Introduction to Key Issues

Introduction to Key Issues

The Secretary’s Environmental Assessment Requirements (SEARS) contains a list of the key issues associated with the development of a wind farm which must be examined by the proponent and assessed by the the Department of Planning (the Department) and the Independent Planning Commission (IPC).  In this section we explain each key issue, what to look out for and what the community can do to ensure that each one is properly assessed.

Broadly speaking the key issues fall into two categories - either social and environmental or technical and engineering.

The technical and engineering issues are usually resolved by the proponent adopting best practice and/or government authorities imposing conditions of consent on the development. No wind farm in NSW has ever been refused on technical or engineering grounds.

The social and environmental impacts are more subjective to evaluate and can generally be reduced but never totally resolved. A wind farm proposal will likely be approved if the social and environmental issues can be reduced to an acceptable level such that the public interest in a wind farm renewable energy project outweighs the private interest of the local community and impacts on the environment.  The Jupiter wind farm was refused because the social and environmental impacts outweighed the public interest.

The following diagram provides an overview of the key issues usually listed in the SEARS.  Each key issue links to a more comprehensive description of each and what to do to get the best outcome.

Summary of key issues

Summary of key issues

Visual impact

Visual impact

The visual impact of a wind farm on public and private views is one of the major issues which needs to be carefully assessed by the proponent.  During the scoping phase the preliminary design of the wind farm should minimise visual impact.  A detailed assessment of the visual impact is then carried out during the Environmental Impact Statement (EIS) phase and again if the layout is modified as a response to submissions.

A visual impact assessment is required for both public and private viewpoints within a certain distance of wind turbines. The impact zone is based on the height of turbines to the blade tip. Viewpoints with medium to high impact will be scrutinised by the Department so make sure that the proponent includes a visual assessment of all properties whether occupied or not and all public viewpoints which will have prominent views of turbines, particularly lookouts, recreational areas and other public spaces, villages, rural residential areas and outlook to areas of high scenic value like mountain peaks, rock outcrops, rivers and creeks.

Visual impact assessment is a complex and subjective process involving multiple steps. We have produced a plain English guide to the Visual Impact Assessment Bulletin for communities.  This guide includes a DIY visual imact assessment worksheet.

Visual Impact Assessment: Non-associated landowners

The assessment of visual impact is arguably one of the most crucial areas for the proponent and the community. Visual impact is one of a range of issues considered in the assessment and determination of wind energy projects, and one of the most likely reasons why the Department removes turbines, recommends mitigation, or outright rejection of the proposal. Accordingly, in submissions on the EIS from the community, concerns about visual impact should be given emphasis. Of all the real impacts a wind farm can have on a community, visual impact is the most accepted and accredited one. This is one area the Department will fully recognise as having serious impacts. For various reasons, mitigation of visual impacts is difficult.

A wind farm has a high potential for visual impact. The height, colour and prominent positioning of wind turbines on ridgelines, accompanied by the fact that there is movement, creates a high visual profile. Enhancing these factors is the large area a wind farm can cover. Because they are being built largely in rural landscapes, there are issues with compatibility.

The Wind Energy Guidelines 2016 say:

“Generally, the visual impact of a wind energy project will depend upon the characteristics and values of the existing landscape, the extent to which the existing landscape is changed by the project and how these changes are perceived by individuals and the broader community.”

Scoping and the PEA

Assessing visual impact begins at the scoping stage. The proponent should engage the community to ascertain individual and community landscape values. This includes the private and the public domain. The community should mention any local landscape features of particular significance, as well as highlight the general features in the landscape they value. The proponent needs to establish viewer sensitivity and the degree of sensitivity of the landowner to this type/degree of change.

To do this the proponent should provide maps of the turbines and impacted residences. The community and individuals should raise any concerns they may have. It is important to ask questions, establish the facts as much as possible, and at the earliest stage, get concerns on the table.

Once scoping is complete, the PEA (also known as the Scoping Report) is sent to the Department to be assessed and the SEARs (list of requirements that must be assessed in the EIS) are issued. It is important that the PEA is completed thoroughly and correctly, particularly in regards to consultation. The Department should not issue a SEARs unless this is so, but there is evidence that deficient PEAS are excepted.  So the community should make their concerns known as soon as the PEA is published and before the SEARs is issued.

