The RTPI champions the power of planning in creating prosperous places and vibrant communities. As learned society, we use our expertise and research to bring evidence and thought leadership to shape planning policies and thinking. As a professional body, we have over 27,000 members across all sectors, and are responsible for setting formal standards for planning practice and education.
Note: This is a response from RTPI England and RTPI Scotland.
Principle
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Do you agree with the principle that developers must provide community benefit funds? Please explain why/why not.
We are in favour of the principle of mandatory community benefits. Community benefits are a way to ensure that communities share in the social, environmental and economic benefits of low carbon energy infrastructure projects.
Furthermore, community benefit funds should improve community engagement and result in positive long-term relationships between communities and developers.
Any community benefits approach should have a degree of inbuilt flexibility to reflect the fact that all communities are different. An overly mandated prescriptive approach could undermine schemes.
The RTPI notes that the recently published Onshore Wind Taskforce Strategy includes an announcement that the Government will publish an update to the 2014 Community Benefits Protocol and formally adopt it as government guidance for England, for which the given date is June 2025. It is not clear if this timeline is correct, and how this Community Benefits Protocol interacts with any Government response to this working paper. Clarification would be welcomed on this point.
Scope
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Considering the policy parameters for the scope proposed above, what types of low carbon energy infrastructure should be included within the scope of the policy? Please provide your reasoning.
In principle, the RTPI is in favour of using community benefits across all renewable energy technologies to garner enhanced community support.
However, we appreciate that certain technologies are more advanced in utilising community benefits compared to others (while there are examples of community benefits being used for onshore wind, we are lacking in examples of their use for hydrogen projects). Different technologies will have different operating costs, and so different contribution values will emerge, and it is important that the policy parameters recognise this. To prevent duplication, storage technologies should be excluded where the same MWs are accounted for in generation technologies.
Nonetheless, it is our view that there are advantages in employing participatory engagement methods across renewable energy technologies. This will allow projects to reap the benefits of enhancing community knowledge about the technology, forming genuine partnerships, and delivering proposals that align with community aspirations for their place.
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What would be the impacts on specific low carbon energy infrastructure technologies of bringing them into the scope of this potential scheme?
No comment.
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Do you agree that there needs to be provision for amending the scope of the policy in future to ensure that it can be adapted to fit future technological changes, and remains in line with the criteria set out above? Please provide your reasoning.
Yes, there should be flexibility within the policy to allow it to be adapted to, if needed, for emerging and future technologies.
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Do you agree with the approach outlined for the provision of community benefits for co-located infrastructure? Please provide your reasoning.
Yes. It makes sense to minimise ambiguity and ensure consistency in approach for the treatment of in-scope technology. For co-located infrastructure, the community funds should be aggregated into a coordinated fund to make the process straightforward for communities and allow piecemeal funds to be compiled. This would better facilitate the use of the fund for larger and more complex projects, giving communities more options.
Thresholds
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Do you agree with the proposed mandatory community benefits threshold of 5MW for power generating and storage assets? Please provide your reasoning.
Yes, this seems appropriate, given it is in line with the threshold for Contracts for Difference eligibility. It also means that small community owned projects, who would struggle to afford contributions, are exempt. This is agreeable given they are intrinsically beneficial to communities.
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Should the threshold vary by technology in order to accommodate nascent technology (such as floating offshore wind)? Please provide your reasoning.
Probably. While a consistent approach is appreciated, different technologies will have different capacities and differing outputs, and a single threshold could financially disadvantage some technologies.
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How should shared ownership arrangements interact with any mandated community benefit fund contributions?
The RTPI is in favour of encouraging and enabling shared ownership of energy infrastructure, but there is however a risk that too much crossover of community benefit funds and shared ownership might confuse stakeholders and those who want to get involved with projects.
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Are there any project types that should be exempt from a potential mandatory community benefits scheme?
Exemptions should apply for offshore projects which are sufficiently geographically isolated that identifying a community is impossible.
Level of benefit
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For those developers already offering community benefits on a voluntary basis, how are these funded?
