6.2.22

Adequacy Review Uungula Wind Farm Environmental Assessment REPORT BY THE DIRECTOR, DEVELOPMENT AND COMMUNITY SERVICES TO 19 JUNE 2013 COUNCIL MEETING Adequacy Review Uungula Wind Farm Environmental Assessment A0100056, A0420260

RECOMMENDATION That: 1. the report by the Director, Development and Community Services on the Adequacy

Review Uungula Wind Farm Environmental Assessment be received; 2. Council make a submission in accordance with attachment 2 to this report.

Executive summary On the 3 June 2013 Council received the Environmental Assessment for Uungula Wind Farm with the adequacy review to be completed by the 17 June 2013. An extension was requested and granted to 20 June 2013 to allow the draft submission to be presented to Council for consideration.

Detailed report The Environmental Assessment describes the project are follows:

The proposed Project development consists of the installation of up to 249 wind turbines, underground transmission line and control cables, overhead transmission lines and control cables, collector substations, switching stations, site compounds, access tracks, crane hardstand and assembly areas, up to six permanent wind monitoring masts (potentially including the retention of existing temporary monitoring masts), appropriate wind farm signage and ancillary features. The Project is to have an installed capacity of approximately 425 MW. Operation of the wind farm is to be carried out by a combination of remote computer control, local operations and maintenance staff. Final wind turbine selection will occur through a competitive tender process pending Development Approval. The wind turbines used for the Project will be three-bladed, semi-variable speed, pitch regulated machines with the rotor and nacelle mounted on a reducing cylindrical tower made out of either a welded steel shell or a concrete steel hybrid, fitted with an internal ladder or lift. Each wind turbine will rise up to 192 m from the ground to the tip of the blades, with typical tower heights of between 80 and 120 m, and blades between 37 and 72 m in length. Wind turbines under consideration for this Project vary in terms of generation capacity upwards of 1.5 MW. Typically wind turbines of this magnitude begin to generate energy at wind speeds in the order of 3.5 to 4 metres per second (m/s) (13 kilometres per hour (kph)) and shut down (for safety reasons) in wind speeds greater than 25 m/s (90 kph). Up to six permanent wind monitoring masts (potentially including the retention of existing temporary monitoring masts), up to 120 m in height, will be installed on-site. The purpose of the masts is to provide necessary information for the performance monitoring of the wind turbines. The wind monitoring masts would be of a guyed, narrow lattice or tubular steel design. The electricity produced by each wind turbine generator would be transformed from low voltage up to 33 kilovolts (kV) by a transformer generally located within or adjacent to each wind turbine. Underground transmission line and control cables will be installed at a

depth of up to 1.2 m below the ground surface to conduct the electricity from the wind turbines to a collector substation. The underground electrical cables will follow internal on-site access roads where practical. Sections of the proposed overhead transmission line may need to be placed underground subject to local requirements. The collector substations and switching station sites are expected to require individual areas ranging from 2.3 to 3.5 hectares (ha) of land and will include standard grid connection infrastructure and buildings. The chosen locations minimise the visual impact of the wind farm by siting the infrastructure away from surrounding public viewpoints, and with vegetation screening, post construction, if warranted. This also allows for the Project’s internal electrical infrastructure and grid connection to have a reduced visual impact. To harness the energy produced, the Project has various options to connect into a 66 kV Essential Energy transmission line, 132 and 330 kV TransGrid transmission line north of the Project site. When it is not generating, the Project will draw a minor amount of electricity from the local transmission network. Project management will be carried out by the Proponent, unless commercial or other arrangements change. All Project and construction management will comply with the appropriate company’s Quality Assurance System and Environmental Management System, or equivalent, ensuring that relevant procedures, statutory requirements and operational standards are met.

The location of the project is illustrated in the figure in attachment 1 to this report. Council submission of the Director’s General’s requirements focused on the following issues:

• Transport and Traffic; • Noise; • Hazards; • Social and Economic; and • Consultation.