SEARs and the EIS

After the SEARs is issued and the EIS process is underway, the proponent will engage with the community to gain access to private properties to create photomontages and wireframes. Residents can refuse entry. Doing so forces the proponent to use public viewpoints. There are reasons why residents may wish to refuse. It sends a very clear message to both the proponent and the Department that residents are opposed to the project. But it also means residents are not participating in the preparation of photomontages and therefore cannot influence the process by requesting photographs be taken from a particular viewpoint and therefore risk having a visual impact assessment at variance with real visual impact. Cooperating and having a photomontage done from your dwelling and other desirable views provides some assessment of visual impact, even if subjective, and this is a very important consideration.

Because photomontages can be a subjective or artistic as a rendition of visual impact modelling, the Department includes wireframes (a stark rendition of turbines in the landscape without a background photograph) as a visual assessment tool. Usually the proponent will provide both.

Visual impact assessment is complex. The Wind Energy Guidelines 2016 provides a detailed framework for the proponent to follow. There are considerations relating to proximity, quantity and the prominence and extent of the positioning of turbines, and the value people place on views and so. All these issues are put through a process which ultimately categorises turbine impact on a viewpoint as HIGH, MEDIUM or LOW. The proponent is obliged to justify placement of turbines in areas of medium to high impact.

The completed EIS will contain photomontages from various viewpoints, wireframes, and an analysis of specific conditions. Mitigation measures will be suggested.

Mitigation

There are three main mitigation strategies. Vegetation screening, benefit sharing agreements and relocation or removal of turbines.

Vegetation screening is usually ineffective. Trees are slow growing and fragile in a rural environment. Tree planting cannot mitigate the view from multiple viewpoints. Because of the size of wind turbines, trees must be planted close to houses, causing hazards including bushfire. Trees planted to block the view of turbines, block all views. Rural blocks typically have multiple views of turbines. When existing vegetation is used to mitigate, the same issues are involved. Wind and fire can alter the vegetation and its continuous existence cannot be guaranteed over the life of the project.

Benefit sharing agreements of up to $2,000 per annum are frequently offered to impacted landowners in exchange for acceptance of visual impact and is an approved method of mitigation. Benefit sharing agreements are complex so please take the time to read that section.

The proponent can voluntarily remove or relocate turbines to lower the visual impact impact on a resident. The Department or IPC may also request the relocation or removal of turbines.

Things to look out for

Many visual impact consultants are urban-based and what the community values about their rural lifestyle are often quite different. This can be particularly seen in relation to a photomontage taken from a single viewpoint on a 40 hectare property. There is an assumption people spend most of their time inside. This is not often true in a rural setting.

Where a house has not as yet been built, there can be a tendency for the proponent to be dismissive.

In other EISs it has been suggested that the landowner build to minimise the impact of the turbines. At times they are not included in the EIS at all. It is important that all residents within the impact zone ensure they are included in their visual impact assessment.

The Wind Energy Framework defines dwellings broadly to mean any properties where people have an entitlement to build. Dual occupancy is usually ignored by the proponent. The resident needs to raise these issues, particularly if they have future plans to build.

Visual impact assessment remains subjective. Methodologies attempt to provide some consistency but are not always vigorously followed. The community should examine the EIS closely and raise anomalies, missing information, and indicate clearly how fairly they have been assessed. All submissions should reference Visual impact issues where visual impact exists.

The Department

Following the publication of the EIS, the Department will often organise an independent Visual Impact Assessment. They should meet with the community to establish resident sensitivity levels and establish local landscape values. The independent consultant may ask to visit properties to form their own assessment of impact. It is recommended that the community cooperate with the independent team as fully as possible.

Night lighting

Turbines taller than 150m are required to be night lit and the Civil Aviation Authority will decide which turbines need to be night lit depending on the wind farm design. This usually means that turbines on the periphery and closest to dwellings will be the most likely to be night lit.

The visual impact of lighting is assessed in terms of the number of night lit turbines, how visible the night lights are to nearby dwellings, their proximity, existing light pollution sources and whether the residences are at a similar elevation to the turbines.

There are a few options for reducing night lighting including low intensity lighting and radar activated lighting.

Jupiter Case Study

Close to 400 submissions raised concerns about visual impact including night lighting. Most said they valued the dark night skies as a feature of the area.

Jupiter was refused because it was too close to too many people and would result in unacceptable visual impacts on the landscape and the residences in the local area.

The Department said that night lighting 30 of 54 turbines would add to the visual impacts of the project, particularly as there were limited existing light pollution sources and there were many residences at a similar elevation to the turbines meaning impacts would be even more significant.

Shadow flicker and blade glint

At certain times of the day when the sun is low in the sky and the sun is behind rotating turbine blades an observer sees shadow flicker. Shadow flicker at dwellings should be limited to 30 hours per year. Assessment of shadow flicker is a geometric calculation based on the position of the sun at different times of the year, the topography and the field of turbine view.

