit, with the focus on creating a lasting legacy. Do you agree with this approach?

Key figures

  • 41 responses (87.2%) were received for this question 
  • 33 comments obtained from respondents
Yes No Don’t Know Not Answered 
Community groups (5) 2 1 1 1
Local Authorities and other public sector (6) 6 - - -
Trade bodies and interest groups (7) 5 - 1 1
Renewables industry (18) 15 - - 3
Others (4) 2 - 1 1
Individuals (7) 5 2 - -
Total  35 3 3 6

Summary 

The table above illustrates the overwhelming number of respondents (85%) agreed with the approach taken in the revised GPPs – including all respondents from the renewables industry (who provided an answer) and those replying on behalf of local authorities/ public bodies.

The responses received from the renewables industry indicated that direct monetary payments were not always the most appropriate form of community benefit provision. Therefore, the flexible approach should be more highly recommended as this would enable communities themselves to suggest the best means of guiding community investment, and that they may not wish to opt for a ring-fenced financial fund. 

More guidance was requested on evidencing from respondents. There was a belief that this would not restrict flexibility but would, rather, create a shared understanding of expectations. 

Also, local action plans were noted as a key element for providing communities with an evidenced-based set of priorities and provide transparency on the community side. However, some respondents felt that the guidance was not clear regarding how developers would provide transparency. 

Additionally, the positive nature of the guidance was welcomed - in particular, where the community are encouraged to build positive relationships with renewable energy businesses. 

2 of the 3 respondents who answered “No” provided comments. Again, these highlighted the fact that community benefits remain voluntary and raised concerns surrounding what legacy, if any, the renewable development will leave to the community.

Similar to the above, 2 comments were received from those who responded “Don’t Know”. These focused on (a) evaluating community benefits against the wider funding environment, and (b) suggestions to bolster some of the practical issues around community planning.

1.3 The revised GPPs will continue to promote community benefit of the value equivalent to £5,000 per MW, however at the same time recognising that some renewable energy businesses will seek to offer flexible packages of benefits for new developments. Do you agree with this approach?

Key figures

  • 39 responses (82.9%) were received for this question 
  • 35 comments obtained from respondents
Yes No Don’t Know Not Answered 
Community groups (5) - 3 - 2
Local Authorities and other public sector (6) 5 - 1 -
Trade bodies and interest groups (7) - 4 2 1
Renewables industry (18) 3 10 1 4
Others (4) 1 - 2 1
Individuals (7) 3 2 2 -
Total  12 19 8 8

Summary 

A considerable number of respondents were in disagreement with the approach outlined (48.7%). 

There were differing views between the responses received from the renewables industry and those representing community groups: the renewables industry argued for the removal of the value per MW figure, whereas the latter believed that this should be the minimum figure offered by developers.

A number of comments were submitted by respondents who agreed with the approach, which are summarised below:

  • The suggested value per MW figure should be the minimum value of the package on offer (similar to those community groups who answered “No”).
  • Further clarity could be provided around the transition period being experienced by the renewables industry - specifically explaining the economic climate in which projects are being developed.
  • The opportunity exists for developers to maximise the community benefit package without adding significant expenditure to a project, while still having a positive, local impact.

A suggestion was also raised that it would be beneficial if there was a method to independently evaluate the package offered by developers.

As indicated above, almost half of respondents selected “No” to the question asked. However, this, predominately, related to the £5,000 per MW figure – not the flexible package approach itself, which was (generally) welcomed.

Comments received includes concerns around how a flexible package would be valued/ assessed, how there may be scope for developers to deliver less for communities, and how the voluntary nature of the guidelines meant there are no requirements for delivery.

A mixture of respondents from various groups (20.5%) also selected “Don’t Know”, and a number of comments were submitted by those who chose this option. These included the belief that the £5,000 figure should be index-linked, as well as concerns around the clarity of wording used in the GPPs (specifically around the word “equivalent”).

1.4 The revised GPPs now includes guidance on developing a community action plan. Is there any additional details that you consider should be included?

Key figures

  • 38 responses (80.9%) were received for this question 
  • 34 comments obtained from respondents
Yes No Don’t Know Not Answered 
Community groups (5) 2 1 - 2
Local Authorities and other public sector (6) 4 1 - 1
Trade bodies and interest groups (7) 5 - 1 1
Renewables industry (18) 14 - - 4
Others (4) 2 - 1 1
Individuals (7) 2 4 1 -
Total  29 6 3 9

Summary 

Over three-quarters (76.3%) of respondents selected “Yes” – welcoming the guidance on community action plans. This included the majority of those representing trade bodies/ interest groups (71.4%) and the renewables industry (77.8%).

However, most respondents who agreed also provided further comments for consideration. 

For example, there were differing views between the renewable industry and other respondent groups regarding who will fund community actions plans, and also whether or not the responsibility should lie with developers to establish such plans – or if this should be the role of, for example, local authorities or similar bodies. 

This was supported by further comments which highlighted the importance of any action planning being community-led.

A request was also made for further guidance to be provided for developers in instances where projects spanned across areas which encompassed multiple community action plans.

There was general support across respondents that, ideally, everything concerning community benefit packages would be open to regular review (i.e. the agreement itself, the community action plan, the area of benefit, and how this will be delivered). It was, however, recognised that, in practice, this unlikely to be achievable. 

Finally, those who responded “Don’t Know” (7.9%) welcomed the inclusion of guidance on developing a community action plan and the statement on the relationship of community benefit funds to decision-making in the planning system. 

It was also noted that the forthcoming Planning Bill makes a provision for Local Place Plans, and the relationship between community action plans and Local Place Plans should be clarified in future guidance.

1.5 Do you have any other views on the revised GPPs?

Key figures

  • 28 comments obtained from respondents

Summary 

Alongside general, positive comments regarding the usefulness of the GPPs, a number of suggestions for improvement/ clarifications were made by respondents.

The issue surrounding the value per MW figure was raised again, with a desire to see this figure being index-linked.   

Additional comments provided included:

  • Further clarity on establishing boundaries between communities to determine who is/ is not impacted.
  • More guidance on capacity building in communities.
  • Consideration to communities impacted by transportation to and from projects.
  • Further information on how community action plans and community benefit funds are monitored.
  • The need to promote involvement from local authorities.
  • Concerns around the impact when re-powering renewable energy installations, and their impact on community benefit arrangements.
  • At which stage in the development of an installation should community benefits begin (for example – at the handover stage or the construction stage, etc.).
  • The need to ensure a level-playing field between renewable energy developments vs. non-low carbon alternatives.
  • Concerns regarding what happens to community benefit arrangements when a development is sold.

Contact

Email: CBSOGuidanceReview@gov.scot