SOUTHDOWN SOUTHDOWN SOLAR SOLAR FARM FARM
Request for Secretary’s Environmental Assessment Requirements – Scoping Report
‘Cal Col’, 6304 Cobb Highway, Deniliquin NSW 2710
Rev Date Description By Approved
1 22/04/2020 First draft Russell James
2 24/04/2020 Second draft Russell James
3 21/05/2020 Third draft Russell James Amy lane
juwi details
Name juwi Renewable Energy Pty Ltd
Address (Physical) Level 3, 199 George Street, Brisbane, QLD, Australia, 4000
Address (Postal) PO Box 13106 George Street, Brisbane, QLD 4003
Australian Business Number 42 159 228 145
Primary Contact Russell James
Project Development Manager
+61 (0) 7 3107 0908
+61 (0) 447 749 914
Secondary Contact Amy Lane
Head of Development
+61 (0) 7 3107 0908
+61 (0) 413 882 566
Website www.juwi.com.au
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Table of Contents 1 Introduction ...... 5 1.1 The Project ...... 5 1.2 Site and surrounds ...... 5 1.2.1 Regional Context ...... 5 1.2.2 Local Context ...... 7 1.2.3 Site ...... 7 1.3 Landowner ...... 9 1.4 Applicant ...... 9 1.5 Capital Investment Value ...... 9 1.6 Purpose of the Report ...... 9 2 Planning Framework ...... 10 2.1 NSW Environmental and Planning Assessment Act 1979...... 10 2.1.1 Approval Process...... 10 2.1.2 Permissibility ...... 10 2.2 Other State Legislation...... 11 2.2.1 State Environment Planning Policy Koala Habitat Protection 2019 ...... 11 2.2.2 Riverina Murray Plan 2036 ...... 11 2.2.3 Protection of the Environment Operations Act 1997 ...... 11 2.2.4 Water Management Act 2000 ...... 11 2.2.5 Biodiversity Conservation Act 2016 ...... 11 2.2.6 Biosecurity Act 2015 ...... 12 2.2.7 Roads Act 1993 ...... 12 2.2.8 Rural Fires Act 1997 ...... 12 2.2.9 National Parks and Wildlife Act 1974 ...... 13 2.2.10 Heritage Act 1977 ...... 13 2.2.11 Crown Lands Act 1989 ...... 13 2.3 Commonwealth Legislation ...... 13 2.3.1 Environmental Protection and Biodiversity Act 1999...... 13 2.3.2 Native Title Act 1993 ...... 14 2.3.3 Commonwealth Aboriginal and Torres Strait Islander Heritage Protection Act 1984 ...... 14 3 Project Description ...... 16 3.1 Design and Configuration ...... 16 3.1.1 Electricity grid and road access ...... 16 3.1.2 Key elements ...... 16 3.1.3 Potential for battery energy storage ...... 18 3.2 Construction ...... 18 3.3 Operation ...... 18 3.4 Decommissioning ...... 18 4 Justification and Alternatives Considered ...... 20
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4.1 Project Justification ...... 20 4.2 Alternatives ...... 21 4.2.1 Site selection ...... 21 4.2.2 Project design and configuration ...... 21 5 Preliminary Impact Identification and Assessment ...... 22 5.1 Project Issues and Risks ...... 22 5.2 Biodiversity ...... 22 5.2.1 Existing conditions ...... 22 5.2.2 Preliminary Impact Assessment and Management ...... 23 5.2.3 Need for further assessment ...... 24 5.3 Aboriginal Cultural Heritage ...... 25 5.3.1 Existing conditions ...... 25 5.3.2 Preliminary Impact Assessment and Management ...... 26 5.3.3 Need for further assessment ...... 26 5.4 Other Impacts ...... 26 6 Community and Stakeholder Consultation ...... 32 6.1 Consultation activities undertaken ...... 32 7 Proposed Environmental Assessment Requirements ...... 33 8 Conclusion ...... 34 9 References ...... 35 10 Appendices ...... 37
Tables Table 1.1 General project information 5 Table 5.1 Assessment of other impacts and need for further assessment 28
Figures Figure 1.1 Project site regional context 6 Figure 1.2 Project area – land used for cropping and grazing in western part of site 7 Figure 1.3 Project area – land used for grazing in eastern part of site 8 Figure 1.4 The site in local context 9 Figure 3.1 Twin 66kV distribution lines 17 Figure 3.2 All three 66kV lines across the Project area 17 Figure 3.3 Indicative Project Area 18 Figure 5.1 Plant Community Types in the Project area 25 Figure 5.2.3.2 Cleared areas 26 Figure 5.2.3.3 PCT 16 – Black Box 26
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1 Introduction 1.1 The Project The proposed Southdown Solar Farm (the Project) is a utility-scale renewable energy project of up to 130 megawatts (MW) output, to be located approximately 10 km south of the town of Deniliquin in southern New South Wales (NSW). Significant factors which favour this location are the relatively high annual solar irradiance and the available capacity of the Essential Energy electricity distribution network to dispatch the energy generated by the Project.
