Hills of Gold Wind Farm

Introduction

The Hills of Gold Wind Farm is the first proposal to which the new Guidelines will apply in their entirety. The original proposal is for a wind farm of up to 98 turbines, each 220m tall, on the Great Dividing Range in the Hills of Gold tourist area south of Nundle NSW bordering Ben Halls Gap Nature Reserve and running 20km south to Mt Crawney.

We intend to use this wind farm proposal as a dynamic case study by tracking its progress through the steps in the assessment process, providing commentary on how the Guidelines are followed, how the key issues are addressed and how the key players interact with each other.

What the community should expect: genuine consultation with affected individuals and local community groups by the proponent so as to properly design and site the wind farm to minimise impacts.

What is actually happening: the proponent is running a one-way promotional campaign to attract hosts, promising jobs and financial incentives and, despite many requests from the community for advice and information on the proposed wind farm, the Department has kept the community at arms length whilst providing counsel to the proponent on the preparation of the PEA.

Information sources:

We note that the Nundle Community website provides more information about the proposed wind farm than does the proponent's website.

Until the PEA is formally submitted and possibly the SEARs is issued, no information about this proposal will be posted on the Department's website.

Newspaper articles describe a divided community.  Those in favour of the wind farm see benefits from the promise of jobs and financial incentives and the importance of wind farms to renewable energy targets.

Community groups in and around Nundle have spoken against the proposal citing environmental, economic and social grounds. Their concerns are the impact on tourism, the visual impact on nearby properties and the environmental impact on a significant section of the Great Dividing Range and three major river systems.

Our Assessment

Everything is running true to form... the proponent has found some willing hosts close to transmission lines on the Northern Tablelands of NSW and is now in the first stage of stitching together a State significant development, insensitively named the Hills of Gold Wind Farm.

Also true to form... the proponent has failed to engage an anxious community, as has the Department by standing back and letting this situation unfold.

Those with the most to gain are in favour of the proposal, and the impacted community with the most to lose are being treated like anti-wind farm campaigners. 

Upon reflection, there is one notable difference - the proponent's representative did say at the first public meeting that this wind farm would not be built if the community did not want it.

Elapsed time: March 2018 - October 2018: 8 months

Our conclusion: community consultation has been poor, and the Department is already favouring the proponent and refusing to meet with the community until the PEA is lodged.

What the PEA should contain: a description of the project in terms of turbine layout and dwelling locations, access routes as well as preliminary visual and noise impact assessments which factors community values and environmental impacts and other constraints into the design of a wind farm to avoid or minimise impacts.

What is actually in the PEA: on face value the PEA ticks all the boxes, but scratch the surface and there is little of merit. Indeed, the PEA takes a "worst-case" approach and suggests that the impacts will lessen as the layout is refined in response to input from the community and government agencies. No attempt has been made to factor community concerns into the wind farm design to minimise impacts at this stage.

Information sources:

We note that the Department met with the Nundle community on the same day as the PEA was published.

The majority of the residents who came to the well-attended meeting opposed the wind farm, asked many questions and were buoyed by the Department's interest in the proposal so early in the process.

Newspaper articles continue to describe a divided community.  Those in favour of the wind farm see benefits from the promise of jobs and financial incentives and the importance of wind farms to renewable energy targets.

Community groups in and around Nundle continue to speak against the proposal on environmental, economic and social grounds.

Our Assessment

The PEA is indeed a worst-case wind farm design case with a layout of 97 turbines crammed into a 28km U shaped ridgeline along the Great Dividing Range and the Liverpool Range. With a height of 220m, turbines will reach an elevation of 1600m and will dominate the landscape for many kilometres in all directions - even with a significant reduction in the number of turbines.

Preliminary noise modelling suggests quite a few turbines will exceed noise levels at more than 9 residences.

The 97 turbines form an interconnecting corridor between Ben Hall Gap National Park (BHGNP) and Crawney Pass National Park.  The proposed wind farm shares a 9 km border with BHGNP where 20 turbines have an offset of 91 m from the park boundary, crammed so close together that the turbines almost touch each other.  The environmental impacts will be high even with a significant reduction in the number of turbines.

The transmission line corridor is 5km wide and 27 km long and the overhead power lines required to connect to the electricity grid 23 km away would require significant land clearing of native vegetation including red gum, yellow and white box.

