15 May 2026
Refreshing the Good Practice Principles for Community Benefits from Onshore Renewable Energy – a Working Paper
GDT is responding to this consultation from the perspective of a well-established and
successful community organisation, which has been making decisions about the distribution of wind farm community benefit funds since 2018, ably supported by Foundation Scotland as our fund administrator.
In preparing these responses we also consulted our Members (eight Community Councils)
and Associate Members (local residents and organisations) at our recent Annual General
Meeting.
We made detailed responses to the earlier consultation and participated in various groups.
Our Chair has also been part of the RAG. We have therefore kept this response brief as we
feel we have through these avenues contributed to the issues covered in this Paper.
Dealing with the specific sections:-
Section 1- Technologies in scope and co-location
We have nothing to add to the proposals on the technologies in scope.
On co-location we support the recommendation that developers should engage with each
other and local communities and should agree to a pooled benefit fund. Underpinning the
achievement of this objective is the need for developers to do effective due diligence and
engagement and to understand what is happening in an area. In addition, communities
should be encouraged and supported to provide a common front to developers to make the framework for engagement more efficient for all. This requires time and resource which is covered in the section 4.
Section 2 – Fund Levels
While we recognise the superficial attractiveness of increased levels and the rationale that
these base levels have not increased, we feel it is premature to comment until the outcome of the DESNZ consultation on mandating of community benefit arrangements is known. The costs of community benefit arrangements are ultimately borne by the end consumer of electricity so this needs to be considered in addressing the amount.
While we recognise that the needs and maturity of different communities will be very
different, we would prefer to put our efforts into discussing how the monies can be used
flexibly, whether we can draw down early, how we get early certainty on the quantum and
profile of payments rather than seek additional monies. We support technology specific fund levels and are not supportive of any type of profit share.
Section 3 – Governance and Distribution
We support the proposals to have a clear local-first approach and alignment with community plans. We also recognise the need for arrangements to evolve over time as the
arrangements mature and the community need changes. We set out our rationale for this in in our response to the initial consultation.
We support the proposal on separating decision making and fund administration. As well as addressing independence and conflicts of interest it also provides a more resilient
governance framework given the long-term nature of these arrangements. It is mainly
volunteers who are involved in this work in a community and good governance needs these individuals to change over time. In addition, individuals do not want to be unable to step down if they want to. Having separate, paid for, fund administration facilitates change in volunteers while ensuring that the collective memory is not lost.
As set out, good communication and transparency is key to building trust and confidence.
However, it can be time consuming for communities and the volunteers involved to do this as well as all the other tasks involved in decision making and monitoring etc. Developers and other professionals also need to recognise that communication from the community may not always be as effective as they would like, not because of a lack of willingness but due to a lack of volunteers' time or resources. Supporting community organisations' ability to communicate in a timely and effective way needs to be considered in the resources required. On Indicators we would encourage flexibility as the needs of communities and their maturity will impact on what they need.
Tools and templates will be useful but, to enhance these, access to support, as set out in
Section 4, may also be useful, particularly if these issues are new in a community.
On governance structure this document sets out the options and the minimum expectations are helpful. On 3. Independent and fair decision making it would be useful if the new GPPs set out clearly the benefits of a third-party fund administration model. This should cover the points in this principle but also the points set out above on the desirability of separating administration and decision making, ensuring continuity etc.
In deciding what legal incorporation is suitable it may be useful for there to be a checklist of questions for a community to consider before making a decision on what is appropriate.
Each of the different models have their pros and cons and finding the most appropriate legal model needs early thinking and guidance. For example, here are some early issues to consider: -
Is the entity to be a charity?
Who are Members? For us we have Community Councils in our area of benefit as
Members as we wanted to have a link back to democratically elected bodies.
Are there different categories of membership? We, as well as the Community
Council Members have Associate Members, who can be organisations/individuals in
the area. The only difference between them and the members is that Associate
Members do not have a vote at a General Meeting. We decided on having this
category of members to enhance our accountability to our local community while at
the same time not eroding the link with Community Councils.
How are trustees/directors appointed? Our Community Councils appoint Trustees,
and these Trustees can appoint up to five additional independent Trustees. The
Chair must be an Independent Trustee. This gives us the ability to ensure we have
all the necessary skills within our trustee group.
The local-first approach is welcomed as it keeps the local community at the heart of the
decision making on utilisation of funds. We also welcome encouragement of pooled funds,
early engagement and regular reviews. Key in this approach will be good and effective due
diligence by developers and effective long term engagement to understand how a
community works, lives and plays together and to take this into account in defining an Area
of Benefit. In drafting the amended GPPs you may want to consider whether there is a
toolkit/ some best practice examples to encourage developers to work with communities and with each other to do this work. This could also encompass working with transmission
owners who have their own community benefit framework, but where their works are often
inter-related and inter-dependent. Transmission Owners have recently signed up to a set of
Principles https://sustainabilityfirst.org.uk/wp-content/uploads/2026/01/Transmission-
Owners-Principles-for-Effective-Engagement_Final.pdf
You should also ensure that you do not inadvertently draft the local first approach in a
potentially restrictive way. ‘Local community’ could be misconstrued and interpreted solely
as the host Community Council. As we have set out previously, Community Council
boundaries often are quirks of history and therefore do not reflect how a current community lives. In addition, the direct transport and visual impact can cover an area which does not simply correspond to the host community council boundary.
Developers should be required to do the due diligence mentioned above to understand the community and to work together to maximise the outputs that can be achieved. They need to encourage and support community cohesiveness and not inadvertently cause division by picking unilateral boundaries.
Section 4- Supporting Communities
We welcome the clear recognition of the need for enhanced support. This can be a daunting topic for all involved to navigate and access to trusted support is critical. We have found, as we have developed over the last eight years, that sometimes it can be tricky to know who shares our interests and objectives and can give impartial advice We have always felt comfortable with Foundation Scotland as they shared our objective to keep the community at the heart of the decision making, but for other organisations it has sometimes felt that they have not shared this focus. It is important that communities can access support and guidance as they need it and have the resources/funding to enable this. Groups need to be free to choose who they feel best meets their needs rather than be required to use an externally determined organisation.
A common theme in this response is that communities are all at different stages on their
journey and this needs to be considered. Communities may lack experience on this topic
initially, but they usually have, collectively, a myriad of other skills and life experiences that
mean they can quickly grasp the issues and find solutions, so we do want to be treated as
partners in any arrangements. We do need access to paid for support to enable us to build
good foundations. Putting funding into this initial stage will help build more resilient and
effective organisations in the longer term.
More checklists and toolkits, while useful, are not necessarily the best answer as they
themselves may make the task appear more daunting. The concept of a Forum is
welcomed as a means to share experiences.
Development support and expertise is a key component of success. A good Community
Action Plan and then a focus on how this is delivered is much more likely to lead to
successful outcomes. The governance arrangements for a development officer and who
they report to is a critical issue to think through early. In the early stages for example would
it be better to use an organisation to provide this support rather than appoint an individual? We certainly found this. In drafting the GPP you should enable this flexibility. Key is giving a community access to funding to enable this work to be done rather than setting out a defined solution. Any resource needs to be firmly embedded in and trusted by their community if they are to achieve their best and community outcomes are to be delivered. Simply having the resource without this clarity will lead to confusion.