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

Scottish Government Good Practice Principles for Shared Ownership of Onshore Renewable Energy Developments

2.1 Do you consider that the revised Good Practice Principles (GPPs) offers clear and practical guidance that will support the delivery of successful shared ownership schemes in Scotland?

Key Figures

• 38 responses (80.9%) were received for this question 
• 25 comments obtained from respondents

	Yes	No	Don’t Know	Not Answered
Community groups (5)	1	-	2	2
Local Authorities and other public sector (6)	3	1	-	2
Trade bodies and interest groups (7)	2	-	4	1
Renewables industry (18)	9	3	2	4
Others (4)	2	1	1	-
Individuals (7)	4	3	-	-
Total	21	8	9	9

Summary 

55.2% of respondents, including half of all renewable energy industry respondents, believed that the GPPs offered clear and practical guidance regarding shared ownership schemes in Scotland.

Many respondents agreed that the revised GPPs were both reasonable and practical. 

However, a number of areas of potential improvement were highlighted, including further promoting liaison with other community groups who have experienced shared ownership, and perceptions around the language in the GPPs being too technical.

Similar to the responses received regarding Community Benefits, a number of respondents who selected “No” felt that, as the GPPs are voluntary, they are open to abuse. 

Also, further parallels can be drawn to comments make in the Community Benefits section around the need to explore how there can be greater involvement of local authorities.

Developers also raised concerns around the changing energy landscape in the UK – particularly as there are changes to subsidies offered by the UK Government which could impact the financial viability of projects.

Although 23.7% of respondents stated “Don’t Know” in their response, further comments were submitted from trade bodies and interest groups. 

Representatives from various associations believed that the guidance did not provide enough support for certain groups in particular, such as:

• Coastal communities
• Fishing communities
• Landowners
• Private businesses

2.2 Do you consider that the revised GPPs includes sufficient detail on the investment risk?

Key Figures

• 37 responses (78.7%) were received for this question 
• 27 comments obtained from respondents

	Yes	No	Don’t Know	Not Answered
Community groups (5)	-	1	2	2
Local Authorities and other public sector (6)	1	2	1	2
Trade bodies and interest groups (7)	-	3	3	1
Renewables industry (18)	5	7	1	5
Others (4)	1	2	1	-
Individuals (7)	1	4	2	-
Total	8	19	10	10

Summary 

The above table demonstrates that over half of respondents (51.3%) believed that there was insufficient investment risk detail.

The comments provided from those who chose “No” were consistent amongst individuals, interest groups and community groups: that the GPPs did not provide enough information surrounding investment risks, and communities must have the ability to fully understand the financial risks surrounding shared ownership before pursuing the matter further.

The general consensus amongst renewable energy developers who said “No” was the need to ensure that communities are aware of the risks of shared ownership from the outset also (i.e. within the GPPs), while also raising separate concerns over whether or not the closure of UK Government subsidies would prevent shared ownership schemes from being financially viable in the future.

This is in contrast to the developers who selected “Yes”, where the feedback received recognised that the GPPs cannot cover all potential types of investment risk – but provided enough detail on the subject matter. 

2.3 The revised GPPs now includes a section on a Typical Shared Ownership Journey. Is there any additional details that you consider should be included?

Key Figures

• 37 responses (78.7%) were received for this question 
• 24 comments obtained from respondents

	Yes	No	Don’t Know	Not Answered
Community groups (5)	1	-	2	2
Local Authorities and other public sector (6)	-	3	-	3
Trade bodies and interest groups (7)	4	-	2	1
Renewables industry (18)	11	1	2	4
Others (4)	2	-	2	-
Individuals (7)	1	4	2	-
Total	19	8	10	10

Summary 

Over half of respondents (51.3%) believed that further information could be input into the Scottish Government’s Typical Shared Ownership Journey.

The comments received varied from group to group, and a brief overview of the key points raised are as follows:

• There was agreement between a number of trade bodies/ interest groups for the need of more case studies from previous, successful shared ownership schemes – as well as greater engagement with the communities involved in these examples.
• A request for greater detail within the Journey for the benefit of community groups, in particular, was noted.
• Different groups objected to the terminology around this being a “typical journey”, as what would be entailed within the shared ownership process varies from project to project. 

In addition to the above, a number of developers provided input regarding potential adjustments to be made to the Journey, while also raising concerns about the management of community expectations around:

• The timescales provided – and the need to stress that there are indicative.
• The timing of investment payback periods (particularly for future, subsidy-free projects).

Finally, a small number of comments were received by those who said “No” and “Not Answered”, which concerned minor adjustments to the formatting and terminology of the Journey.

2.4 It is the intention to amend the guidance on a regular basis to ensure it reflects changes to policy and/ or other relevant issues. How frequently do you consider this should happen?

Key Figures

• 39 responses (82.9%) were received for this question 
• 25 comments obtained from respondents

	Annually	Every 2 years	Other time period	Not Answered
Community groups (5)	2	2	-	1
Local Authorities and other public sector (6)	-	3	1	2
Trade bodies and interest groups (7)	4	2	-	1
Renewables industry (18)	2	5	7	4
Others (4)	1	1	2	-
Individuals (7)	4	3	-	-
Total	13	16	10	8

Summary 

As the above table shows, “Every 2 years” was the most popular choice from respondents (41%). 

A number of respondents who opted for this time period, from a mixture of backgrounds, believed that the GPPs should be reviewed more often but the actual amendments should be 2 yearly to reduce the administrative burden.

Furthermore, multiple organisations felt it would be beneficial for renewable energy developers to be involved during the review process.

Of those respondents who suggested “Annually” (33.3%), the comments provided suggest a split between those who feel it is important to consider the GPPs each year to ensure they remain relevant compared to respondents who believed they should be reviewed annually (but not amended) every year initially – then change to every second year.

This is similar to those who selected “Other time period” – where there was a general consensus that the Scottish Government should review annually but make amendments (where required) anywhere between every 2 to 5 years. 

Concerns were raised about having reviews and amendments too often, as this could place an unnecessary burden on parties involved.

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

Key Figures

• 26 comments obtained from respondents

Summary 

The majority of comments received were from renewable energy developers. However, some additional points were made by other groups, including:

• Ensuring that communities are not pushed towards the idea of shared ownership by those with vested interests.
• Ensuring everyone in the community has a voice and that no one is left behind.

With regards to the responses from developers, while there was general support for the GPPs and feedback surrounding minor language and terminology changes, a number of developers also raised either new concerns or took the opportunity to reinforce previous comments made.

For example, planning was noted as a key issue - with some developers arguing that, if a developer has offered a shared ownership opportunity to a community, then this should be taken into account during planning process. 

However, others were keen to stress that some form of shared ownership should not be mandated in order to gain planning approval.

There was also a view, which was common across a number of developers, that shared ownership should be part of wider-community benefit package offered to communities. 

Other key points raised by developers are summarised below: 

• Other developers raised the belief that shared ownership was being promoted within the renewables industry, but not other industries.
• The necessity to include developers during the review of the GPPs.
• The need to ensure the GPPs remain flexible.
• How shared ownership, through administrative and other associated costs, could impact on the financial viability of a project.
• The potential for local authorities to be involved, where communities do not have the capacity of interest in shared ownership.