It remains to be been seen just how much land clearing will be required for the whole wind farm even with a significant reduction in the number of turbines.  Google maps tells us the land clearing has already begun in several places.

Two access routes are proposed.  One will take turbines down the main street of Nundle and up past Sheba Dams on what must be one of the steepest roads in NSW with some hairpin bends.  The second access road is from the Head of Peel Road in the southwestern end of the wind farm and across several river systems on slopes in excess of 30 degrees up to the ridgeline.

The PEA describes a worst-case scenario which would result in extreme visual, environmental and noise impacts. 

Everything is running true to form... the proponent has submitted a wind farm proposal which anticipates the removal of turbines.

Negotiations with hosts and landowners whose properties are needed for access and for transmission lines are ongoing.

The proponent is still stitching together an over-exaggerated State significant development. But the truth is that the PEA probably does contain enough information for the Department to issue a standard SEARs within 28 days.

Also true to form... the proponent has failed to engage an anxious community, and by adopting a worst-case approach risks alienating the community even more.

By engaging the community early in the process, the Department has restored some confidence that local concerns will be heard.

Elapsed time: March 2018 - October 2018: 8 months

Our conclusion: as it is currently proposed this wind farm has extreme visual, environmental and noise impacts across a large area, but the local community now has the Department's ear and will be making their views known at every opportunity.

What the community should expect: a SEARs (Secretary's Environmental Assessment Requirements) which outlines what the proponent is required to assess and include in the EIS documentation. There is also a list of government agencies to be consulted.

What's in the SEARs: for the most part the SEARs is fairly standard as compared to previous wind farm SEARs, but there are a few additions and omissions.

Additions:

1    An accurate estimate of the capital investment value of the development by a qualified person is required. 

2    There is a new requirement under the heading reasons why the development should be approved:

"a detailed consideration of the capability of the project to the security and reliability of the electricity system in the National Electricity Market, having regard to local system conditions and the Department’s guidance on the matter"

This requirement is based upon the recently issued fact sheet Electricity System Security and Reliability Environmental Assessment Requirement May 2018.

3    There is a new key issue: Social & Economic – the EIS must include an assessment of the social and economic impacts and benefits of the project for the region and the State as a whole, including consideration of any increase in demand for community infrastructure services and impacts to tourism. We sought clarification and were told:

"the Department expects the social and economic assessment to consider the impacts and benefits to the community on matters such as to access to and use of infrastructure, services and facilities, way of life, aesthetic value and amenity."

This adds further dimensions to the social and economic key issue which we plan to discuss.

 Omissions

1   There is no mention of this proposal requiring approval under the EPBC Act as a controlled action. Given the proximity of this proposal to two national parks and the likelihood of significant impacts on a range of threatened flora and fauna, there should be a directive to consult the Department of the Environment and Energy in Canberra. The Department has confirmed that an EPBC referral, on the basis of a potential to significantly impact Commonwealth listed birds and bats, was likely after further biodiversity studies are conducted.

2    Whilst the SEARs requires an assessment of the impact of the project on bats and birds, there is no detailed methodology for assessing bat and bird strike in the SEARs as has been provided in other SEARs. We sought clarification from the Department who stated:

"...this is the first [SEARs] to be issued for a proposed wind farm since the commencement of the Biodiversity Conservation Act 2016 (BC Act) in August 2017. The BC Act introduced reforms to the assessment of biodiversity impacts and conservation in NSW. 

The preparation of a Biodiversity Development Assessment Report (BDAR) is mandatory under the BC Act, with an explanation of the methodology and information requirements to prepare a report outlined in the Biodiversity Assessment Method (BAM). The BAM also provides clear requirements for assessing the impacts of wind turbine strikes on avifauna which was not specifically referenced in the framework for biodiversity assessments which apply for other projects such as the Granite Hills Project. As such, an attachment outlining the methodology for assessing bird and bat strike in these SEARs is not required."

We plan to add information about the new biodiversity impact assessment to the website shortly.

Our Assessment

We would expect a supplemental SEARs containing more project specific requirements to be issued in the future.

The CCC has been formed in accordance with the Community Consultative Committee Guidelines State Significant Projects November 2016.  The Department appointed an independent chair, calls for nominations were made and the chair selected 7 community representatives.

Updated: 10 May 2019