At this stage Council has been requested to undertake an adequacy review of the EA with a further opportunity being available for a detailed submission during the exhibition of the EA. Due to the limited time available the major focus of the adequacy review has been the transport and roads component as this is considered to have the potential for the greatest impact on Council’s infrastructure.

TRANSPORT AND TRAFFIC Samsa Consulting Pty Ltd on behalf of the Proponent has undertaken a Traffic & Transport Study, dated May 2013. The Study aims to investigate and assess the construction and operational traffic impacts of the project and takes into account and refers to the requirements as outlined in the DGR and other authority requirements. The study area involves two local government areas, this review is limited to traffic and transport issues within Mid Western Regional Council’s jurisdiction. The report indicates that the construction activity phase (18mths – 2yrs) would generate peak traffic movements associated with project. During this phase vehicles would be comprised of articulated semi-trailers (some with extendible trailers), low loaders, dolly and jinker arrangements, concrete trucks, tipping trucks, cranes and light vehicles. The longest loads will be for blades with trailer lengths of approximately 62m long. The heaviest loads are anticipated to be larger cranes, weighing 135 tonnes, and those importing nacelles with gearbox weighing about 125 tonnes. It is unclear from the report if it is intended to have cranes remain on-site for the duration or use

contractors that would mobilise to site as required. The latter would add to pavement stress due to the increased movements of the heaviest loads. It is outlined that heavier components will be imported to site using low loaders with extendable decks and multiple axles with up to eight tyres per axle. This will disperse point loads on the pavement to around 1600kg per tyre. This reduces the load on the pavement to less than that of conventional semi-trailers and the use of this configuration is appropriate for heavy mass loads. It is proposed to monitor the pavement condition using dilapidation reports before and after the project, although no detail of the criterion or methodology of assessment is offered. It is stated that the oversized vehicles movements would be Restricted Access Vehicles (RAV) requiring RMS permits to operate on public roads. It is also suggested that traffic control (e.g. stop/go) be utilised to help traverse difficult junctions. The report has overlooked the need to contact Council regarding roadworks along the routes that may present impediments to oversized vehicles. It is assumed that acquiring RAV permits is sufficient notification to roads authorities. However, this is often not the case as information regarding such movements is not always conveyed to the local authority that may be undertaking maintenance activities. If traffic control is warranted the approach speeds to traffic controllers would need to be modified in accordance with the Traffic Control at Worksites Manual (June 2010). On RMS controlled roads this would additionally require a Road Occupancy License and Speed Zone Authorisation. These permits and approvals are not addressed by the assessment. There are a number of possible routes from major roads that may be utilised to access the project site, although the final route remains undetermined. The assessment presumes that wind farm components are likely to arrive via the Port of Newcastle as this is the closest sea port and affords the most direct route to the project area. Various major routes were explored with the most relevant to MWRC being from the Golden Hwy to the project site utilising either the Castlereagh Hwy/Goolma Rd or Ulan/Cope Roads via Gulgong or Mudgee. The latter option was considered less feasible due to the constraints of negotiating the urban centres. The preferred route, turning right off the Castlereagh Hwy at the Fisher St. roundabout in Gulgong and continuing along the Goolma Rd, accesses the project site using local roads. Three access points are provided: the Lower Piambong Rd, directly from the Goolma Rd at 19.9km from the roundabout in Gulgong, and the Twelve Mile Rd. Both the Twelve Mile and Lower Piambong Roads present issues for the movement of oversize and heavy mass vehicles. Both roads have overhanging tree limbs and a large number of culverts that would require structural assessment. The Twelve Mile Road has a narrow, single lane bridge on a relatively sharp alignment within 1.1km from the intersection with the Goolma Road. The present form of the bridge poses a significant obstacle for the types of vehicles described in the assessment. The road reserve is quite narrow at this location and realignment for another crossing would likely involve land acquisition. Modifying or replacing the present structure would be expensive and possibly prohibitive for the proponent. The Lower Piambong Rd intersection with the Goolma Rd is located on a curve and presents sight distance issues. The report suggests widening but has not considered the probability the land acquisition would be required to facilitate the treatment. This road is winding with some hair pin bends and numerous narrow stock grids. Oversize trucks negotiating this road would likely be a source of substantial inconvenience for local traffic. Upgrading this road to allow passage of such vehicles would be a major exercise involving realignment, removal of trees and stock grids. Extensive consultation with local landholders would be required if this route was elected and these stakeholders were not identified in the assessment. For the above reasons neither of these access points are preferred. The report does identify another access point 19.9km west of Gulgong, directly off the Goolma Rd. This appears to coincide with a road reserve, known locally as the Donnelly Rd. The Donnelly Rd is comprised of long

