Improve the assessment process

Introduction

The Wind Energy Guidelines 2016 go some way to improving the assessment process but they fall short of providing real transparency and clarity for the community as we have discussed in our plain English Guides.

Some of the ambiguities and inconsistencies between the component parts of the Guidelines can be resolved in the SEARs by spelling out how and where impacts assessments are to be conducted.

However, tightening the SEARs will do little to address the underlying flaws in the assessment process.

So what can be done to improve the assessment process?

There are a number of things which can be done to improve the assessment process for both the community and the developer and achieve a better outcome for the people of NSW. There include:

  • mandate a realistic proposal from the onset by establishing some site selection principles
  • ensure the community is properly informed and engaged from day one
  • improve community confidence in the assessment process
  • improve the quality of EIS documentation

Site selection

Unless the assessment process mandates a more realistic or feasible wind farm proposal from the onset, delays in the assessment process will continue and there will be no improvements in the quality of community consultation and outcomes. This is because it is basically in the proponents interests to take the time to stitch together the biggest wind farm they can.

The proponent may be encouraged to scope a realistic proposal for a wind farm if there is an obligation to consider some site selection principles for the wind farm project area and the location of turbines early in the scoping phase.

Currently wind farm site selection is driven by suitable wind resources, willing hosts, proximity to electricity transmission lines, site access for construction, and this inevitably puts them close to people. And as more wind farms are built they will be sited even closer to people.

This means that there ought to be site selection principles which are considered early in the scoping phase and used by the Department to assess the feasibility of the wind farm proposal in its infancy.  This might include:

  • optimal wind resources

  • sites with suitable land area, geology and hydrology, and adequate access and road connections, including options for managing construction traffic

  • sites with characteristics that may assist in minimising localised impacts such as: land that does not contain native vegetation or has previously been cleared

  • land that can be readily decommissioned and rehabilitated back to pre-existing or better condition

  • localities where the community broadly supports the development

  • localities identified by Government as optimal for renewable energy development, and

  • proximity to the electricity network and connection capacity available at the anticipated connection point.

And because of the high visual and environmental impacts we stress that a wind farm should not be located:

  • adjacent to a national park or other significant native vegetation or geographic features

  • where the majority of the community do not support the development, and

  • on land easily eroded or not easily rehabilitated.

In addition to suitable site selection, turbines which exceed noise and visual impact thresholds should be removed from the preliminary design.

We believe that the community will be more receptive to a realistic and well conceived wind farm proposal.

Inform and engage the community

We hope that under the 2016 Guidelines the Department will take a more hands-on approach and make sure the community is properly informed and engaged from day one.

But more can be done to increase community confidence in the assessment process and to level the playing field on which wind farm developers and the impacted community interact.

First of all, the playing field is far from level when the Department assists the proponent whilst the community gets little guidance and no second chances. We suggest that the Department appoint an independent liaison person as early as possible during the scoping phase to:

  • assist the community in understanding the assessment process

  • run DIY visual and noise assessment workshops for the community

  • facilitate information dissemination

  • address the needs of particular audiences to be able to participate in the assessment process, and

  • generally be a conduit between the Department and the community.

Secondly, the Department should publish minutes of meetings with the proponent on their website.

Community confidence

Community levels of confidence would increase (and correspondingly the levels of uncertainty would decrease) if the Department:

  • made a clear policy that wind farm hosts are represented by the proponent on the Community Consultative Committee

  • clarified the weight which will be given to people's views on matters that affect their lives

  • clarified how benefit sharing agreements are assessed and remove the secrecy surrounding all agreements

  • required that the proposed model of turbine including tower height and blade length be stipulated.

Community confidence would also be raised and transparency improved if the Department routinely commission independent peer reviews of environmental impact statement (EIS) documents including:

  • site suitability

  • visual and noise impact assessments including accuracy and comprehensiveness of EIS documents

  • biodiversity and heritage impacts including accuracy and comprehensiveness of EIS documents

  • conduct independent annual audits of winds farms under construction and in operation and publish the results on the Departmental website.

Quality of EIS documentation

Much work needs to be done to raise the quality and consistency of environmental impact assessment documents by ensuring that consultants have independence from the wind farm developer and implementing an accreditation and registration system for consultants.

An effective accreditation and registration system should include:

  • Australian citizenship

  • prescribed qualifications and practical experience

  • membership of the relevant professional bodies

  • an annual competency exam

  • audits of the quality of their work to assess objectivity and knowledge of the guidelines

  • a process for de-registering consultants, and

  • a register of disqualified consultants.