Public engagement for sub-20MW wind turbine proposals – good practice guidance

6. Recommendations for developers and landowners

6.1 Developers or landowners can assist in keeping neighbouring properties or landowners informed of their development proposals prior to the submission of a planning application. Prospective developers can facilitate appropriate public participation as early as possible when designing and planning wind energy developments. This will benefit not only the local community but also the developers. This could be viewed as a component of effective project planning and development. Any form of engagement should be proportionate, tailored to differing scales of development.

6.2 The scale of development should help to determine the type and appropriate level of engagement that would be appropriate.

1. For smaller developments (generally 50m or less to tip height) it may be helpful for developers to produce a leaflet/flyer with information which can be distributed to properties or handed out to stakeholders. Alternatively posters can be used to advertise an application for example within a local post office, shop, community hall, library or other facilities well used by the community.

2. For larger-scaled developments, or where proposals might affect a city, town or village, it may be more suitable to engage the wider community. For example by organising a public event where a larger representation of a community can be engaged with and where people can ask questions of a particular proposal. Regardless of scale, developers should be able to provide the following details clearly to stakeholders on their development proposals:

i. the proposed location using a map or aerial image to provide context;
ii. an image providing an accurate representation of what the proposed development will look like;
iii. details of the proposed turbine height (to both hub and blade tip in meters) and the generating capacity of the development (in kW or MW);
iv. a plan that identifies the zone of theoretical visibility ( ZTV) of the development;
v. where further information on the development can be obtained from;

3. In order to aid the planning authority in its assessment of the proposals, it would be helpful for a developer to identify what, if any, engagement it has carried out for the proposals.

6.3 Developers may wish to prepare and apply a coherent Engagement Plan in discussion with the relevant planning authorities. They should be open to allowing the public with opportunities to scrutinise and influence key aspects of the project, and be clear about how views will be taken into account. Developers could also consider whether or not it would be appropriate to offer a local financial stake in their project, as a matter of good practice and be open to this if it is desirable to the local community. ^[31]

6.4 Crucially, it would be helpful to be open to the possibility that public engagement could indicate that their approach or design can be modified or tailored to suit a particular local situation; to consider moving turbines; maintaining project capacity in a different location if achievable e.g. taking account of land ownership. Such discussions can potentially help to identify appropriate mitigation measures where necessary.

6.5 In the first instance, developers are encouraged to engage in pre-application discussions with planning authorities who will have information that could be useful in identifying local issues along with contacts for community groups and other key stakeholders. As a starting point, discussions can be held with every community council which the application site covers, and any community council which has a direct boundary with the application site, where appropriate. Consideration could also be given to circumstances where there are likely to be prominent or expansive views referred to in paragraph 5.9 of this guidance. Consideration of a development's likely Zone of Theoretical Visibility ( ZTV) coverage can aid in identifying such issues. A fair and transparent process can be used to identify the appropriate groups to consult - individual groups must not be selectively involved to the exclusion of hard-to-reach groups or individuals. Developers are encouraged to engage with all relevant community groups within an area, and in particular those residents who are likely to be most affected by the development. This will ensure that a broad range of views and opinions from the wider community is obtained.

Identifying geographic boundaries for public engagement

6.6 The scale and likely impact of a development will assist in determining how to define a proportionate and appropriate geographic context for engagement. For all forms of wind energy development, a starting point could be to give consideration to notifying and engaging with community groups and residents of those properties within at least 1km of the development. Recognising the wider impacts of larger wind farm developments (generally greater than 50m to tip height and/or developments with multiple wind turbines) can have, it may be appropriate to engage with the occupants of those properties within a 2km distance from the development. If applied, such approaches would be more consistent with other notifications and engagement practices, including CARES, and for larger developments reflect the consideration of visual impact and purpose of the 2km community separation distance set out in Scottish Planning Policy.

6.7 Further good practice principles exist for developers to use at their discretion in engagement for wind energy proposals. These are set out in other Scottish Government documents and are summarised below:

6.8 Using the boundary of the relevant community council(s) as a foundation, the following factors may also be incorporated to identify an appropriate geographical area. This is not a comprehensive checklist to be applied to every development. The number and nature of the factors selected will be dependent on the local context and developers' company policies. ^[34] Some issues to consider include:

• Proximity to site (perimeter/boundary may be dependent on scale of project)
  • Concentric circles may give a starting point for identifying an area of benefit. It may be useful to also consider ZTV coverage of the development to identify those areas that may be visually affected. Larger developments (greater than 50m in height and/or multiple turbines) should generally have a larger circle; and it may be more appropriate to give consideration to those properties within a 2km distance from the development. However, a concentric circle may pose challenges for example when this divides community councils; administrative boundaries should be respected in conjunction with other factors.
• Geography and topography
• Characteristics of development
  • Size, scale, siting and visibility of development
• Construction
  • The communities which will be affected in either the short-term or long-term by the construction of the development, e.g. access roads.
• Immediate / adjacent / surrounding postcode areas
  • Consult a map of local postcodes to identify appropriate area boundaries.
• Demographics - population density/spread
  • Be sensitive to any significant populations which may have been overlooked, for example in rural areas or where harder to reach groups exist such as gypsy / travellers or ethnic minority groups.
  • Local authorities normally have information that can aid such assessments to tailor appropriate consultation.
  • Consider the groups that are likely to be hard to reach because they may not want to engage and those that would like to engage but can't because of when / where events are planned. In the latter instance consider whether or not additional support and accessibility is required.
• Consider local authority policy/guidelines.
• • Acknowledge local authority policies or guidelines and discuss with the community in the consultation period if relevant.