straights with good sight distance and little traffic. Within the first ten kilometres of this route there are no drainage structures, one gravel creek crossing and few trees. The report identifies this route as the preferred option and given the problems posed by the other local roads under consideration this recommendation is appropriate. Samsa Consulting Pty Ltd assessed the capacity of the present network to cope with additional traffic using available traffic data from the RMS and councils. It is noted that while some data was from 2005, traffic counts were validated by undertaking a survey in early 2013. The report assessed the current capacity of the network to absorb project generated traffic using the methodology set out in Austroads Guide to Traffic Engineering Practice. The assessment adequately demonstrated that the level of service remained satisfactory. The report also discussed the cumulative impact of other regional developments such as Bodangora and Crudine Ridge Windfarms along with the Cobbora Coal Mine. Due to uncertainty surrounding the timing of various stages of these projects, the Consultants have concluded that further consideration may be necessary once the timetable for the Uungala Wind Farm Project has firmed and progression of the other projects has been confirmed. This point is made in the appended report and should be re-iterated in the main body of the assessment.

LANDSCAPE AND VISUAL ASSESSMENT The EA states the following in relation to the Landscape and visual assessment:

The Proponent commissioned Moir Landscape Architecture Pty Ltd to prepare a Landscape and Visual Impact Assessment (LVIA) for the Project. The LVIA involved a comprehensive evaluation of the visual character of the landscape in which the Project would be located, and an assessment of the potential landscape and visual impacts that may result from the construction and operation of the Project, taking into account appropriate mitigation measures. In terms of overall landscape sensitivity, the LVIA determined that of 83 viewpoints surrounding the Project, 22 will have a low visual impact, 21 will have a moderate visual impact and 29 will have a high visual impact. The LVIA also determined that the Project is likely to be an acceptable development within the viewshed, which in a broader context also contains built elements such as roads, agricultural industry, aircraft landing strips, communication and transmitter towers and transmission lines. There are a number of potential visual effects associated with the wind farm, including glinting, which experience suggests is relatively rare and shadow flicker effects which are likely to be experienced at ten residences. Night time lighting has the potential to be visible from surrounding receptors, however the level of visual impact would diminish over distance and when screened by landform or vegetation. The Project will have some degree of visual influence, however it is unlikely that wind farm projects will ever conform, or be acceptable to all points of view. Overall, the cumulative visual effect of the Project would not result in any significant ‘direct’, ‘indirect’ or ‘sequential’ cumulative impacts when considered against any existing or proposed projects.

The visual assessment provides a detailed report on the potential impacts. It should be noted that three of the area viewpoints considered to experience a high visual impact are on Goolma Road and one viewpoint at the Cudgegong River Park. The impacts on views across Lake Burrundong are quite significance and Council may wish to provide further commentary on these impacts as part its submission during the exhibition of the EA. The assessment includes an assessment of the proposed Bodangora Wind Farm which is less than 9 km from the Uungula project. It is interesting to note that the assessment states that following regarding the potential cumulative impacts:

The existing visual character of Goolma Road is likely to be altered as a combined result of the proposals. Travelling along Goolma Road it is identified that either the Bodangora, Uungula or both wind farms would be visible. Roadside vegetation is a prominent element of Goolma Road which would significantly reduce these potential views. Travelling along Goolma Road the local presence of Wind Farms would be apparent, and it is likely that the wind farms would become the strong characterising element in the landscape. A photomontage has been prepared from Goolma Road (refer to Photomontage 22) to illustrate the potential visual impact of the proposed Uungula Wind Farm from a location identified as having a potential cumulative visual impact. Although this location is likely to have a cumulative visual impact, views towards the Uungula Wind Farm are distant and likely to be low.

