Effective community consultation and engagement is essential for large-scale renewable energy and transmission projects to earn the ‘social license’ to operate within the community. To be effective in community engagement, developers need to ‘engage the community’ and involve the community wherever possible in the design and execution of programs related to the project (but not necessarily the project itself).
Absent or poor community engagement allows misinformation and community opposition to gain momentum. This can lead to projects not proceeding due to objections lodged in the planning and environmental process and delays from lengthy and costly legal challenges to the project. It may also impact on the reputation of the sector within the community and may result in broader community opposition to the industry.
The Commissioner has observed significant variety in the level of community engagement by developers to date. Initiating project developers (developers that secure the landholders and permits, then ‘on-sell’ the project to a long-term developer or operator) may not have sufficient funds available to effectively invest in community engagement or neighbour relations. These more limited efforts can result in lower levels of community support and more divided communities, compared to projects where the project developers invest appropriately in effective community engagement from the very start of the development activity.
Community and Stakeholder Committees
In some jurisdictions, such as New South Wales, the planning guideline framework provides for an early and continuing focus on community engagement, including the establishment of a Community Consultative Committee (CCC) or equivalent that is maintained throughout the life of the project. ‘Feed-in tariffs’ and ‘contract for difference’ arrangements, such as those established by the ACT and Victorian Governments, can place a significant weighting on selecting developers and projects that propose and demonstrate effective community engagement programs. They also enable the sponsoring jurisdiction to expect and extract desired community and project outcomes.
Many developers establish and fund Community Engagement Funds to support a wide range of initiatives that benefit the local community. In some jurisdictions, the provision of such funds is a condition of the permit’s approval.
We suggest that committees such as CCC’s are most effective when there is an independent chair and an appropriate balance in the committee membership. Chair and committee appointments should be made by an independent body where practical. Committees may play a vital role in conveying accurate information about the project, identifying and resolving issues that require multi-stakeholder cooperation and dispense with inaccurate perceptions about the project and related events.
The quality of information provided by project developers, via their websites, newsletters, public meetings and direct contact vary between projects and/or developers.
Developers should ensure that they provide up-to-date websites with clear information about the developer, project, current news, contact details, complaint processes and project documents, including planning approvals.
While most projects and developers now maintain reasonably effective project websites, some project websites remain difficult to find, are out of date or lack sufficient information and easy navigation. Not surprisingly, there is a high degree of correlation between poor communications and website quality with poor community support for the project.
Developers should consider engaging with media, such as local newspapers, to convey accurate information and updates about the project. Positive media engagement can be an extremely effective way to communicate with the broader community. Conversely, poor media relations and negative media reports, especially in mainstream and national media, can be hugely detrimental to the project and may fuel those in opposition to the project.
The quality of written correspondence from developers to community members varies widely. Developers should take the time to carefully review correspondence (including letters, emails, news updates and flyers) to ensure that it is clear in its message and objective.
It is also possible for developers to ‘over-engage’ with the community and cause engagement fatigue. The community will generally be interested in the project and keen to participate in engagement events. Developers need to take care when preparing the engagement program to avoid repetition and duplication.
Some regions of Australia are experiencing increased clustering of projects, which may result in community sentiment that projects are infiltrating and ‘surrounding’ communities. The concept of Renewable Energy Zones, while largely beneficial to opening new areas for projects, may have this unintended consequence.
As a result, individual project developers have both the need and opportunity to communicate more effectively with other developers in the area and better coordinate engagement with the affected community. Developers have the opportunity to collaborate on community engagement, communication and multiple construction programs to minimise cumulative impacts on residents and townships.
Developers should also be aware of other key infrastructure projects that may be taking place within the region, such as major infrastructure and road works, to ensure that where practical, project construction is planned and coordinated to minimise unnecessary cumulative impacts to communities.
Engagement Best Practice Guidelines
Several community engagement publications have been issued or updated in recent times, including publications by the Clean Energy Council, Victorian and Tasmanian Governments. These guidelines are useful resources to assist developers to plan, prepare and execute effective engagement programs.
Community engagement plans are now required in some planning permit applications. Other stakeholders may also mandate the requirement for a well-designed and executed community engagement plan, including investors and providers of finance.