Consultants analysing the theoretical shadow flicker argue that the analysis is conservative (meaning over-estimated) because the sun doesn’t always shine, and the wind direction can change the orientation of the blades. However, the Wind Farm Guidelines 2016 do not suggest that shadow flicker should be downplayed by factoring in the chances of cloud cover or favourable wind direction.

If theoretical shadow flicker exceeds 30 hours per year, changes to siting and turbine design must be made to reduce shadow flicker. Similarly, the direct reflection of the sun from the wind turbine structure (glint) must be minimised through appropriate turbine treatments (such as the use of low sheen and matte finishes).

Consultants may suggest that the effects of shadow flicker can be reduced/eliminated by screening structures or planting of trees to block shadows cast by the turbines and shutting down selected turbines when shadow flicker is likely to occur. However, the Wind Farm Guidelines 2016 does not offer such mitigation strategies and they would be impossible to police after a wind farm is built, except by a landowner keeping a log of flicker and glint over a 12 months period.

If the SEARs does not explicitly state the zone of visual influence for shadow flicker analysis including minimum distance from turbines, number of turbines and the distance around a dwelling for which modelling should occur, seek clarification from the Department. And object to the analysis if it does not concur with the Department's advice.

Jupiter Case Study

Over 400 submissions expressed concern about visual impact and shadow flicker.

The original EIS found that 12 non-host dwellings would be affected by shadow flicker. The revised layout which reduced the number of turbines from 88 to 54 claimed to have virtually eliminated shadow flicker even though only one of the offending turbines had been moved or removed.

Unlike other wind farms where turbines are in a linear arrangement, Jupiter turbines were arranged in clusters and the layering affect may well have increased shadow flicker. This was neither questioned nor addressed.

Noise impact

Noise impact

Turbine noise

As a part of the EIS, the proponent must assess the noise impacts of a wind farm during construction and operation. This assessment is based on measuring the background noise (noise level excluding intermittent noise levels) at various locations in and around the wind farm. The background noise is then factored into a noise modelling of different types of sound at residences within a certain distance (defined in the SEARs) and at different wind speeds. Noise emanating from the wind farm during construction and operation is assessed by the Department and the Environmental Protection Authority (EPA).

According to the Noise Assessment Bulletin noise from wind farms is unique because:

Noise monitoring for the EIS establishes the baseline for background noise. A noise limit of 35 dB(A) or 5 dB(A) above the background noise if the background noise is more than 35 dB(A) measured over a 24-hour period is required for noise compliance.

Noise types such as tonality (frequency or pitch) and ultrasound (inaudible) must also be assessed and appropriate adjustments made to the base level noise measurements.

The operation of the electrical substations, noise from the transmission lines, construction noise, traffic noise and blasting must also be assessed.

The assessment must identify noise/vibration sensitive locations (including approved but not yet developed dwellings), baseline conditions based on monitoring results, the levels and character of noise (e.g. tonality, impulsiveness, low frequency etc.) generated by noise sources, noise/vibration criteria, modelling assumptions and worst case and representative noise/vibration impacts.

Clearly noise is a complex issue and there are limits to what the community can validate or question. Even more reason to consult experts at the Department and the EPA drawing attention to issues that arise from noise monitoring locations, equipment and duration.

Local knowledge and cross-checking the proximity of dwellings to substations, transmission lines and access roads are important. As is questioning all aspects of noise assessment and expressing concerns to the Department along the way.

Keep in mind there are three aspects to noise compliance. In the first instance, monitoring equipment is strategically located to measure background noise to establish a baseline for noise modelling.  Noise modelling uses computer software to predict the noise generated by the wind farm based on the layout, topography and size and proximity of turbines to residences and a generic model of turbine.  It is guesswork at best and too easy to mis-model the wind farm.  Any background noise close to the threshold should be questioned,likewise noise modelling close to the threshold should be questioned. Finally, if the wind farm is approved and built noise compliance is a requirement of operation.

Be aware that the Department says that turbines within 1500m of a dwelling are not likely to be noise complaint.

We have produced a plain English guide to the Noise Assessment Bulletin for communities and which includes a range of issues to watch out for.

Jupiter Case Study

Over 250 submissions raised concerns about noise and questioned the noise monitoring methodologies, particularly in relation to the siting of noise monitoring equipment near sources of noise such as roads and water pumps to give higher background noise readings and so raise the noise compliance bar in favour of the wind farm.