The assessment goes on to conclude that The Uungula Wind Farm is a relatively isolated development, set back from major transport routes and views from these major routes as generally obstructed by topography and vegetation. Again this conclusion is one that the Council may wish to address further in the detailed submission.

NOISE The consultants Sonus Pty Ltd were engaged by the Proponent to undertaken a Noise Impact Assessment for the development. The DGRs require that operational noise be assessed against the South Australian Guidelines which at the time of issuing the DGRs were considered to be the most stringent in this Country. In addition to this DP&I requested that the assessment also consider the background levels when separated into daytime and night-time periods as per the approach taken in the Draft NSW Guidelines. The assessment states that

... for any wind turbine model with sound power levels and hub heights that are equal to or less than those assessed for the Acciona AW77 and Vestas V112, the wind farm layout can achieve the stringent requirements of the SA EPA Guidelines. Once the final wind turbine model has been selected, the noise assessment will be re-run to demonstrate compliance with the SA EPA Guidelines and DGRs. Should there prove to be any exceedances at this stage, they will be resolved through micro-siting wind turbine positions, the removal of wind turbines, landowner agreements, or the reduction of wind turbine operational noise, whichever is deemed the most acceptable and appropriate solution to achieve compliance.

Council continues to be concerned regarding the potential impact of noise of State Significant Development on the rural living environment. The Department of Planning & Infrastructure, as well as the proponents, need to understand that when a noise from a wind tower in a rural environment increases the noise level from 12dBa to 40dBa, it has a dramatic effect on the health of the residents, differently to what would happen in a suburban environment, where the background noise levels most of the time are around 35dBa.

ECOLOGICAL ASSESSMENT An extensive assessment has been undertaken by Environmental Resource Management Australia (ERM) on behalf of the proponent. The EA states that the Proponent has made a number of amendments to the proposed layout to minimise and avoid impacts on the ecological values of the site. The assessment includes a Biobanking Assessment resulting in the identification of 5 properties that are currently being investigated as environmental offset locations. Having regard to the potential impacts on Council’s rate base it is considered that this impact should be included in the assessment and Council be adequately compensated as part any Voluntary Planning Agreement that may apply to the project.

AVIATION ASSESSMENT The EA states:

According to the Aviation Impact Statement carried out by REHBEIN Airport Consulting (REHBEIN), the Project does not impact the OLS, but does penetrate the PANS OPS in one instance at Mudgee Airport. The Project also penetrates the surface of the Instrument Flight Rules air route. REHBEIN recommends the Proponent consider the provision of obstacle marking and lighting as a duty of care obligation. On receipt of Development Approval for the Project, and with particular regard to the Aviation Impact Statement, the Proponent will consult with CASA on the issue of obstacle lighting. The Proponent will be seeking a solution, which, if appropriate to do so, will consider the provision of obstacle marking and lighting. If CASA insist on full compliance with the requirements of the NASF Guideline D or the now withdrawn CASA Circulatory AC 139-18(0), the Proponent will commit to shielding provisions allowed under existing CASA guidelines.

Council will need to further investigate any potential impact on the Mudgee airport. The Mudgee Airport provides a critical transport link for the region and Council has invested considerable sums to ensure its ongoing sustainable operation. Due to the limited time to review the EA Council reserves the right to further engage with CASA and the Department regarding the any potential impacts. In addition, it appears that the EA has not made an assessment of the potential visual impacts of the mitigating measures that may be required as these are yet to be fully identified. It is considered that the EA cannot be finalised until such time as CASA’s requirements are fully identified and therefore full impacts of the project and any mitigating measures are assessed. Council stresses that the ability of the Mudgee airport to continue to function and to grow to serve the future needs of the region is critical and should not in any shape or form be placed in jeopardy by the proposal.