General information about the project is provided in the following table.
Table 1.1
Name Southdown Solar Farm
Address “Cal Col”, 6304 Cobb Highway, Deniliquin NSW 2710
Proponent juwi Renewable Energy Pty Ltd
Local Government Authority Murray River Council
Titles Lot 1 DP 184442, Lot 1 DP 820113, Lot 4 DP 626349, Lot 267 DP 756325, Lot 5 DP 113290, Lot 194 DP 632131, and Lot 268 DP 756325
Total Areas (approximate) 390 ha under Option to Lease Up to 390 ha to develop
Land use Predominantly, grazing and cropping
Capacity Approx 130 MWp
Connection 2 x 66 kV Essential Energy overhead lines
1.2 Site and surrounds 1.2.1 Regional Context The Murray River Council Local Government Area (LGA) is located to the north of the Murray River, in Southern New South Wales, approximately 250 km north of Melbourne. The Project site is in the north of the Murray River LGA and 10 km south of the town of Deniliquin (which is in the Edward River Council LGA). The main land use in the region is agricultural and the main income is derived from food production and food-processing, with a focus on dairy farming and dairy products. Recently, this focus has been shifting to less water-intensive practices, such as cropping (NSW State Government, 2020). Figure 1.1 shows the Project site within the regional context.
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Figure 1.1 Project site regional context
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1.2.2 Local Context The Project site is in an area of relatively flat land, cleared for agriculture and is bounded by the State-controlled Cobb Highway to the west, the Council-controlled Cal Col Road to the south and by other privately-owned rural properties to the north and east. The Deniliquin electricity sub-station is approximately 12 km to the north-east of the site.
1.2.3 Site The Project area is in the ownership of one landowner, who is engaged in cropping and sheep farming. The land mainly comprises flat, open paddocks, without irrigation, with a long history of agricultural use. The landowner also has a house and sheds on the property. Three 66 kV overhead lines (OHLs) cross the site in parallel with each other, running north-east to south-west. Figures 1.2 and 1.3 show the general Project site and Figure 1.4 shows the Project site in relation to the local road network.
Figure 1.2 Project area – cropping and grazing in western part of site
Figure 1.3 Project area – grazing land in eastern part of site
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Figure 1.4 The site in local context
(Source: EMM)
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1.3 Landowner The landowner is also the occupier of the Project area. The landowner has given permission for the development of the Project.
1.4 Applicant juwi Renewable Energy Pty Ltd (juwi) is a wholly-owned subsidiary of juwi AG, a German-based developer, constructor and operations manager of renewable energy facilities utilizing wind, solar and/or battery energy storage systems (BESS). Globally, juwi AG has offices in 14 countries and has installed over 1,000 wind turbines and more than 1,700 solar PV plants.
The company entered Australia in 2014, initially focusing on microgrids, including solar/BESS hybrid projects. With regard to the development of utility-scale projects, juwi has obtained development approval for three solar projects in Queensland, totaling 300 MW and is working on other projects in NSW and Victoria. The company’s site selection process very deliberately seeks to minimize risks and costs to the project, including all matters which the NSW State government would consider during the Environmental Impact Statement (EIS) process.
1.5 Capital Investment Value The project has an estimated Capital Investment Value of $160m. Because the Southdown Solar Farm is in the preliminary design stage, the value given here is no more than an estimate. The capital cost of the project will exceed the $30 million threshold for it to be classified as a State Significant Development (SSD), as defined under the State Environmental Planning Policy (State and Regional Development) 2011.
1.6 Purpose of the Report This Preliminary Environmental Assessment – Scoping Report (PEA Scoping Report) has been prepared in accordance with the requirements of the Department of Planning, Industry and Environment (DPIE) for projects identified as Significant State Developments (SSDs) and therefore requires an Environmental Impact Statement (EIS) to be prepared under Part 4 of the Environmental Planning and Assessment Act 1979 (EP&A Act).