Both Regional Councils also raised concerns about the noise.

Noise monitoring was conducted at dwellings within 5 kms of a turbine.

Many residents had background noise readings close to 35 dB (A) leaving no room for error in the design of the wind farm. The margin of error is an important point since no information about the brand and model of turbines was given in the EIS.

Unlike other wind farms where turbines are in a linear arrangement, Jupiter turbines were arranged in clusters and the layering affect may well increase noise levels. This was neither questioned nor addressed by the Department.

Residents Against Jupiter Wind Turbines (RAJWT) conducted its own background noise readings at a number of sites and met with the EPA to discuss issues with wind farms and noise measurement. The EPA did not inspect the site.

The Department arranged a meeting with their own noise consultant and members of the local community.

A significant number of the background noise monitoring results did not rise with wind speed, indicating the monitoring was done in a sheltered spot. This warranted closer examination which was not done by the proponent nor the Department.

Noise and Health

Noise and Health

Wind farm noise emission levels and risks to health are complex because the noise is variable, as are human perceptions of noise. The focus is usually on health risk from infrasound (inaudible low frequency noise) and sleep deprivation from audible and inaudible sound.

The Department's position is that there is currently no evidence supporting a link between wind energy projects and adverse health outcomes in humans relating to infrasound. This is in accord with the National Health and Medical Research Council (NHMRC) statement Evidence on Wind Farms and Human Health (February 2015) which concludes that there is currently no consistent evidence supporting a link between wind energy projects and adverse health outcomes in humans relating to infrasound. The Department qualifies this statement by saying that the NSW Government will continue to monitor contemporary scientific research outcomes to ensure its position reflects robust evidence on any health effects, including any advice released from the National Wind Farm Commissioner and the Independent Scientific Committee.

However, the NHMRC also says that given the poor quality of current direct evidence and the concerns expressed by some members of the community, high quality research into possible health effects of wind farms, particularly within 1,500 m, is warranted. To that end NHMRC has funded two projects:

Research at the Flinders University of South Australia: explores relationships between noise from wind farms and effects such as annoyances and reduced sleep and quality of life.

Research at the University of New South Wales: investigates the broader social and environmental circumstances that may influence the health of people living near wind farms.

Results are expected in 2020.

Jupiter Case Study

Over 240 submissions raised concerns about health and questioned the noise monitoring methodologies, particularly in relation to siting of noise monitoring equipment (eg close to water pumps or roads, rather than living and sleeping areas on the wind farm side of houses) which gave high background noise readings.

Traffic noise

Regardless of how close residences are to access roads, traffic noise will be deemed manageable. Mitigation measures to reduce construction-related traffic noise may include scheduling of construction traffic deliveries, vehicle maintenance, restricting construction traffic to day time operation hours and notification of local residences in the event of night time deliveries.

Apply local knowledge and object if you consider traffic noise, particularly during construction, to be extreme.

Construction noise, blasting and vibration

Regardless of how close residences are to the project area, construction noise will be deemed manageable. Mitigation to reduce construction noise might include the construction of temporary acoustic barriers, the use of proprietary enclosures around machines, the use of silencers, the substitution of alternative construction processes and the fitting of broadband reversing signals.

Blasting will be limited to daytime Monday through Saturday.

Apply local knowledge and object if you consider noise, particularly during construction, to be extreme.

Biodiversity

Biodiversity

The Office of Environment and Heritage (OEH) works with the Department to address issues regarding biodiversity in the development of wind farms.

OEH will meet with the proponent, study the area, and will put in a submission on the EIS during public exhibition.

OEH is concerned with area species on the threatened and endangered list. However, they will also act to protect non-threatened species, such as the Wedge-tailed Eagle, particularly when there are known nesting sites in the area.

Areas of attention are: any clearing of native forest; native grasslands; protected flora; hollow bearing trees; habitat of protected fauna; or protected fauna that may be impacted by the wind farm. Close attention will be paid to bird and bat species vulnerable to blade strike, and animals with specialised habitat.

OEH work on a system to avoid, minimise and offset impacts on biodiversity. Offsetting is used to “replace” lost habitat by purchasing similar, existing habitat, elsewhere.  The proponent may well call for submissions from wind farm neighbours to have their properties used to offset biodiversity impacts.

When approaching biodiversity in relation to wind farms it is important to note that wind farms can always be located somewhere else. Thus, arguments for the necessity of accepting environmental impacts for the "greater good" are tenuous. As wind farms are being built to save the environment (the threat of global warming will potentially have massive impacts on the environment) OEH regard wind farms favourably, and therefore are involved in a balancing act between protecting the environment from harm and assisting wind farms to be built. However, the very fact of being an environmental project places an onus on wind farms to not harm the environment further.