No comment.
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Recognising the need for flexibility, are there any impacts or considerations of funding community-led projects that should be taken into account?
No comment.
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Do you foresee any challenges for developers to fund mandatory community benefits? Does this differ between technologies?
No comment.
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How can significantly larger community funds be best managed (requirements to use regional funds, introduction of a cap on funding, limit on cap duration)?
Without a clear mechanism, the accumulation of funds could lead to political arguments that delay the delivery of benefits to communities.
Decisions around the use of community funds could be plan-led. There is an opportunity for local development plans (LDPs), neighbourhood plans or local place plans to establish the needs of a community and the infrastructure required to turn the community vision into a reality. There is also the potential for forthcoming spatial development strategies to direct community benefit towards larger, sub-regional, long-term .
At the same time, it is important that the community benefit funds are used in a way that best serves the community, in the way that they choose, and we are aware that there will need to be a balance between competing interests in this regard. The independent fund administrator, in conjunction with a group of local people, could sufficiently balance all the different actors involved, to ensure the best possible outcome.
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Do you have a preference for either of the proposed methods for calculating the level of contribution payable in respect of energy generating stations (i.e. by reference to either installed capacity or generation output)? Are there any further considerations relating to either option which require exploration?
No comment.
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Do you agree with the principles of seeking to enable combining funds and utilising regional funds?
Yes, with the consent of communities receiving the funds.
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Do you agree with the outline proposals for a) when payments apply, b) index-linking, c) changes to project lifespan/capacity/ownership, and d) suspension of payments?
We agree for the proposals for (a), (b), (c), and (d).
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Do you agree with the proposals to place the developer obligations for community benefits on the relevant licence-holder (e.g. a licence for generation of electricity under the Electricity Act 1989)? Are there any further considerations that should be taken into account regarding ownership and change of project ownership?
Yes. It is important for community benefits to remain in place regardless of who owns the site. If the owner of a project does change, they need to re-engage with the community, so the community are made aware of the owner change.
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Are there any other aspects on funding that should be considered?
No comment.
Use of funds
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Do you agree or disagree that we should not produce prescriptive guidance on what the fund can be used for? Are there any other factors that should be considered?
We believe that there should be guidance produced on how the fund should be used, but this does not need to be prescriptive. The guidance should include clear examples of appropriate and non-appropriate uses, but overly prescriptive guidance could stifle innovation approaches.
Any guidance produced for the use of funds should establish a clear and robust set of principles that underline the overall purpose of the benefits fund. It should be made clear what is not an appropriate use of funds, with examples.
If it is the responsibility of individual communities working with fund administrators and developers, there needs to be clear guidance set out for communities so they are aware of what the benefit fund can be used for. The fund administrator should serve as an impartial expert seeking to achieve the best outcomes for the community. There should be an obligation on the fund administrator to justify the decisions behind how the fund will be used.
Administration
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Do you agree with the suggested roles and responsibilities defined for the developer, fund administrator, administrative body, community representatives and community, and with the proposed governance structure? Would you suggest any amendments?
Yes, we feel that the suggested roles, responsibilities and governance structures are appropriate. It is important that the governance structures are robust and transparent, with clearly defined roles and accountability embedded from the start.
We are strongly in favour of a community benefits register and feel that this should be public and open access. This would help communities easily see what other projects are taking place and improve transparency across the entire process.
Given how important the fund administrator role is, and how they represent multiple interests and community engagement, it is vitally important that the government provides further details on what kind of oversight and accountability is in place regarding the decisions taken by the administrator.
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Do you agree that some flexibility in the governance structure is needed? If yes, do you think that the suggested ‘truncated’ governance approach would adequately capture and reflect the needs of smaller funds or communities with less capacity?
We understand the need for flexibility in governance structures where there are smaller funds and where administrative costs could be overly burdensome. Where an in-house fund administrator is appointed by developers, there should be sufficient oversight at a national level to ensure that the process is functioning correctly, and that communities’ views and best interests are sufficiently represented.