This report supports a request to DPIE from juwi for the Secretary’s Environmental Assessment Requirements (SEARs) for the EIS.
This report:
describes the proposed development, including project justification and alternatives considered outlines permissibility and strategic planning requirements for the project under NSW and Commonwealth legislative frameworks describes the existing environmental and social context of the project provides a preliminary assessment of project impacts and management sets out previous, current and proposed stakeholder consultation proposes environmental assessment requirements for incorporation into the SEARs.
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2 Planning Framework 2.1 NSW Environmental and Planning Assessment Act 1979 2.1.1 Approval Process The EP&A Act and the NSW Environmental Planning and Assessment Regulation 2000 (EP&A Regulation) provide the framework for environmental planning and assessment in NSW. Part 4 of the EP&A Act relates to development assessment and consent; Division 4.7 relates to the assessment of development deemed to be significant to the State (or SSD), within which, Section 4.36(2) states:
“A State environmental planning policy may declare any development, or any class or description of development, to be State significant development.”
State Environmental Planning Policy (State and Regional Development) 2011 (the SRD SEPP) identifies development that is State Significant Development (SSD). Clause 8 states:
“1) Development is declared to be State significant development for the purposes of the Act if: (a) the development on the land concerned is, by the operation of an environmental planning instrument, not permissible without development consent under Part 4 of the Act, and (b) the development is specified in Schedule 1 and 2.”
1)(a), above, applies to the Project. In addition, Paragraph 20 of Schedule 1 of the SRD SEPP defines relevant SSD for ‘electricity generating works’ (et al) as:
“Development for the purpose of electricity generating works or heat or their co-generation (using any energy source, including gas, coal, biofuel, distillate, waste, hydro, wave, solar or wind power) that— (a) has a capital investment value of more than $30 million, or (b) has a capital investment value of more than $10 million and is located in an environmentally sensitive area of State significance.”
As the Project will have a capital investment value of more than $30m, 20(a) above also classifies the Project as an SSD. As a result, juwi is required to prepare an EIS detailing the potential environmental impacts as a result of the Project and the appropriate management measures. The EIS would be prepared in accordance with the requirements of the DPIE SEARs.
2.1.2 Permissibility The relevant local planning instrument is the Murray Local Environmental Plan 2011 (LEP). Under this LEP, the Project area is designated as ‘Zone RU1 Primary Production’ and the objectives of the zoning are:
To encourage sustainable primary industry production by maintaining and enhancing the natural resource base. To encourage diversity in primary industry enterprises and systems appropriate for the area. To minimise the fragmentation and alienation of resource lands. To minimise conflict between land uses within this zone and land uses within adjoining zones.
The Murray LEP does not include ‘electricity generating works’ amongst uses ‘permitted without consent’ or ‘permitted with consent’. However, under clause 34(7) of State Environmental Planning Policy (Infrastructure) 2007 (the I-SEPP), development of electricity generation works is potentially allowed on any land, with consent. The I-SEPP prevails over the Murray LEP, by virtue of section 3.28 of the EP&A Act 1979.
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2.2 Other State Legislation 2.2.1 State Environment Planning Policy Koala Habitat Protection 2019 State Government’s spatial viewer koala habitat protection (NSW Department of Planning, Industry and Environment, 2020) shows areas requiring ‘Koala Development Application’ and ‘Site Investigation Area for Koala Plans of Management’, within the Project area (and within juwi’s preliminary design area).
The EIS will consider the presence of Koala habitat in the Project area. If such habitat is present a Management Plan will be drafted.
2.2.2 Riverina Murray Plan 2036 The proposed Project falls within the Riverina Murray region of NSW. DPIE has prepared the Riverina Murray Regional Plan 2036 (RMRP) for the region which provides a 20-year blueprint for the future of the Riverina Murray (NSW Department of Planning, Industry and Environment, 2020).
The plan sets out the NSW Government’s vision for the Riverina Murray, which is to create a diversified economy founded on Australia’s food bowl, iconic waterways and a strong network of vibrant and connected communities (NSW Department of Planning, Industry and Environment, 2020).
The Government has set four goals for the region to achieve this vision:
a growing and diverse economy; a healthy environment with pristine waterways; efficient transport and infrastructure networks; strong, connected and healthy communities.