Another major consideration in this area is the sad lack of research on environmental impacts of wind farms. Most Australian studies have been conducted by the wind industry and are consequently unreliable. Overseas research exists and is alarming. However, scientific bodies in Australia dismiss overseas research as being irrelevant to Australian conditions.

Local councils and land zoning

The area involving or near the proposed wind farm may be classified as environmentally important through local council zoning. E3 zones, Environmental Living, and Reserves are an example. Although councils are not the determining body for state significant wind farms, the Department will take into account the land zoning.

What you can do

Approach OEH to discuss your concerns. Bring to their attention any local knowledge regarding flora and fauna. Work with them and assist them to ensure their submission is thorough and accurate. The community may wish to ensure that they add local data to OEH’s knowledge base.

Contact any local Landcare, Wildcare and conservation groups in your area.

Contact local councils and encourage the protection of existing environmentally zoned areas.

Write a submission regarding your concerns about biodiversity impacts.

Federal Department of Environment and Energy

On a Federal level, the Department of Environment and Energy may be involved with a wind farm proposal when it is deemed a controlled action, meaning the wind farm has the potential to impact matters of national significance including threatened species. You can make submissions to the Federal Department of Environment and Energy. If they are involved, it would be worthwhile contacting them and discussing your concerns. The Federal Department of Environment and Energy is very focused in its areas of concern and can intervene with considerable power.

Jupiter Case Study

The proposed Jupiter Wind Farm covered two regional council areas. The Goulburn Council area was zoned E3 - Environmental Management. The Goulburn Council wrote to the Department and stated that it was not suitable to build wind turbines on this land because of its environmental sensitivity. In their rejection of the Jupiter Wind Farm, the Department referred to the E3 zoning as one of many reasons that made the site unsuitable.

The Queanbeyan Palerang Council also opposed Jupiter on noise and visual impacts.

Initially, OEH recommended the removal of 13 turbines and the relocation of 14 turbines to reduce biodiversity impacts. They requested further studies for a number of flora and fauna species, raptors and migratory species and hollow bearing trees. They had concerns about the impact of turbines on connectivity between areas of remnant vegetation and avoidance of all high constraint biodiversity areas, as well as querying the width of access roads.

They also had concerns about potential for Aboriginal cultural heritage and wanted additional information on methodology. The amended layout changed little. OEH largely maintained its original concerns and recommended the removal of 2 turbines and relocation of 12 turbines that were identified in its original submission to avoid/reduce impacts on biodiversity, particularly the risk of blade strike on threatened species such as the Glossy Black-Cockatoo.

Local community groups made submissions expressing their concern regarding environmental impacts, bringing attention to local environmental groups, and the location of the wind farm in the middle of two biodiversity corridors.

Cultural heritage

Cultural heritage

Land clearing, road building, excavation and construction works may disturb Aboriginal cultural heritage.

The Office of Environment and Heritage (OEH) maintains the Aboriginal Heritage Information Management System (AHIMS) which contains detailed information on recorded sites of aboriginal heritage and other Aboriginal heritage reports.

The wind farm proponent should consult this database.

Local aboriginal communities and land councils can provide valuable local knowledge about the potential risks to aboriginal culture. Community groups should liaise with aboriginal stakeholders to get an appreciation of the issues and aboriginal values.

The extent of recorded sites and archaeological significance of artefacts will determine the risks that will need to be managed. Moving turbines, changing road routes and minimising excavation are common mitigation strategies. The proponent may be directed to commission a Heritage Management Plan to be prepared by a suitably qualified person in consultation with OEH and Aboriginal stakeholders.

Jupiter Case Study

The proponent did not adequately survey the project area nor provide evidence of AHIMS searches.

Nor were aboriginal communities consulted.

Property values

Property values

The Department's current position is that wind farms are unlikely to have a measurable negative impact on surrounding land values in rural areas even though they acknowledge that the data is limited.

And further, that an approved and compliant wind farm would not result in any significant or widespread reduction in land values in areas surrounding a wind farm. A decline in property values is currently not a winning argument against a wind farm proposal.

The onus therefore is on community members to present an expert opinion that property values will decline no matter what the layout. For example, a valuation report from a registered valuer or a written testimonial from a bank that finance to build or purchase a property is contingent on a wind farm NOT being approved.