Equally, where communities have limited capacity to engage in the scheme, there should be a mechanism by which the role of the fund administrator is regulated and accountable, to ensure that communities are not penalised by a lack of experience or resources.
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Do you agree with the proposed approach to the decision-making process?
We agree with the principle of an outcomes-based approach to engagement, rather than a prescriptive process that could become a box-ticking exercise. Flexibility in approach makes sense, but it is important that guidance around decision-making represents best practice in engagement and encourages early, comprehensive engagement to empower and involve communities.
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Do you agree with the deadline of one year before payment is due for having governance structures in place?
Yes, this seems appropriate.
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What would be an appropriate cap on spending from the fund for administrative functions? What costs can you anticipate the fund structure would entail? What costs have you incurred in setting up voluntary schemes? Do you think we should set out a sliding scale for larger projects?
No comment.
Enforcement
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Do you agree with the suggested approach to enforcement of this potential scheme? To what extent do you think the enforcement mechanism outlined above is appropriate and proportionate for this potential scheme? What other details could be considered?
We agree with the chosen enforcement principles and consider that they would underpin a robust and proportionate enforcement regime. We agree that any enforcement regime should not inadvertently inhibit new projects coming forward.
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Do you agree with the proposed chain for dispute resolution between communities and administrators? Is the proposed escalating chain for resolving disputes appropriate and proportionate? Do you think we should include any more specific instances or reasons for enforcement action to ensure the robustness of the scheme?
Yes, the proposed escalating chain seems appropriate and proportionate.
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Should consideration be given to imposing any of the proposed enforcement actions on other persons or groups under the scheme? Please provide your reasoning.
We agree that that imposing penalties on the community would not be appropriate under the requirements of the scheme, and contracts should be utilised to help safeguard against individual actors seeking to exploit schemes. It makes sense to keep the scheme under review, with scope to strengthen enforcement powers if evidence of widespread non-compliance comes forward.
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What do respondents think would be a practical use for any additional revenue generated from civil penalties?
No comment.
Defining communities
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Do you think a case-by-case approach to defining the community is appropriate? Are there any other bodies or groups not listed above that should be part of the engagement process for determining eligibility?
A case-by-case approach is probably most appropriate to determine the extent of the ‘community’, as long as there is sufficient guidance and the work of defining the community is informed by best practice. We agree with the consultation paper that flexibility is key to ensure maximum opportunity for communities to be captured considering the geographic scale of the project.
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Do you agree that capacity building will be required in communities? What do you believe this should look like and who do you believe is best equipped to carry this out? Please provide reasons for your answers.
Yes, capacity building should be required in communities to ensure that communities are sufficiently informed and can be fully engaged in the process. Particular attention should focus on those lower income and disadvantaged sections of local communities, and those who typically lack the time or resources to engage with projects like this. The government should clarify how these harder-to-reach sections of the population will be engaged.
There should be suitable standards set out that can be applied to projects to allow communities to meaningfully engage with a project. The aim should be for developers and fund administrators to initiate engagement as early as possible, and this should include the greater use of participatory approaches at the ‘options’ stage of project development to facilitate a genuine and meaningful partnership between developers and communities. Rather than being given an opportunity to comment on already-established proposals, communities would be empowered to articulate their needs and shape the options for projects coming forward before proposals are set in stone. This is vital to ensure that community benefits achieve their intended purpose.
The Scottish Government have established a Community and Renewable Energy Schemes (CARES) that supports communities to engage with and participate in local energy projects. CARES provides advice, funding, and support to community groups, charities, and other eligible organisations. Ultimately, nothing can replace working with communities and helping them create a plan for how they want the community benefit fund to work for them. Investment in community capacity would reap benefits across planning as a whole, by improving engagement with the system and improving knowledge among local communities.
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Do you agree that capacity building and engagement should be funded by the community benefit fund administration budget? What do you believe should be done in cases where the administrative cost of capacity building and engagement initiatives are too costly for smaller-scale projects?
No comment.
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Do you agree community engagement should be led by the fund administrator? Do you believe our proposals have any unfair impacts on those with protected characteristics? If yes, which groups do you expect would be specifically impacted? Please provide supporting evidence.