The development of the Project is consistent with these objectives, in particular the development of a growing and diverse economy.
2.2.3 Protection of the Environment Operations Act 1997 The NSW Protection of the Environment Operations Act 1997 (POEO Act) is the principal NSW environmental protection legislative framework and is administered by the NSW Environment Protection Authority (EPA). The Act creates pollution offences relating to land, water, air and noise pollution and imposes a duty on polluters and occupiers to report pollution incidents to the EPA and other government agencies. Solar energy generation does not fall within the definition of electricity generation under Schedule 1 of the POEO Act and therefore does not require an Environment Protection Licence (EPL).
2.2.4 Water Management Act 2000 The NSW Water Management Act 2000 (WM Act) regulates the use and interference with surface and groundwater in NSW where a water sharing plan has been implemented. The Water Sharing Plan for the New South Wales Murray and Lower Darling Regulated Rivers Water Sources 2016 applies to the region in which the Project is located and will be considered in the EIS.
2.2.5 Biodiversity Conservation Act 2016 The NSW Biodiversity Conservation Act 2016 (BC Act) commenced on 25 August 2017 and repealed the following:
NSW Threatened Species Conservation Act 1995; Sections of the NSW National Parks and Wildlife Act 1974 (NPW Act); and NSW Native Vegetation Act 2003.
The BC Act established a new regulatory framework for assessing and offsetting biodiversity impacts for proposed developments. Where development consent is granted, the consent authority may impose as a
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condition of consent, an obligation to retire a number and type of biodiversity credits determined under the new Biodiversity Assessment Method (BAM).
The BC Act is also supported by the Biodiversity Conservation Regulation 2017 and the Biodiversity Conservation (Savings and Transitional) Regulation 2017, which outline the methods to be used in applying the BAM, and specific consideration for transitional projects immediately following commencement of the new framework
Preliminary field surveys were completed by ecological consultants (EMM) in January 2020. The purpose of these field surveys was to undertake preliminary mapping and classification of vegetation to plant community type (PCT) and a high‐level assessment of threatened species habitat within the site. Additional field surveys will be conducted during the preparation of the biodiversity development assessment report (BDAR) and EIS. Substantial work has already been undertaken to avoid and minimise impacts to biodiversity, largely by restricting development to predominantly cleared areas of lower quality ecological values within the project investigation area. A key objective of the Project design will be to use the information from the biodiversity field surveys to avoid and minimise potential impacts on biodiversity values as far as practical and, subsequently, avoid or minimise offset obligations for the Project under the BAM.
2.2.6 Biosecurity Act 2015 The Biosecurity Act 2015 (Biosecurity Act) provides a statutory framework for the management of biosecurity risks from diseases, pests (plant and animal) and contaminants which have the potential to cause harm to the environment, people and the economy. The Biosecurity Act aims to reduce risks by preventing the entry of diseases, pests and contaminants into NSW; by identifying, containing and eradicating new entries; and by minimising potential impacts through appropriate management.
The Biosecurity Act has provisions in place for conferring a power, function or right; or imposing an obligation, for the prevention of the introduction, or control or eradication of invasive pests, such as types of plants and animals which threaten ecosystems, habitats or species. Under the Biosecurity Act, Local Control Authorities such as local councils may appoint authorised officers to enforce weed management and provide direction on complying with obligations under the Biosecurity Act.
The potential for the Project to result in noxious weed, pest and/or pathogen impacts, and control measures to minimise potential impacts, will be considered during the EIS process.
2.2.7 Roads Act 1993 The Roads Act 1993 (Roads Act) provides a framework for the management of roads in NSW. It provides for the classification of roads and the declaration of Transport for NSW (TfNSW) and other public authorities as roads authorities for both classified and unclassified roads. The Roads Act confers functions on TfNSW and other roads authorities and allows distribution of such functions between TfNSW and other roads authorities. The Roads Act sets out procedures for the opening and closing of public roads and regulates the carrying out of various activities on public roads.
For the EIS, a traffic impact assessment outlining any requirements for use of roads in the area will be included. If required, approval from TfNSW or local council will be sought under section 138 of the Roads Act.
2.2.8 Rural Fires Act 1997 The NSW Rural Fires Act 1997 (RF Act) aims to prevent, mitigate, and suppress bush and other fires in local government areas of the State. Section 63 (2) of the RF Act requires the owners of land to prevent the ignition and spread of bushfires on their land. Under Section 4.42 of the EP&A Act, a bush fire safety authority under Section 100B of the RF Act is not required for an SSD that is authorised by a development consent.