Case study:

Vento ludens ltd. approached three community councils in the Moray Council area that had been identified through their initial community profiling stage. The community councils suggested including three further community councils in the Aberdeenshire Council area. vento ludens consequently included all six community councils in the consultation process. Through dialogue at public exhibitions and meetings, it was agreed by all that the initial three community councils were the most appropriate stakeholders, and discussions were progressed with these groups accordingly.

Identifying stakeholders and community characteristics

6.9 Once the developer has considered an appropriate geographical boundary for consultation, links can be explored and where possible developed with individuals and groups as listed below. ^[33]

6.10 These stakeholders can be invited to propose any other communities of place or communities of interest which they feel should be included in the process at this stage. The VOiCE community engagement tool helps identify all the relevant people with an interest, available at: http://www.scdc.org.uk/what/voice/. Reference should be made to the Scottish Government's Principles of Inclusive Communication document ^[34] .

6.11 Some community councils in certain areas may be under pressure to commit time and resource to engagement on a number of development proposals at any given time. Other community councils may not have resources or the necessary experience to engage with the wider community. This should be taken into account and addressed as appropriate following discussion with the relevant community council.

6.12 In the event there is no community council operating within an area, discussions with local authorities may help to establish any relevant community groups that may be active in a locality and could act as an alternative. Local Authority community council liaison officers will be a relevant contact in aiding this and early dialogue with them is encouraged.

6.13 Once appropriate contacts have been identified, these stakeholders could then be invited to form a contact group to take forward further discussions, or any other appropriate method of working together can be employed, for example community open days or events.

6.14 In addition to those listed above, some further factors for consideration in identifying the community include:

• Resources of communities
  • Recognise that some groups or individuals may require support to fully contribute to discussions. Reasonable efforts should be made to make consultation accessible to all e.g. consideration of providing translators if required and provide easy-read versions of documents, potentially for multiple language groups.
  • Some well-resourced communities may have established networks which can be utilised.
  • Consider the potential to set up community liaison groups ( CLGs) comprising residents and representatives to act as a forum for discussions about proposals and to act as a point of contact for information within communities themselves.
  • Some developers are known to staff and attend such groups and cover administrative costs, including venue hire, provision of a secretary and/or providing logistical support. In some rural areas it may be appropriate for developers to engage with crofting/grazing communities who generally receive 50% of the rental income from wind turbines on their land along with the land owner.
• Needs of communities
  • Existing action plans or similar which can be supported.
  • Community issues identified through other means.
• Other relevant stakeholder areas
  • The catchment area of any local schools
  • Travel to work areas

Methods for engagement

6.15 Developers can draw on a range of engagement methods and tailor to specific developments and communities. ^[35] The following non-exhaustive list aims to suggest some starting points for designing the consultation process.

Possible methods of facilitating dialogue include:

• Community drop-in session;
• Presence at local community event;
• Stakeholder forum/workshop;
• Telephone hotline;
• Workshops and focus groups,
• Web-based consultation;
• Meetings in homes;
• Street stalls;

Possible methods of providing information;

• Press releases;
• Community newsletters;
• Public meetings;
• Posters in public areas;
• Mail drops - Leaflet/flyer;
• Use of social media and internet;
• House visits;
• Information road show;
• Letter, email or telephone contact;
• Formal consultation documentation;
• Mobile exhibitions;
• Via community stakeholders such as community council representatives.

6.16 The process can continue after views have been gathered from the community. It is important that developers provide feedback on how and why points were or were not accepted and an on-going clear point of contact. They can also ensure that community groups are able to access relevant support within the developer's organisation and externally.

6.17 Information on development proposals should contain accurate details of the development proposal, naming key contacts for further information and identifying project timescales, including when the planning application is likely to be submitted to the local authority.

6.18 When the concept of and approach to community benefit is introduced, it should be made clear that it is independent of the planning process and is not a material consideration in deciding an application. This equally applies when developers consider it would be appropriate to offer a local financial stake in their project.

Case Study:

Scottish Power Renewables consulted on a site which straddled three local authority areas. A range of consultation methods was undertaken to engage groups throughout the region. Information was distributed through newsletters, mail drops and house visits to raise awareness of the project. The area had few active community councils and no local venues, so a mobile exhibition was used to reach individuals. Although a time consuming process, this successfully created strong relationships between the community and Scottish Power Renewables and the mobile exhibition gave the opportunity for the community to voice concerns.

6.19 Upon submission of a planning application to the planning authority, a summary of the community consultation that took place should be provided for that authority's consideration.