Overall, there continues to be a wide range of opportunities for developers to broaden and improve their community engagement. The Commissioner’s suggestions and recommendations are listed below.
Community engagement programs for transmission projects have different nuances compared to other renewable energy projects. Most notably, transmission projects are long, linear projects that traverse many communities, geographies and different land use areas. The engagement programs described in this section therefore require tailoring to be effective at engaging and communicating with a myriad of affected communities.
While early engagement with the community is encouraged, going public too early may have unintended consequences. Presenting a ‘multi-corridor’ option approach to the broader community and asking them to help select the final proposed transmission line route can inflame a wide cross-section of the community and create animosity and division between community members as they lobby to eliminate candidate corridors that affect them.
An alternative approach is for the proponent to determine the preferred route corridor and engage the community and landholders to help finalise the actual route design and details. This approach allows that subset of the broader community to be focussed on optimising the solution, rather than the whole community group focusing on stopping the project.
This was a year of major progress for offshore wind energy generation in Australia. In December 2022, the Minister for Climate Change and Energy declared Australia’s first offshore project development area.
It is still early days for this new form of renewable energy generation. While there is no direct community around the actual turbines, developers will need to engage proactively and effectively with on-shore community groups that live in proximity to construction and shipping activity, have visibility of the proposed turbines or live in proximity to (or will host) the required on-shore transmission infrastructure.
Developers will also need to engage with stakeholders associated with marine and bird life conservation through to commercial fishing industry groups.
The Commissioner is assisting several developers by reviewing their engagement plans, enquiry and complaint management and stakeholder mapping.
3.2.1 The developer should invest early in community engagement, this should be well before the commencement of the permit approval phase. An acquirer of a project still in development should conduct due diligence on the extent and effectiveness of community engagement activities undertaken by the existing developer, prior to finalising purchase of the project, and should be prepared to make the necessary investments in community engagement going forward.
3.2.2 The developer should proactively identify and establish effective working relationships with key community stakeholders, including those opposed to the project.
3.2.3 The developer should, in consultation with the responsible authority and the community, consider establishing a CCC (or equivalent) with an appropriate charter and membership. The CCC Chair should be a respected member of the community at large and independent of any direct impact or benefit of the proposed project. The CCC should meet monthly during critical stages of the project’s development, approval, construction, post-construction testing and initial operations.
3.2.4 Developers should provide a range of information and education opportunities for community members to better understand the benefits and impacts of the project and address any questions or concerns. Initiatives to consider include:
- establishing a ‘shop front’ in the community town centre that provides project and permit information, a map and model of the project, information about the type of project and that is equipped to address questions or concerns
- providing an informal electronic channel for community members to ask questions (for example, by utilising a social media platform or chat room) and provide feedback about the project, including being able to do so anonymously
- providing opportunities for community members to visit operating projects and projects under construction
- providing access to a wind farm noise simulators and enabling community members to experience simulated noise scenarios
- maintaining an easily found, up-to-date project website with full transparency on contacts, complaint process, project details, current status, planning permit details and other documentation
- briefing local members (federal, state and local government) on the project and providing them with timely updates and information
- developing effective relationships with local media and providing the media with accurate information to assist their reporting of the project and any perceived or real impacts
- providing information sessions at locations convenient for community members, including presentations from key stakeholders, project partners and suppliers, to complement regular project newsletters and updates
- ensuring transparency for employment and contractor opportunities that arise from the project’s construction and operational phases
- publishing the minutes, where applicable, of CCC (or equivalent) meetings on the project website and allowing observers to attend CCC meetings
- understanding, assessing and informing the community about the impacts on local accommodation and catering during construction. Opportunities may exist for developers to construct accommodation which may, in turn, be utilised for long-term accommodation for people in need of housing. It is also essential that contractors make timely payment of invoices and accounts for accommodation and meals or catering.
3.2.5 The developer should establish a formal complaint and enquiry process, including a system to record and manage complaints. The developer should also provide a deidentified register of complaints and enquiries information. The complaint process should commence at the initial stage of the development activity and continue throughout the life of the project. The developer should ensure that the process enables community members to have their concerns addressed in a timely, consistent and transparent manner.