The NSW Rural Fire Service (RFS) Bush Fire Prone mapping tool indicates that parts of the site are bush fire prone. Advice will be sort from local RFS representatives, in respect of mitigation measures to adopt in the design of the Project site.
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2.2.9 National Parks and Wildlife Act 1974 The National Parks and Wildlife Act 1974 (NPW Act) is the key legislation governing the management of the State’s parks, conservation areas, reserves, historic sites, and places and objects of aboriginal cultural heritage significance. It also provides for the protection and care of native fauna and flora. Places or objects of Aboriginal cultural heritage on or in the vicinity of the site will need to be managed in accordance with the NPW Act. Clause 86 of the Act states: a person must not harm or desecrate an object that the person knows is an Aboriginal object. Under Section 89J of the EP&A Act, an Aboriginal heritage impact permit under section 90 of the NPW Act would not be required for an SSD, unless the requirement of an environmental planning instrument for consultation or concurrence specifies that it applies to SSD.
A desktop assessment of the Project’s potential impact upon Aboriginal cultural heritage has been undertaken and is considered in this Scoping Report. This will be further assessed during the EIS process.
2.2.10 Heritage Act 1977 The Heritage Act 1977 provides a legal framework for the management of items and places of State heritage significance, providing for their protection. The Act encourages conservation of the State’s heritage and provides for the identification and registration of items of State heritage significance. Under Section 89J of the EP&A Act, an approval under Part 4, or an excavation permit under section 139, of the Heritage Act 1977 would not be required for an SSD. Any existing or unknown or other potential unknown State heritage items will be managed under the Heritage Act 1977.
The potential for the Project to have an impact upon historic cultural heritage has not been considered in this Scoping Report and will be addressed during the EIS process.
2.2.11 Crown Lands Act 1989 The Crown Lands Act 1989, administered by the Minister for Crown Lands, regulates the management of Crown land for the benefit of the people of New South Wales and in particular to provide for:
a) a proper assessment of Crown land, b) the management of Crown land having regard to the principles of Crown land management c) contained in this Act, d) the proper development and conservation of Crown land having regard to those principles, e) the regulation of the conditions under which Crown land is permitted to be occupied, used, sold, f) leased, licensed or otherwise dealt with, g) the reservation or dedication of Crown land for public purposes and the management and use of h) the reserved or dedicated land, and i) the collection, recording and dissemination of information in relation to Crown land.
Under Part 3 of the Crown Lands Act, a land assessment is required to be undertaken for any matters affecting Crown Land.
The potential impacts (if any) of the Project, on Crown land, have yet to be assessed and will be addressed during the EIS process.
2.3 Commonwealth Legislation 2.3.1 Environmental Protection and Biodiversity Act 1999 The Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act), administered by the Commonwealth Department of Agriculture, Water and the Environment (DAWE), requires approval from the Environment Minister for actions likely to have a significant impact on a Matter of National Environmental Significance (MNES).
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The EPBC Act identifies the following nine MNES:
World heritage properties National heritage places Wetlands of international significance (Ramsar wetlands) Nationally threatened species and ecological communities Migratory species Commonweatlh marine areas Great Barrier Reef Marine Park Nuclear actions A water resource, in relation to coal seam gas development and large mining development
Any proposed action likely to have a significant impact on the following must be referred to the DAWE to determine whether the action is a ‘controlled action’ and includes:
Actions that have a significant impact on MNES Actions that (indirectly or directly) have a significant environmental impact on Commonwealth land Actions carried out by the Commonwealth Government
The assessment of the significance of the impact is based on the criteria listed in the DAWE’s Significant Impact Guidelines 1.1 (Department of Agriculture, Water and the Environment, 2020). Should the Environment Minister decide the action will be taken in a manner that will ensure it will be likely to not have an adverse impact on the MNES, approval will be granted.
The EIS will consider the requirement for an ‘EPBC Referral’ to the Minister and this will be further assessed during the EIS process.
2.3.2 Native Title Act 1993 The Native Title Act 1993 provides a National framework for the recognition and protection of native title i.e. the rights and interests, recognised by common law, possessed under traditional laws and customs of Aboriginal and Torres Strait Islander people.
The Act recognises the ownership (or set of rights and interests) of land or waters by Aboriginal and Torres Strait Island groups prior to European Settlement and provides a mechanism for determining where native title exists, who holds it, and identifies compensation for actions affecting it. The Act establishes ways in which future dealings affecting native title may proceed and sets standards for those dealings.