Community engagement should be done at as early stage as possible, ensuring meaningful engagement with communities and the building of a relationship between them and the project developers. There should be clear guidance that details the principles underpinning proper engagement and the outcomes that good engagement would achieve.
Shared ownership
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Are you aware of evidence which suggests that shared ownership has or has not delivered the benefits referred to above?
No comment.
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Are you aware of any evidence to support other benefits of shared ownership for either communities and/or developers?
Scotland has encouraged shared ownership projects in national policy, guided by the Good Practice Principles. The Crossdykes Wind Farm is an example where a community had a stake in a large-scale, subsidy-free wind farm which provided ongoing benefits to the local area. The community used funding delivered through CARES (see q.30), negotiated with the developer, and when the wind farm was sold, the community received significant profits that can then be reinvested into further community projects.
In Scotland, the Good Practice Principles is the mechanism by which standards for all renewable energy proposals are set out. Ideally, they allow communities to meaningfully engage with proposals, and allow for early, meaningful and widespread engagement, focussed on outcomes, rather than a tick-box exercise which may or may not achieve a positive outcome for communities. An outcomes-based approach would help to ensure that developers proactively engage with hard-to-reach groups (including youth, the elderly, time-poor, those who lack internet, non-English speakers, those with poor literacy etc.), and to help ensure greater use of participatory approaches at the ‘options’ stage of project development.
We believe this approach is more likely to bring about a genuine and meaningful partnership between renewable energy operators and communities and better empower communities to articulate their needs and shape the options for projects coming forward before proposals are set in stone.
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Are you aware of any risks arising from encouraging shared ownership schemes?
Shared ownership relies on community capacity and capability to engage with the project in a meaningful way. As the paper acknowledges, there needs to be more done to build up skills and capacity to help this function effectively.
Additionally, shared ownership schemes require local people to have a financial stake in the project. There are inherent risks in this, and any return on investment may not meet the expectations of investors.
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What are the barriers to shared ownership in Great Britain?
The barriers to shared ownership in Great Britain include a lack of awareness, and lack of community expertise, capacity, and resources. Communities need to be made more aware about the option of shared ownership projects and the potential benefits they can bring. Many lack the necessary expertise to engage in these types of projects. For those that can, assurances are needed that opportunities will be available, so they can engage with projects in confidence. Well-informed communities who can participate more effectively in shared ownership projects leads to a smoother process for developers too.
From the developer side, there can be a reluctance to engage in shared ownership schemes where it is considered that they might increase risk and uncertainty or delay projects. Additional incentives might be required as many developers are unfamiliar with the process and are not incentivised to offer shared ownership options to local communities.
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Do certain communities face barriers to shared ownership more so than others? If so, how and/or why?
Those communities lacking in time, expertise, and available funding will face the biggest barriers to shared ownership, as they will not typically be able to engage with the process in the most meaningful way, and engagement is less likely to take place where community engagement is considered particularly difficult or onerous.
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How can government ensure that low-income communities, or those experiencing higher rates of fuel poverty, are able to engage with shared ownership offers?
By working to improve capacity and expertise within communities, by setting standards for meaningful, outcomes-focussed engagement underpinned by robust principles, and by supporting low-carbon shared ownership projects.
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Do certain developers and/or particular sectors face barriers to shared ownership more so than others? If so, how and/or why?
The shared ownership model can be difficult to apply to linear infrastructure projects because of the number of affected communities.
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Does a particular barrier represent more of a barrier to shared ownership than others? If so, which and how?
Awareness, for both communities and developers, of the process and benefits of a shared ownership approach is one of the biggest barriers currently, along with access to affordable capital for communities and appropriate financial and legal advice.
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What actions can the government take to address these barriers and promote further uptake of shared ownership, particularly in England?
The government can engage with communities and developers, set clear guidance and principles for the operation of shared ownership schemes, and incentivise developers to get involved with these types of projects.