Research

The two main studies that have so far been completed, the Preliminary Assessment of the Impact of Wind Farms on Property Values (NSW Valuer General 2009) and the more recent report Review of the Impact of Wind Farms on Property Values, by Urbis, both make it clear that, as yet, there is insufficient data to draw definite conclusions. However, it is worth mentioning that both documents state that the most likely land use type to be negatively impacted is the rural lifestyle property, as it is largely bought for aesthetic purposes, and rural residential properties, because of the denser population.

The 2009 report includes an assessment by Hives, 2008, that states:

“Properties benefiting from turbine leases increased in value. Rural properties were unaffected. Some detrimental effects were evident on lifestyle properties.”

“Discussions with local agents suggest that the wind farm has deterred some buyers. Agents generally reported that the number of potential buyers decreases the closer a property is located to the wind farm.”

In the Review of the Impact of Wind Farms on Property Values, 2016, URBIS states:

“Whilst evidence to support these effects in the present Australian context is somewhat limited, the following factors are worthy of consideration:

Proximity to residential dwellings – Issues surrounding noise, shadow flicker and close visual impacts are likely to be exacerbated if wind turbines are located close to residential dwellings, and therefore any such perceived diminution of residential amenity has the potential to influence property values.”

“In our professional opinion, appropriately located wind farms within rural areas, removed from higher density residential areas, are unlikely to have a measurable negative impact on surrounding land values.”

“There is limited available sales data to make a conclusive finding relating to value impacts on residential or lifestyle properties located close to wind farm turbines, noting that wind farms in NSW have been constructed in predominantly rural areas.“

Jupiter Case Study

About 220 submissions raised concerns about decline in property values and limitations on future development like subdivision.

However, the Department’s Assessment Report concentrated on the emerging rural residential nature of the area, and the problem of visual impacts on such a large number of residents, where suggested mitigation was deemed inappropriate.

Bushfire risk

Bushfire risk

The Department notes that in its Wind Farm and Aerial Firefighting Information Sheet, the NSW Rural Fire Service (NSW RFS) states that the presence of a wind farm would not stop it from fighting a fire and it would deal with wind farms in the same way it deals with other potential hazards, such as powerlines, radiocommunication towers, mountains or valleys. We could not find this fact sheet on the RFS website.

We suggest you give a presentation to the NSW RFS asking them to submit an expert assessment of the bushfire risk for this wind farm to the Department.

Provide them with local knowledge about the proximity of dwellings to turbines, implications for aerial firefighting, access to water storages and explain concerns that the community has about the EIS bushfire risk assessment.

Vegetation screening near houses to mitigate the visual impact of turbines may increase bushfire risk. Ask the RFS for an assessment of bush fire risk associated with vegetation screening proposed in the EIS.

Consider inviting the RFS for onsite inspections.

Jupiter Case Study

Over 250 submissions raised concerns about the bushfire risk associated with the wind farm.

The EIS focused on assessing the risk of the wind farm itself causing a bushfire and concluded that the risks were low. It also concluded that the wind farm would not impede aerial support for firefighting around the project area.

The NSW RFS were not consulted by the proponent nor did they make a submission.

Traffic, transport and road safety

Traffic, transport and road safety

NSW Roads and Maritime Services (RMS) will provide advice on the suitability of roads to accommodate the type and volume of traffic associated with a wind farm development and the adequacy of any proposed road upgrades and maintenance commitments.

Considerations include road weight restrictions, over-sized loads, intersections and access roads as well as the routes for delivery of wind turbines and other infrastructure from the dock (eg from the Port of Newcastle) to the project area.

Generally, the Department considers that traffic and transport impacts will be restricted to the construction period and will be suitably managed by road upgrades and traffic controls. The wind farm proponent usually negotiates road upgrades with RMS and the regional councils.

If you have specific concerns about traffic, transport and road safety issues contact the RMS and invite them for an onsite inspection.

Jupiter Case Study

Over 50 submissions expressed concern about increased traffic and safety of users particularly along school bus routes.

Radio interference

Radio interference

Radio, televisions, mobile phones and mobile/fixed radio signals generally need a clear line of sight between the transmitting and receiving locations. Wind farms and other infrastructure have the potential to cause interference with this line of sight. Wind farms also break down the signal as it passes through a process called "reflections of transmission".

The Department’s view is that the current level of service is to be maintained after a wind farm is constructed, and the wind farm operator should make good any disruption of service.

We suggest you gather as much information about reception by studying coverage maps and get radio, TV and mobile phone service providers to provide testimonials as to the current level of service to residences particularly where the wind turbines will obstruct line of sight to transmitter locations.