People who hold native title have a right to practice their traditional laws and customs, whilst respecting Australian laws, and have a right to a) be consulted with regarding any proposed action on their land b) receive compensation for that action. In areas where native title existence has not been determined, a compensation application can be made by a registered native title body corporate or group of people asserting native title rights.
The potential existence of native title within the proposed project area will be considered during the EIS process.
2.3.3 Commonwealth Aboriginal and Torres Strait Islander Heritage Protection Act 1984 The Aboriginal and Torres Strait Islander Heritage Protection Act 1984 enables the Australian Government to respond to requests to protect areas and objects of particular significance to Aboriginal people, if it appears that state or territory laws have not provided effective protection.
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The Australian Government can make a declaration to protect an area, object or class of objects from a threat of injury or desecration. However, the government cannot make a declaration unless an Aboriginal person or group of persons has requested it. A declaration is only made if the relevant processes of the state or territory have been exhausted.
This Scoping Report considers the potential presence of Aboriginal heritage within the project area and this will be further assessed during the EIS process.
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3 Project Description 3.1 Design and Configuration 3.1.1 Electricity grid and road access There are three 66kV lines, operated by Essential Energy, crossing part of the Project site and two of these have the capacity to dispatch the energy produced by the solar farm. Connection to these two lines will be via a sub-station contained within the boundary of the solar farm (see Figure 3.3).
Figure 3.1 Twin 66kV distribution lines Figure 3.2 All three 66kV lines across the Project area
The major, local State road is the Cobb Highway, connecting the site with Deniliquin to the North and Moama and Victoria to the South. Access to the site will be from the Council controlled Cal Col Road, which connects directly to the Cobb Highway and serves a small number of rural properties (see Figure 1.4).
3.1.2 Key elements The Project will have an output of up to 130 MW. The final design will be dependent upon grid considerations, stakeholder engagement, environmental constraints, and the availability of materials and commercial considerations, close to the time of construction. Based on preliminary design work, juwi anticipate deploying approximately 335,000 photo-voltaic modules, mounted on single-axis tracker assemblies, in rows aligned in a north-south direction. The trackers will be mounted on driven or screwed piles; at this stage juwi anticipates these will be supported by the ground, without the need for concrete. The maximum height of the mounted modules will be approximately 3.50 metres. The direct current from each module is collected and converted to alternating current by approximately 40 inverters, located in 20 dispersed stations, within the solar farm. A sub- station compound (approx. 50m x 70m) within the site, and close to the Essential Energy overhead lines, will
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comprise one 33/66kV transformer and associated switchgear (some of which will be owned and operated by Essential Energy).
It is anticipated there will also be a shed for storage of replacement parts and maintenance equipment and an office and mess room. Several internal tracks (unsealed) will be formed. The Project will be enclosed within a standard security fence, likely to be chain-link to 2m with barbed-wire strands above. It is likely that a closed- circuit tv monitoring system will be installed.
Figure 3.3 Indicative Project area
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3.1.3 Potential for battery energy storage Whilst the solar farm is being designed without a Battery Energy Storage System (BESS), space will be made to provide one, near to the sub-station, at a later date.
3.2 Construction Construction of the Project is expected to take approximately 15 months and is anticipated to begin in 2022. Activities will be conducted during normal daytime work hours, by a workforce of up to 200 full-time equivalent (FTE) employees. It is anticipated that workers will be located largely in the town of Deniliquin, with the possibility of some resident, or finding accommodation in, Moama/Echuca and Finley.
Noting that there will be an increase in the volume of traffic on the Cobb Highway and Cal Col Road, delivering plant, materials and workers to site, a Traffic Impact Assessment will be undertaken, to be incorporated in the EIS. At this stage, the route of construction traffic is unknown. Many components sourced from overseas arrive containerised; shipping, port and haulage costs, and timeliness, are all considerations in choosing the route for these items. Material for civil works will be sourced as locally as possible and could arrive to site from North or South, on the Cobb Highway.
For the construction period, it is likely that secure laydown and storage areas will be formed within the Project area.
The need for heavy civil works such as grading/levelling and compaction of the site will be minimised, as the flattest land areas within the Project boundary will be used and these are already mostly cleared of vegetation. Civil works will be required to prepare the site by installing fencing, internal access tracks, and minor earth works. Some heavier earth moving will be required for certain project infrastructure (e.g. substations) in those instances where a level pad is necessary.