3.2.6 The developer (and CCC) should consult widely and communicate effectively on the proposed construction and related transport plan. The developer should also ensure appropriate restoration and ‘make-good’ actions are in place to remedy damage that may occur. They should seek to leave local infrastructure in the same or better condition than prior to the construction.
3.2.7 The developer should advise community members in advance of impactful activities during construction using all relevant channels, such as text messaging. Where more than one construction project is occurring concurrently in the same area, projects should collaborate to identify and resolve issues, such as constrained supplies of gravel, tradespeople, accommodation, meals and road access issues.
3.2.8 The developer may seek out opportunities to facilitate improvements to related community infrastructure. Initiatives may include improving mobile phone coverage, utilising the ‘imported’ project workforce to help upgrade local facilities (such as parks, playgrounds) and other practical activities which would benefit the overall community for years to come.
3.2.9 Local councils should proactively engage with the project and community, clearly communicating the council’s level of support for the project as well as its role in facilitating and promoting effective community consultation and project compliance. Council should participate in any CCC or equivalent. If there are multiple large-scale infrastructure projects concurrently in development within a council’s jurisdiction, council liaison resources should be appointed to coordinate issue resolution between Council, community members and developers. Where appropriate, other planning and approval agencies should ensure that local councils are provided sufficient opportunities and support to effectively engage in consultation and approval processes for projects. If Council is the formal planning authority for the project, Council will need to be mindful of any real or perceived conflicts of interest related to the above.
3.2.10 Where possible, the developer should engage local staff (or relocate staff into the project area) to lead community engagement activities and respond to community concerns and complaints. The developer should also seek to hire local tradespeople, contractor staff and other suppliers.
3.2.11 Once a project is in operation, the developer should continue to provide information and updates about the project as well as provide opportunities for the community to visit the project site (such as an ‘open day’).
3.2.12 The developer should consider establishing and maintaining a community engagement fund and ensure there is appropriate community involvement in the governance and management of the fund. In some jurisdictions, such a fund is mandated. The fund should allow opportunities for community originated submissions to obtain funding for projects. Prioritisation of funded projects that benefit community members more directly affected by the presence of the project should be encouraged. The community fund should include and benefit community members that live in proximity to the project, rather than only supporting projects related to a regional centre.
3.2.13 Developers may wish to consider providing offers for community members to become shareholders in the project. This can provide a practical sense of ownership within the community. Developers may also offer beneficial arrangements to community members such as reduced or subsidised electricity bills, gift cards for use at local vendors or other practical benefits to local residents and businesses within the immediate community.
3.2.14 Project stakeholders, including the responsible authority, council, bankers, investors and regulators, should seek evidence of the project’s community engagement plan and the outcome of the plan. This information should inform the stakeholder’s decision making and influence on the project and developer.
3.2.15 Industry bodies, such as the Clean Energy Council (CEC) and the Renewable Energy Alliance (RE-Alliance), should continue to promote effective community engagement and publicly recognise individuals and organisations achieving excellence in positive community engagement outcomes. Appropriate priority should continue to be given to this topic when designing industry forum programs.
3.2.16 State governments can continue to play a key role by promoting effective community engagement. Examples of this include the decision to include community engagement plans as a key selection criterion for eligibility for government ‘feed-in tariff’ programs and utilising formal permit conditions to mandate preparation, endorsement and execution of the plan.
3.2.17 Developers should ensure that all contractors, sub-contractors and other project stakeholders are aware of their responsibility to engage well with the community and minimise community impacts. If there are multiple infrastructure development projects occurring within a region, developers should be aware of potential cumulative impacts to the community and should liaise with local councils and other developers to proactively plan to avoid or minimise unnecessary impact.
3.2.18 Transmission developers should minimise the number of route options they announce for public review and consultation. Too many route options may generate unnecessary widespread opposition to the project, especially if there is ultimately only one obvious and viable route.
3.2.19 Offshore wind farm developers will need to be cognisant of the diverse stakeholders to their projects. Stakeholders will be geographically and functionally diverse, including onshore landholders and community that may be affected by infrastructure such as transmission deployments and pre-assembly activities.