Onshore Wind, Call for Evidence, Part A – Community Engagement and Benefits Further evidence to support questionnaire November 2012 1 Onshore Wind, Call for Evidence, Part A – Community Engagement and Benefits Background BT welcomes this consultation. Where significant infrastructure development presents environmental issues, we agree that engaging with communities is essential to secure the delivery of such projects. Honest, transparent, constructive and open dialogue is required from all parties. BT is one of the UK’s top 10 electricity consumers, using over 2TWh every year. We now secure more than 50% of this electricity from renewable sources via our supplier. This electricity is purchased at wholesale market prices. Despite achieving an absolute reduction of 6.5% in consumption over the last three years, we have seen our electricity costs increase significantly over the last eight years and this is impacting our business. BT wants to secure longer term price certainty in our electricity supply, from low carbon sources. To do this BT has sought to develop electricity generation from renewable sources. BT has consent for two small wind farms and has land secured for others. We recognise that the development of wind farms is an uncertain process, with high investment risk. BT has progressed development in accordance with planning policies and worked hard to ‘design out’ and mitigate environmental impacts. However, local people often object to planning permission as they believe that the development is being imposed on their area without appropriate local benefit. We have been seeking a single approach that provides a consistent way to provide communities with greater benefits, with transparency and greater certainty at its heart. Delivering infrastructure to support national needs requires a common approach across Government, to provide consistent direction and policy certainty. Without this, capital will be diverted to more attractive markets. Specific Issues and response to consultation Community engagement Engagement with the silent majority of communities is difficult. We have used a combination of methods to engage with communities. Engagement has to ensure that representative views are gathered from across communities. Public meetings are rarely of value, while public exhibitions, one-to-one meetings, up-to-date web pages and social-media sites provide opportunities to engage across the age spectrum. We have engaged a specialist local community consultant on some developments and this has proved of significant benefit in developing trust. Community ownership Wind farms typically operate for 25 years. This presents an opportunity for communities to be less dependent on state support and to enhance their communities by securing long-term funding from a development. Access to finance, particularly for the development or consenting phase of projects, is a significant barrier that prevents most communities getting projects started. Clearly this is where development companies can lead and/or support communities, bringing expertise and finance to work with communities, gaining mutual advantage through project delivery. 2 In our experience, discussions of community ownership (collectively through a community organisation or individually as residents) have provided the most open and positive engagement with communities. However, joint ownership can present challenges and comes with risk or liability for owners. BT is supportive of the development of a standard legal model of community ownership to assist in delivering projects through financing and into operation. An excellent example of a full community ownership structure is presented by the Roseland Community Energy Trust in Derbyshire, which has submitted an application for a six turbine (c.12MW) wind farm, which will be owned for the benefit of the community (www.rcet.co.uk). Importantly this model does not rely on funding from individual local people but from corporate partners and other sources willing to invest. This element is essential if a wind farm is going to be delivered to benefit less affluent areas. Alternative models using cooperative ownership (such as Energy4All) are well established, allowing individuals in a community to invest in a wind farm and thus see a personal return. BT is supportive of both of these approaches and we suggest DECC considers both models further. Realising the benefits of wind farms We consider that the appropriate level of benefit is one that continues to provide a material benefit over the life of the wind farm. However, communities have a wide view on what is ‘appropriate’ and it is their view that is critical. More affluent communities have commented that £1k per annum per MW is ‘meaningless’, whereas other less affluent communities welcome the same sum. Local communities close to a wind farm are best placed to decide how money should best be spent and funds should be able to be ring-fenced for these areas. Benefits should be available to all individuals, homes, schools, community groups and SME businesses. We support an objective of leaving a positive low carbon legacy, which outlasts the wind farm itself. Community funding derived from the operation of the wind farm can be used to deliver energy and carbon reduction in local homes and businesses, through funding insulation, improved heating equipment, local education and training in wider sustainability issues. This approach would deliver a reduction in energy costs to each household or business, a permanent reduction in carbon and, importantly, a reduction in fuel poverty. However, as stated above, decisions on the use of local funds should be decided by communities. BT does not support the use of community funds to pay the electricity bills of local home owners. We consider that this would not encourage energy efficiency in homes and businesses. It could even encourage more profligate use of energy unless carefully implemented and supported with energy efficiency measures. Community benefits from wind farms are secured by legal agreement. This is often through the use of a Section 106 (in England) planning agreement. Community funds can also be secured through use of alternative legal structures. The developer (and wind-farm special project vehicle (SPV) where appropriate) can sign a legal agreement to provide community benefits into a ring-fenced fund managed by a community foundation or similar organisation. This approach has the added benefit of being able to attract match funding. Such agreements also allow greater flexibility of delivery and importantly, more locally focused delivery of benefits close to a wind farm, rather than benefits being spread across a whole council administrative area. This approach is often welcomed by local communities who value this greater independence. This approach should be considered further by DECC. 3 As community benefits are secured by legal agreements, the cost of secured community support must be allowable in the DECC costs model for Renewable Obligations (RO), and thus considered in Part B of this consultation. If the UK is to deliver its renewable energy targets, any reduction in the RO must be very carefully balanced with expectations of increases in community funding. Retention of business rates from wind farms by the hosting council is a significant positive approach to provide local benefits from wind farms. This approach should be applied to all operating wind farms from its inception and this adjustment to rates distribution should be applied as soon as possible. The BT example In consultation with communities, it is perhaps not surprising that BT is asked to improve broadband services in rural areas. BT is already investing significant sums to deliver the Government’s standard of 2Mbps. Through the Broadband Delivery UK (BDUK) programme we are seeking to work with Government and local authorities to deliver this speed of service to 90% of the population. This still leaves areas which are beyond economic reach. It is these rural areas where wind farms are often sited, presenting an opportunity to deliver improved broadband using funding from the wind farm, should communities wish this. Wind farms also typically require a service of around 2Mbps, enhancing this association. We have proposed this improvement for one of our potential sites with a positive response. The benefits of access to higher speed broadband are well established and thus this opportunity also provides a positive and lower carbon legacy. A report commissioned by the UK Post Office estimated that “the direct financial benefits of broadband in the home are in the order of £70 per month for the average UK household – ranging from £23 for the 10% of households with the lowest income to £148 for the 10% with the highest incomes. In total, the third of UK households which are not yet online are foregoing direct financial benefits of approximately £4.4 billion per annum.” At a proposed wind-farm site in Devon we have sought to develop a long-term partnership with the community to deliver economic growth and development over the life of the wind farm. Whatever the eventual ownership structure, BT will receive the electricity from the development and so will have a long-term community presence, alongside the network we already provide. We consider that this close association of communities with BT will also help to change the wider perception of large corporates. The sale of electricity direct to large consumers is thus a community partnership approach that BT strongly supports. This direct purchase approach must be maintained in the Electricity Market Review. Conclusion The outcome of this consultation should provide communities and developers with clear, impartial guidance on the most suitable partnership models. These models should promote transparency and openness in the debate about the planning balance on individual projects, to develop trust and positive working relationships. It should also seek to provide an open platform on which developers and communities alike can observe greater certainty of delivery of projects through the planning system. The consideration of benefits to a community should be a material planning consideration, but must not be allowed to override situations where significant environmental harm would result from development. 4 We would appreciate your continued correspondence with BT on this matter. We would be happy to discuss these issues further. Further enquiries can be directed to David Pincott, Head of Political Research, Policy and Briefing, BT Group plc Tel: 020 7356 6585/email: david.pincott@bt.com 5