During site establishment works, measures will be introduced to mitigate potential impacts on the environment and sensitive receptors close to the development footprint. Where required, additional or improved drainage channels, sediment control ponds and dust control measures will be implemented. Laydown areas and waste handling, fuel and chemical storage areas will be placed to minimize potential environmental impacts during construction.
3.3 Operation The Project is expected to be operational for approximately 30 years, with the potential to run longer than this, if financially viable.
It is anticipated that the facility will require regular maintenance throughout its operational life, including replacing PV modules, repair and replacement of inverters, maintaining vegetation, fencing, drainage and internal roads. It is expected that up to 5 FTEs will be on site at a time and regular light vehicle access will always be required.
Heavy vehicles may be required occasionally for replacing larger components such as transformers or components of a BESS (should one be installed); individually, these activities are not likely to occur more than once every 10 years. Operations and Maintenance (O&M) activities will typically be undertaken by specialist subcontractors and/or equipment manufacturers.
juwi may consider sheep grazing on the land, to manage grass underneath the solar panels during operation. Protocols will be developed to ensure biosecurity is maintained and that activities do not impact on the safe and efficient operation of the solar farm, O&M staff, or nearby properties.
3.4 Decommissioning When the decision is made to cease operating the solar farm, all components will be removed to a depth of 1 metre below the surface and the land returned to a state consistent with agricultural use. During this time a
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number of workers will be required on site, along with plant and heavy vehicles (although the number of each will be much less than during construction). As much material as possible will be recycled, with the remainder removed to approved waste management facilities.
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4 Justification and Alternatives Considered 4.1 Project Justification In the first 12 months of operation, the Southdown Solar Farm would be capable of producing over 257,000 Megawatt-hours (MWh) of electricity, equivalent to the consumption of around 46,000 NSW homes (based on average domestic consumption in the Essential Energy region), with almost zero direct carbon dioxide emissions and at a lower price than coal- or gas- fired generators in NSW.
By replacing electricity otherwise produced by coal- or gas-fired power stations, the Project will contribute to Australia’s targets as part of its commitments under the United Nations Paris Agreement on Climate Change. Under this Agreement, Australia aims to reduce carbon dioxide emissions by 26-28% below 2005 levels by 2030. 257,000 MWh of electricity generated by a black-coal-fired power station results in, approximately, 238,000 tonnes of carbon dioxide emissions (Clean Energy Regulator, 2020).
At State level, the NSW government has recently launched a strategy to reach net-zero greenhouse emissions, including reducing emissions by 35% by 2030 (compared to 2005 levels) and the electricity sector has been identified as a key part of the strategy (NSW Government, 2020).
The electricity system operates as a market, with generators selling their output in the ‘wholesale’ market. In NSW, the demand for electricity, generally, exceeds the supply from NSW-based generators, leading to higher wholesale electricity prices than if the two were in equilibrium; higher wholesale prices feed through to higher retail prices for all consumers. Thus, increasing the supply of electricity, by increasing the number of lower-cost generators, is advantageous for NSW electricity customers. The Project will generate electricity at a lower price than existing fossil fuel-fired plants (and much lower than a new-build fossil fuel plant) and, therefore, assist in reducing retail prices in NSW.
Looking ahead, four NSW coal-fired stations will close in the next sixteen years: Liddell, Vales Point, Eraring and Bayswater (AEMO, 2020), with the loss of 8,520 MW of capacity. These four plants alone comprise around 85% of the NSW coal-fired fleet. The Liddell power station is scheduled to close the first of its four turbines in 2022 and all its turbines will have shut down by mid-2023 (AEMO, 2020). Liddell has a stated capacity of 1680 MW, which is a significant loss of capacity in NSW and its closure increases the likelihood of higher prices and increases the risk of insufficient supply, leading to blackouts, across the State, at times of high demand. In all cases, these plants will require replacing with lower cost generation, to avoid higher electricity prices and the risk of blackouts. Fortunately, solar farms, such as the Southdown Solar Farm, will make this possible.
AEMO has identified a number of Renewable Energy Zones (REZs) within each State and the Project will be within the South West NSW REZ (AEMO, 2020). REZs have been identified through modelling which takes account of solar (and wind) resource, the electrical network and the match with demand, topography, typical property sizes, degree of vegetation, of protected areas and of urbanization, and population density. AEMO has assessed the South West NSW REZ as having the potential for 4,000 MW of utility-scale solar. State government’s ‘Net Zero Plan Stage 1: 2020-2030’ also refers to this REZ (NSW Government, 2020).