Blade throw

Blade throw

Blade throw is the structural failure in a turbine blade during operation, resulting in the ejection of projectiles into the surrounding area. A blade throw event is a rare occurrence provided the turbine model is certified to the relevant international standards, has adequate lightning protection, a safety shutdown system as well an ongoing maintenance program.

This is not likely to be an issue unless a dwelling is unusually close to a wind turbine.

Jupiter Case Study

The nearest host dwelling was 550m from a turbine and was considered a safe distance.

Soils

Soils

Soil is closely linked with water and the key issues are erosion and impacts on vegetation and water flow during the construction processes. The type of soil should be assessed in the EIS and the degree of impact indicated. Mitigation measures can be used to varying degrees of effect.

Impacts on soil effect both host properties and non-associated properties.

Some key characteristics of soil landscapes that could be impacted by a wind farm are topsoil erodibility, subsoil erodibility, reduced infiltration, additional surface water flow and salinity. Access tracks, clearing, and construction can all have major impacts.

The network of tracks and trenches connecting the turbines must cross drainage lines. The drainage lines and drainage depressions have the potential for soil erosion and water quality impacts.

The Revised Universal Soil Loss Equation (RUSLE) estimates soil loss and is frequently used by wind farm developers. However, it does not accurately estimate the overall erosion hazard.

Problems with the RUSLE are well known and include the following limitations as stated in the Blue Book (Managing Urban Stormwater: Soils and Construction, Landcom 2004)

“Because the RUSLE takes into consideration all major components likely to affect sheet erosion, it is the most widely used (and abused) soil loss equation available. While it does have great practical value, its limitations should be recognised and understood.”

The main limitations are:

Jupiter Case Study

The Jupiter Wind Farm project area was largely granite soils - infertile, non-cohesive, shallow soils with low water holding capacity and therefore at high risk. Perfect soils for native orchids to flourish. Granite-based soils are easily eroded when disturbed and vegetation is difficult to re-establish on these soils after disturbance.

Evidence presented in the Soil Landscape Mapping Project of Jenkins (1996), suggests that the Jupiter EIS did not adequately address the highly fragile and erosive nature of soils found within the project area.

The majority of the Jupiter project area is located within soil landscapes that have moderate to high soil erosion hazard as defined by Jenkins (1996).

It is probable that, with only a standard suite of soil conservation engineering practices as proposed in the EIS, that the Jupiter project would likely have had a significant overall impact on soil and water resources.

Successful soil erosion control would require a thorough understanding of the soils found in the area. The EIS did not reflect an understanding of this. Evidence suggests that the EIS considerably underestimated the potential for negative impacts on soil and water.

Waste

Waste

The EPA will recommend waste management and disposal practices.

Aviation safety

Aviation safety

Airports, aerodromes and landing strips within the vicinity of the wind farm should be identified and the wind farm’s potential to impact or restrict aviation activities assessed in the EIS. Refer to the Civil Aviation Authority’s Guideline D: Managing the risk to aviation safety of wind turbine installations (wind farms) / wind monitoring towers.

Be aware that private landing strips must also be assessed. These are often used for agricultural purposes and firefighting. The Aerial Agricultural Association of Australia (AAAA) is opposed to all wind farms which are proposed to be built on land that is likely to be affected by bushfire. And if wind farms are built in an area where aerial application occurs then turbines should be placed in straight lines, set back at least 100m from any boundary and powerlines should be underground. Refer to the AAAA’s National Wind Farm Operating Protocols (May, 2014).

We suggest you give a presentation to the AAAA asking them to submit an expert assessment of aerial safety with respect to the nearest landing strips.

Provide them with local knowledge about the proximity of landing strips to turbines, implications for agricultural activities, aerial firefighting, access to water storages and explain concerns that the community has about the continued access to those landing strips

The visual impact of night lighting for aviation safety has been discussed under the Night Lighting heading.

Jupiter Case Study

The community identified two private airstrips 2.5 and 2.8 km from the nearest turbines which were not assessed in the EIS.

The AAAA was not consulted by the proponent nor did they make a submission.

Mineral resources

Mineral resources

There are likely to be mineral exploration licenses within the project area and if approved, the wind farm would not preclude exploration from occurring within the entire project site, only near wind turbines during the wind farm operational life.

So, the turbine layout may or may not interfere with exploration during the life of the wind farm.

Jupiter Case Study

The company holding exploration licenses over 50% of Jupiter objected to the wind farm because the turbine cluster would make access impossible.

