Please do take the time to respond to this Consulttion.
The consultation can be found here
Responses may be submitted until 11th April 2025, when the consultation closes. It purports to be part of a review of the Good Practice Principles for community benefits from onshore and offshore net zero energy developments, which seeks to ensure that our guidance helps communities and developers get the best from community benefits.
The opening section (a foreward by Energy Minister Gillian Martin MSP) can safely be skimmed, given that it’s little more than a puff piece promoting the alleged importance of green energy to our economy together with the usual dubious claims about the anticipated benefits, while ignoring the many downsides (industrialisation of Scotland’s wild places, damage to tourism, impact on communities and individuals, damage to the environment and ecology, expensive energy leading to fuel poverty and the exporting of energy-intensive industries that are reliant on cheap energy, etc.).
The Minister asks how net zero energy developments will impact communities (she means “what impact will it have on”), and the way the question is phrased carries with it the first hint that it isn’t just the communities that will experience the adverse impacts of renewable and related developments who are to receive the ‘trinkets for the natives’ that the community benefits regime is intended to benefit. Why else refer to communities, particularly those who will have developments on their doorsteps? [our emphasis]. After all, what other communities are affected by such developments? Why should unaffected communities benefit? Then there’s this:
It… means increasing access to cleaner, more sustainable energy, and delivering meaningful and long lasting benefits for people in communities. Embracing this opportunity will contribute towards achieving our mission to tackle poverty and support community wealth building. Our ambition for the future of community benefits needs to be commensurate with the scale of opportunity from Scotland’s net zero energy transition.
And this:
The people of a country producing high volumes of clean electricity should see direct benefits in terms of affordability of energy. We will continue to advocate for Scotland’s communities to receive a just and equitable outcome from increased transmission infrastructure.
And then this:
We want to use all levers available to ensure that Scotland’s community benefit arrangements deliver sustainable, meaningful and impactful outcomes, informed by the voices of our diverse communities.
Finally this:
I am determined that Scotland’s renewable energy resources should deliver even more significant benefits to our society…
This appears to signal a bigger underlying agenda? How will benefits to affected communities eradicate poverty and specifically child poverty, which is predominantly within urban areas. It reads, for better or for worse, as though it’s aimed at diverse communities of Scotland rather than just the bits of Scotland that are directly adversely affected by renewable energy developments and the associated industrial infrastructure.
Section 1.1 refers to rural and island communities who are not always in proximity to offshore and onshore renewable energy developments, then says:
Community benefits have the potential to deliver meaningful and long-term benefits for these communities.
The implication, once more, seems to be that communities both in proximity and not in proximity to such developments might benefit. We have already seen this in practice where community benefit funds from renewable developments are used by Councils for various projects, including firework displays, more than 10 km distant from an onshore windfarm.
Section 2 is basically a puff piece in favour of offshore wind, while recognising some of the difficulties associated with this problematic energy source. For current purposes, the importance of this section is with regard to what is meant by the term “communities”, especially in the context of community benefit. We are told:
Identifying the community who will benefit is a key principle of designing and providing a community benefit package, as set out in our existing Good Practice Principles. The guidance notes that there is no single definition of community that can be applied for every used by the developer to identify the most relevant stakeholders.
The Scottish Government has defined ‘a community’ in National Planning Framework 4 (NPF4) as ,
| “A body of people. A community can be based on location (for example people who live or work in or use an area) common identity (for example a shared ethnicity, language, age) or common interest (for example the business community, amenity, sports, social or heritage groups).” |
It would be expected that for consistency, the same definition of ‘community’ would be applied. In which case, are community benefits to be distributed to those only of a specific ethnicity, or those with a specific net zero supporting agenda?
Whereas with onshore wind and other terrestrial renewable energy technologies the Scottish government states “proximity to site is the primary [but apparently not the only] indicator”, it’s different with regard to offshore developments:
Offshore development involves multiple communities, often in multiple places, and at times with varying and competing interests. In some circumstances, a ‘community of locality’ based on geographical location will be key….Offshore wind development will be focused around strategically located port clusters with proximate communities. Other communities are based in areas where offshore energy transmission infrastructure comes ashore – although the construction of electricity transmission infrastructure is not limited to offshore wind developments.
There is still the implication that all of Scotland should benefit from any community benefits that are going:
Community benefits from offshore renewables have the potential to support a wide range of projects across Scotland, from infrastructure to culture and beyond….As set out above, the dispersed footprint and large scale of offshore wind projects often involves multiple communities and identifying appropriate decision makers and beneficiaries is key. However, there is also a need for collaboration, engagement and strategic thinking across communities and stakeholders to maximise the impact of community benefits.
Beyond the hints, however, there is a fairly blunt and direct suggestion that developers’ money might be used more widely than in just the communities that have been adversely affected by these developments:
Community benefit arrangements in Scotland have typically followed a project specific application style fund, however other models have been put forward by local authorities and community stakeholders. These include proposals to use a portion of funds to support regional strategic funds, as well as for a nation-wide community wealth fund. [Our emphasis].
While our position remains one of opposing renewable energy developments in inappropriate locations, and of being angered by the “trinkets for the natives” aspect of community benefits (also known as bribes), we think that where communities have had these developments foisted on them (often against the wishes of the majority of residents) then any community benefits that are on offer should be reserved for those unfortunate communities and not shared more widely among those who have not and will not suffer the adverse consequences. That principle should apply whether it is onshore or offshore developments that are under discussion.