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How successful has a voluntary approach to shared ownership been? Should the government continue with a voluntary approach or consider expanding shared ownership, possibly via a requirement for developers to offer shared ownership to eligible communities?
No comment.
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If shared ownership is expanded, should regulations be made in accordance with the existing provisions relating to the ‘Community Electricity Right’ in the 2015 Act? If you consider that amendments should be made to the scope of the existing provisions, what changes should be made and why?
No comment.
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If shared ownership is expanded, how will communities and developers need to be supported for a mandatory shared ownership scheme to be successful?
As we have mentioned elsewhere in our response, there will need to be robust, clear guidance that is not overly prescriptive. Communities and developers need to buy into the vision of the project, and both must be convinced that the benefits are worth the effort of engaging in a meaningful partnership.
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If shared ownership is expanded, should there be exemptions to the expansion?
No comment.
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If shared ownership is expanded, how should developers’ engagement with communities take place?
Given the risk of poorly implemented projects weakening public support, there is an opportunity to examine the hierarchy of community engagement. Proactive engagement can frontload the decision-making for renewable energy schemes, increase community and local authority support, and in turn deliver enhanced industry certainty by reducing the risk of consenting delays.
Good
At the minimum, developers should ensure traditional consultation is conducted effectively. Engaging with communities at the onset of projects is particularly crucial to ensure consultation is beneficial to all stakeholders.
Consultation should also incorporate multiple modes of communication to reach the diverse spectrum of society. Although there has been a transition to online methods of engagement, these should not replace face-to-face engagement, which is proven to strengthen trust. A hybrid approach would be most welcome. Maintaining communication channels to respond to feedback following consultation is also vital.
Nevertheless, there is a risk of consultation becoming a ‘box ticking-exercise,’ especially in the absence of specific standards for engagement. The RTPI therefore recommends that policymakers set outcomes-based standards for community engagement which require developers to engage with a minimum number of people who comprise a representative sample of the community affected by their proposals.
Better
Where commercial developers are present in projects, participatory approaches at the ‘options’ stage of development offer an improvement on standard consultation. Research has confirmed the importance of communities being involved from the project development stage, as opposed to being presented with a finalised concept. In a genuine partnership, those impacted must be able to shape the options for projects coming forward before proposals are set in stone.
For example, the developer of an extension of the Berry Burn Wind Farm in Moray, Scotland liaised with the community in the options stage of the development and revised proposals in response to feedback around improving biodiversity within the site to repair damage caused by wildfires and to mitigate the risk of future ones.
Promising approaches has been trialled by the Centre for Sustainable Energy and the Campaign to Protect Rural England which involved conducting workshops that enabled communities to collectively determine where to appropriately integrate renewable energy into their local landscapes.
Planning guidance should make clear that developers should demonstrate that they have provided opportunities for participatory engagement at the ‘options’ stage of development.
Best
Shared ownership, which enables communities to become a financial and/or development partner in renewable energy projects and receive a share of future profits, provides a deeper level of community involvement that complements participatory approaches to engagement. This model empowers communities to directly shape projects and have a stake in their future, which fundamentally changes the power relations between developers and communities.
One example of how participatory engagement has worked well in practice elsewhere is the French ‘Commission Nationale du Débat Public’ (CNDP). This state-sponsored public body is tasked with promoting genuine engagement around project options. The CNDP approach emerged in response to severe public opposition to previous state infrastructure projects and was originally focused on major and contentious projects. It is increasingly being adapted, however, to renewable energy. CNDP public debates take place before a project has been planned in detail and provide the local community with direct input into the principle and location of development. Evidence indicates that this model has reduced local opposition to strategically important infrastructure projects and has improved the ability of communities to shape decisions affecting them.
To this end, the RTPI is pleased that the Onshore Wind Taskforce Strategy included an announcement that the Government will formally embed best practice principles of engagement into planning guidance in England. We eagerly await further details of this guidance and hope it will reflect the principles we have set out above.
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Are you aware of any risks or potential adverse impacts arising from expanding shared ownership either in line with the 2015 Act provisions or otherwise?
No comment.
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