Water use

Water use

Water required for the construction of the wind farm is needed for the construction of concrete foundations and infrastructure, dust suppression and in case of fire. As a rule of thumb, estimate the water required as about 100ML per turbine.

There has been a tendency for some proponents to underestimate water requirements.

Examine where water during the construction phase will come from and implications for the local community. Once again, local knowledge might come in handy when identifying specific issues.

The Department will assess this and include appropriate water licenses in the conditions of consent.

Water required during wind farm operation will probably be rainwater captured onsite.

Riparian areas and erosion

Riparian areas and erosion

The wind farm may involve water crossings for site access, internal access roads and cabling.

Expect NSW Roads and Maritime Services (RMS) to provide advice on the suitability of water crossings to accommodate the type and volume of traffic associated with a wind farm development. Water NSW will provide advice on whether the EIS adequately addresses water quality issues and erosion control.

However, unless there are unusual circumstances like highly saline or sodic soils, standard practice soil and erosion management techniques as described in a range of NSW Government guidelines will make any risks to soil erosion and water quality deemed to be manageable.

Once again, local knowledge might come in handy when identifying specific issues.

Jupiter Case Study

Jupiter had many streams and water crossings which were not identified in the EIS. The proponent did not carry out a proper water quality assessment using the NorBe Tool (refer to the Neutral or Beneficial Effect on Water Quality Assessment Guideline 2015) nor was this a specific requirement of the SEARs.

Nobody noticed that the Eastern Gas Pipeline ran through the middle of the Southern precinct, nneither the government agencies, nor the proponent or their consultants, even though it is clearly marked on topographical maps and there was a warning sign every 50m or so down through the middle of the site.

Cumulative Impacts

Cumulative Impacts

The cumulative visual, noise, biodiversity and traffic impacts of multiple wind farms in close proximity must be assessed and are often checked by the Department during peer review when the farms are less than 5km apart.

Jupiter Case Study

There were several nearby wind farms, the closest being 6km away, and the cumulative impact was assessed as insignificant even though many residences were located on ridges overlooking wind farms to the east and west of their properties.

OEH however was concerned about the cumulative impact of wind farms on the flight paths of birds.

Interestingly, the cumulative impacts of each of the 3 wind turbine clusters within the Jupiter project area was not assessed nor was that a stated requirement in the SEARs.

Decommissioning and rehabilitation

Decommissioning and rehabilitation

Decommissioning means that the wind turbines and other infrastructure is removed from the site and revegetated, allowing land to be returned to its former use after about 20 to 25 years. No wind farm owner has ever abandoned a wind farm in Australia nor have any been decommissioned as they have not reached the end of their operating lif. Collector wind farm was the first wind farm in Australia built in 1998 and may be the first to be decommissioned.

The requirements for the owner of the wind farm to decommission and rehabilitate the land at the appropriate time should form part of the host agreement. These agreements are private agreements and the details are not known.

Decommissioning is included by the Department in the conditions of consent. But unlike construction or operational conditions of consent, decommissioning will occur 20 to 25 years down the track, and some would say, are impossible to enforce.

The wider community often expresses concerns about who is responsible should the wind farm owner simply walk away or become insolvent when decommission time looms. These wind farms are on private land and it may well be the hosts who are left to pay for decommissioning.

Social and economic consequences

Social and economic consequences

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. The Hills of Gold Wind Farm proposal is the first to include this requirement and it remains to be seen how the proponent will address this requirement in the EIS and how the Department will assess it.

We sought clarification from the Department 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."

It seems that this requirement is loosely based upon the Social Impact Assessment Guideline, September 2017 for state significant mining projects.

We expect the proponent to consider the positive and negative consequences of a wind farm on:

Some impacts will be positive, other negative, some tangible others intangible and most will be experienced differently depending upon someone’s perspective and relationship to the proposal.

Given the broad ranging consequences and different perspectives, we would expect a wind farm proponent to interview impacted members of the community and community groups individually and to publish transcripts of the interviews.

Security and reliability of the electricity system

Security and reliability of the electricity system

Since May 2018, the security and reliability of the electricity system conditions must be assessed by the proponent including local network conditions. This requirement is based upon a fact sheet Electricity System Security and Reliability Environmental Assessment Requirement May 2018.  The Hills of Gold Wind Farm proposal is the first to include this requirement and it remains to be seen how the proponent will address this requirement in the EIS and how the Department will assess it.

We expect the proponent to address a wind farm capacity to remain operation during events like storms (security) and to despatch power to meet demand (reliability implying a storage capability) and to explain how the technical components of the wind farm will work to achieve this.