Native title over most of Western Australia has been resolved. There have been 135 determinations that native title exists in Western Australia, covering in excess of 1.828 million square kilometres or over 70% of the Stateʼs area. Exclusive native title has been recognised over more than 1 million square kilometres (over 40% of the State). Nearly 220,000km2 of land within Western Australia is held within the Aboriginal Lands Trust (ALT) estate, constituting about 8.7% of the State. There are approximately 12,000 people living on the ALT estate in 142 communities. In addition to native title and ALT land, the Aboriginal Communities Act 1979 (WA) creates a regime of ʻcommunity landsʼ which are declared by th eState(and include most Aboriginal communities in the State). Community councils have the power to make by-laws in relation to the community lands regarding access, use of community lands, building safety, and regulation of conduct. Western Australia has very strong solar resources, and also high quality and nationally competitive wind resources that are largely untapped, particularly for offshore wind. There is clearly much interest and potential for the development of clean energy projects on land where First Nations communities hold an interest.