SOCIAL AND ECONOMIC IMPACTS It is considered that the Socio- Economic Assessment included in the report is entirely inadequate. Chapter 19 of the Assessment only provides cursory assessment of the potential impacts and fails to address the cumulative impact of growth caused by other State Significant Development within the region. It is considered that the proponent should be required to assess the Local Service Assessment Report commissioned by the DoPI that gives a complete overview of the potential impact of growth and the subsequent impacts on infrastructure. The EA cites the economic benefits that it purports to bring to the area but down plays any impact on the provisions of services. The EA states:

During the construction phase of the Project up to 480 construction jobs could be created which will be filled with a mix of local, state-wide and national construction workers. It is assumed that those construction roles filled by the state-wide and national workforce will temporarily migrate into the region and therefore place some temporary upward pressure on the rental housing market. However it is considered that the construction phase will result in minimal demand for other community infrastructure such as schools or health facilities.

This is a totally unsubstantiated statement. For example, experience has shown that temporary workers have the potential to increase the actual demand on health services 3 fold as each worker as a different health profile and therefore demand. This region has experienced the dramatic impact that temporary workers seeking accommodation can have on tourist accommodation and affordable housing. The EA makes no attempt to undertake a genuine assessment on the potential impacts and the cumulative impacts of state significant development on housing, infrastructure and facilities. It does not attempt to identify the likely domicile of the temporary and permanent workforce and a one page commentary included in the EA is considered a farce.

The DGs requirements included: include an analysis on the potential for social and economic impacts on the local community (demand for the provision of additional local infrastructure and services, including temporary and permanent housing needs, and how this demand will be addressed) In addition in Council’s submission on the DG’s requirements Council stated: Social and Economic

• an assessment of the potential impacts of the project on the local and regional communities, including; temporary and permanent housing needs for the construction and operational workforce and their families (including location, availability and related impacts eg traffic);

– one of the issues that has been overlooked in the past 5 years of major projects in the Mid-Western Region and the Hunter is the second and third tier social impact on communities. For example currently mining employees (from the three major mining projects that have recently been approved in our LGA) may be able to find accommodation but at the expense of other critical staff such as teachers and police. Housing shortages have lead to inflated rents there is currently a zero vacancy rate for rental accommodation in the area. In the case of Mid-Western Regional Council’s recent strategic planning, work has been undertaken to ensure that there is land available for development. However, the area does not have the economic base to bankroll the investment in residential development on the scale that is/will be required to accommodate the anticipated increase on population associated with mining – this project will exacerbate that problem, particularly during the construction stage. Considers the following requirements reasonable:-

• potential impacts on local and regional amenity; an assessment of the demand the project may generate for the provision of additional local infrastructure and services;

• a detailed description of all contributions that would be provided to service the demand on hard and soft infrastructure generated by the project;

• a detailed assessment of the costs and benefits of the project as a whole, and whether it would result in a net benefit for NSW.

It is considered that the EA cannot proceed to exhibition until an evidence based socio –economic assessment is undertaken addressing these critical issues. At this stage insufficient assessment has been undertaken to allow an informed comment by Council. Council reserves the right to make further comment on the any VPA that will be negotiated with the proponent until the full impact of the development is assessed. It is considered that the VPA should be commensurate with that required of the mines. At this stage it is considered that the Community Wellbeing and Community Fund is a random amount that cannot be based on any assessment of socio and infrastructure impact as these impact are yet to be identified.

Financial implications The full financial implications for Mid-Western and the potential impact on infrastructure is yet to be assessed and will be subject of a full report to Council during the exhibition of the EA once the EA is amended to undertake a full socio economic impact assessment.

Strategic or policy implications Not Applicable

CATHERINE VAN LAEREN DIRECTOR, DEVELOPMENT AND COMMUNITY SERVICES 14 June 2013 Attachments: 1. Map showing location of the project. 2. Letter to Department APPROVED FOR SUBMISSION: WARWICK L BENNETT GENERAL MANAGER

ATTACHMENT 2