Local, adversely affected communities should decide how community benefit is spent. After all, the Minister has said, Our view is that those communities must see tangible and long lasting benefits, and that there must be improvements on how these are delivered and how those communities are involved in decision making. A long list of topics the SG considers is suitable for CB funding is provided on page 18, which includes ‘cultural assets, educational support, skills development etc. Decision making should extend to meaningful decisions by the affected community on how and where community benefit funds should be spent.
Within the existing Good Practice Principles, the Scottish Government set out that the voluntary community benefits (CB) are not compensation for impacts on communities or other interests, including commercial interests, arising from renewable installations.
Nevertheless, the intention is for CB to benefit those communities who are most likely to be adversely affected by renewable developments.
Thus questions with regard to offshore wind, such as question 1:
(In the context of offshore wind development, what or who or where do you consider the relevant communities to be?)
should, in our view, be answered narrowly. E.g. Those whose livelihoods and environmental interests are specifically likely to be affected adversely by construction, operation and decommissioning of off shore windfarms. In particular, this should include fishermen and their families, farmers whose land will be disrupted by pylons, turbines and substations, properties affected by increased traffic, noise and dust during construction and those properties affected by related rural industrialisation of turbines, pylons or substations, local businesses and communities relying on tourism whose outlook and amenity will be industrialised and environmental groups such as marine ecologists.
Similarly with regard to question 7:
(The development of offshore wind is often geographically dispersed with multiple communities who could potentially benefit. To what extent do you agree or disagree that a regional and/or national approach to delivering community benefits would be an appropriate way to address geographical dispersal of development and multiple communities?).
This could potentially allow the Scottish Government or local authorities to decide which communities, for example a particular regional or national faith or ethnic group, might benefit from CB, even if they lived in an urban area distant from the development.
The same applies with regard to questions relating to onshore “net zero energy” developments (section 3). We recommend ignoring the pro-net zero propaganda with which this section commences, and once more answering the questions narrowly. We have reservations about shared ownership or community-owned developments, given the need for expertise in terms of financing, the legal complexities of potentially very expensive liabilities and managing such projects over what may be lengthy timescales.
With regard to question 3.3.1 (a):
(Which of the following onshore technologies should be in scope for the Good Practice Principles?)
We believe all industrial scale renewable developments should provide CB, specifically: Wind, Solar, Hydro power, Hydrogen, Battery storage, Bio energy, Carbon capture and Electricity transmission. The ever-expanding raft of industrial-scale “net zero” developments plaguing the country all have the potential to cause considerable harm and distress to local communities, so we see no reason to exclude any of those listed in the question from the Good Practice Principles. That applies to the euphemistically-labelled Electricity Transmission, given the scale and environmental destruction that can be caused by all the proposed pylons and substations.
We believe that the same Good Practice Principles should apply in a standard way across all the technologies selected, rather than being different for different technologies, but we recognise and respect the fact that others may feel differently.
As for question 3.3.2:
(Do improvements need to be made to how eligible communities are identified? For example, changes to how communities are defined at a local level, and whether communities at a regional and/or national level could be eligible.)
we reiterate our view that ‘communities’ should be defined narrowly so as to include only those adversely affected by the developments in question.
One question in particular struck us as requiring a specific answer:
(What should the Good Practice Principles include on community benefit arrangements when the status of a new or operational energy project changes? For example, reviewing arrangements when a site is repowered or an extension is planned, or when a new project is developed or sold.)
We believe that communities should not be excluded from further benefits if a project is sold or re-powered. Re-powering invariably results in a different wind site footprint, usually with bigger, more powerful turbines with new and deeper foundations with new turbines often requiring aviation lighting,more and larger solar panels, installation of industrial scale BESS, etc. Such changes should be treated as new applications, with the implication that fresh community benefits should then be triggered.
Another question is certainly pertinent, given the tsunami of applications to which Scotland is currently being subjected, and their potentially overlapping nature:
(Should the Good Practice Principles provide direction on coordinating community benefit arrangements from multiple developments in the same or overlapping geographic area? If so, what could this include?).
We think the answer to the first part of this question is very firmly in the affirmative provided the communities local to and affected by the developments have a final say on how CB is to be used and distributed in their area The answer to the second part may vary from respondent to respondent.
Question 3.3.3. asks about setting a funding benchmark:
(Do you think that the Good Practice Principles should continue to recommend a benchmark value for community benefit funding? The current guidance recommends £5,000 per installed megawatt per year, index-linked (Consumer Price Index) for the operational lifetime of the energy project).
We think that a benchmark should continue to be set, but at a much higher level. We reluctantly recognise that indexation by reference to the Consumer Price Index (CPI) is likely to remain the case, given that the Contracts for Difference (CfD) regime currently adopts that index. However, we would answer to the effect that should the CfD regime at any stage adopt the Retail Price Index (RPI) for indexation purposes, then at that stage RPI should also apply automatically to indexation of community benefits.To ensure that CB payments incorporate rises commensurate with the CPI, there should be a minimal five yearly review, as occurs with section 75 agreements between local authorities and developers to maintain site restoration bonds at appropriate financial levels.
In the above notes we have touched only on the questions that we feel should most urgently be answered, but please respond to all questions that are of concern to you. Please note that the Scottish Government requests that responses be via the following website link:
https://consult.gov.scot/offshore-wind-directorate/community-benefits-net-zero-energy-developments/
However, if that is inconvenient, then responses can also be emailed to communitybenefitsconsultation@gov.scot
Alternatively, the postal address may be utilised:
Community Benefits
Offshore Wind Directorate
Scottish Government
5th Floor
5 Atlantic Quay
150 Broomielaw
Glasgow
G2 8LU
Don’t forget – the deadline for responses is 11th April 2025.
0 Comments