South Lanarkshire Council Response

South Lanarkshire Council Response Is the set of technologies proposed above the most effective scope for the final updated Good Practice Principles? Yes Would our proposed approach of adapting guidance for different technologies be effective? Yes Is our proposed approach to ‘co-located’ developments clear and practical for communities and developers? Expected co-ordination from developers between each other and on co-ordination of funds is positive. However, it is unclear who would be expected to facilitate this - does the LA / local Planning Authority play in a role in this? What does successful co-ordination look like and what additional statutory bodies and stakeholders are required to achieve this vision? It is unlikely that it will be achieved by communities and developers alone, in recognition of statutory bodies and associated duties. How does this factor community capacity? Would the technology-specific funding recommendations proposed in this section build on progress to date and help communities gain meaningful benefits from developments? Yes, While we note £6k per MW for onshore wind is an increase from the £5k guided it isn’t keeping up with inflation and currently South Lanarkshire has several windfarms contributing £7k+ per MW due to RPI increases since they started operation around 2013 – 2016 a rate of £7k - £7.5k would be more appropriate and keep up with inflation. Would these recommendations be achievable for renewables developments of different types, whilst leaving room for flexibility? Yes Do the proposed Principles provide a clear and workable foundation for refreshed governance and distribution guidance? The guidance should reference existing structures and funds and propose developers and communities should consider what exists within the area first. Too often new funds and administration of funds are overlayed existing structures this is inefficient and wasteful in governance and community time. A preference should be steered to existing structures unless there is a reason not to choose existing funding structures. Each operator and windfarm creating a new community panel and governance structures keeps communities busy and on small projects and misses the transformational opportunity of joining funds up. The guidance should propose combining new funds with existing funds where appropriate and indicate there are benefits from this in efficiency and impact. Reference to strategic partnership working and collaboration with additional stakeholders and statutory bodies should be made to strengthen proposals and link in with existing priorities whilst still prioritising community ambitions. Are the Indicators a helpful and proportionate approach, and which structure is most usable (principle led, lifecycle based, hybrid)? Yes these are core principle funds should operate, there are many existing organisations that can help local communities local LAGS, SCO, Firstport, Development Trust Scotland, we don’t need new guidance or structures simply point people to what exists. The indicators could move further to what the funds deliver as they don’t measuring impact and outcomes, while challenging, proposals to measure the Social Impact of the funds such as CLLD uses would move the Community Benefit from Outputs to Outcomes and demonstrate the long term impact. Are the updated and new Tools helpful, and are there any additions or changes would improve the final set? See section 4 Are governance structure options and minimum expectations appropriate? We would seek to add the model that has worked in South Lanarkshire through the REF for twenty years. The Council acts as Accountable Body and administers local funds within strict geographic eligibility areas for local community benefit, decision making is made either by Community Panels, officers or Councillors depending on local agreements. All information is published and reported annually to Council Committee. This model administers £6m annually all going to local communities and for local communities. The massive advantage this provides is in strategic partnership and impact that smaller Community Benefit funds cannot achieve. The funds fund projects but also drive forward and delivers on strategic impact projects such as the Connect 2 Renewables employability project, RISE employability work, CLYDE SSE SLC Regional Net Zero funding, 3rd Sector rural Transport development, The Douglas Valley Outdoor Adventure Tourism Development, none of these are possible with isolated individual funds. The fund consults with communities on a regional basis and drives forward regional rural impact local benefit and projects. An additional proposed governance structure Council administered should be added as an option for communities to consider. Would suggest adding in a partnership model to the list of proposed minimum expectations. For example, the community-led Douglas Valley Advisory Group advises South Lanarkshire Council on strategic projects that it wishes to progress on their behalf, where community capacity does not meet the demand and whilst respecting and supporting existing groups and outcomes. High level expectations should include that developers and communities are supported to understand and connect to the existing community benefit landscape at a local scale, particularly where there are multiple developments. A list of all existing fund administrators should be referred to and consulted with at an early stage, recognising that new funds are often adding to a complex existing landscape of community benefits. With a clear statutory role, there would be a benefit to promoting Local Place Plans wherever Community Action Plans are noted. Is the strengthened local first distribution approach clear and practical, including for co located developments? Partially, the principle works well for isolated windfarm developments but much less well in areas of multiple windfarms. The communities closest to windfarm developments must be the core beneficiaries however the Guidance should recognise that communities are not isolated and don’t function that way and that where funds are becoming substantial there should needs to be encouragement towards regional funding. We would recommend the guidance sets a limit to this but states that regional funding of up to 30% can bring significant benefit to host communities and should be encouraged within discussions with developers and neighbouring communities. Would the measures proposed in this section strengthen the resources and capacity of communities, and help enable them to secure and make the most of community benefit funds? Definition of lack of capacity misses out the issue of time many people have in acting as a barrier to contribution, for example, many working families in full time employment with caring responsibilities. In this regard, mention of a partnership approach would again be beneficial. The approaches seem to focus on communities new to community benefit funds without recognition of communities who have already had access to benefits for an amount of time who still struggle to achieve strategic change.

South Lanarkshire has the longest history of running Community Benefit Funds (over 28 years) and possibly the largest density of funds in Scotland. The Council has consulted and works closely with all of the Community to deliver lasting impact and have learnt many lessons. The funds mangement have advanceinto a fourth generation of funding that has listened to the 3rd sector and has a focus on Community wealth Building and transformational imapact

A concern is that the policy doesnt recognise there are existing succesful Community Benefit structures that should be considered by developers and communities first, that in the Central session this was raised by community groups. Also that pulling together multiple funds into one Governance structure can be an option that increases efficiency and reduces the funds that go to management and increase benefits going to communities.

Also the disparity in funding in rural areas is damaging, and the guidance ignores the growing issue where random boundaries create the differance of having £1ms of pounds or a few tens of thousands annually isnt fair on communities or delivering the best for people.   Regional funding help all communities if constructed properly, SSE CLYDE has an example that should be considered more widely, SSE SLC CLYDE Net Zero fund also provides an example.