Three major transmission infrastructure projects are planned in Southern NSW which will facilitate the export of electricity from the REZ, to areas of significant load. The EnergyConnect (Electranet & Transgrid, 2020) NSW to South Australia interconnector has already received approval from the Australian Energy Regulator (AER), while the Humelink (Transgrid, 2020) and VNI West (AEMO, 2020) projects are undergoing regulatory investment tests by the AER.
During the construction of the Project, around 200 workers will be required, with as many as possible recruited from the local area and the majority of the workforce staying in nearby towns. Processes will be in place to source as many goods and services from local businesses, as practical. In recent years, the area has seen a decline in demand for goods and services, as local agricultural practices have become less labour-intensive and, based on discussions with representatives of businesses in Deniiquin, the opportunity to be involved with the Project would be very welcome (Muir, 2020).
Once in operation, there will be maintenance of grounds, fencing and the plant itself and it is anticipated the Project will require up to 5 local FTE employees.
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4.2 Alternatives 4.2.1 Site selection For all projects, juwi undertakes analysis of constraints and opportunities to identify potential project sites in NSW and other States. This process has included consideration of factors such as:
the regulatory environment for renewable energy projects solar irradiation levels access to and the capacity of the existing electricity network potential for land acquisition land suitability (topography, existing land use, flood risk, zoning etc.) the need to minimise the environmental and social impacts (e.g. avoiding sensitive environments, or areas of cultural heritage value).
The proposed location for the Southdown Solar Farm emerged, as a result of the above, as a site with high potential and low impact and the decision was taken to proceed with pre-development investigations and activities. Where alternatives are identified, these are also pursued for their development potential.
4.2.2 Project design and configuration The design and configuration of the Project will incorporate the findings of subsequent studies and investigations undertaken in preparation of the EIS, including consideration of environmental and social factors such as:
identifying and operating within any environmental constraints (such as avoiding areas within the project area that may be of conservation significance) minimising disruption to local landholders minimising adverse amenity issues to nearby properties considering the expectations and concerns of the local community and Murray River Council.
These aspects will be balanced against the need to achieve design, construction and operational efficiencies to reduce the Project costs and maximise revenues.
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5 Preliminary Impact Identification and Assessment 5.1 Project Issues and Risks The proposed development of the Project may result in a number of potential environmental and social impacts, both positive and negative. The nature and extent of these potential impacts will be assessed during the EIS process so that effective avoidance, management and mitigation measures can be incorporated into project design, construction, operation and eventual decommissioning.
Overall, the Project is expected to be a relatively low risk development due to the inherently low impact nature of solar farm construction and operation, and the location of the project away from areas of high environmental sensitivity. An initial assessment of environmental and social risks by juwi has identified two areas of potential impact that warranted preliminary assessment at the PEA Scoping Report stage:
potential impacts on ecological values such as local habitat for threatened and endangered species and potential impacts on Aboriginal cultural heritage, which, although considered a low likelihood, will require specific assessment and consultation.
Sections 5.2 to 5.3 discuss these preliminary assessments further.
The initial assessment of environmental and social risks also identified a number of other potential environmental or social impacts:
Land use impacts Hydrology and water resource management Traffic and transport Visual amenity Socio-economic impacts Noise impacts Air quality and dust Airfield impacts Historic heritage Electric and magnetic fields Bushfire hazard Contamination Waste management.
These other impacts are considered to be lower risk than biodiversity and cultural heritage impacts and are readily manageable by undertaking relevant assessments and implementing robust management and mitigation procedures. The other impacts are discussed further in Section 5.4.
5.2 Biodiversity
5.2.1 Existing conditions A detailed desktop assessment has been undertaken, followed by a two-day field survey in December 2019 by ecologists. The ‘NSW State Vegetation Type Map –Riverina-Murray’ (NSW Department of Planning, Industry and Environment, 2020) is the relevant map for the Project area.
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The majority of the Project area is cleared of native vegetation and is used for cropping, production of livestock fodder and sheep grazing and is composed of exotic vegetation with very few biodiversity constraints. Clear evidence of tilling and sowing is evident through much of the Project site. Dominant exotic species include Ryegrass (Lolium sp.), Wild Oats (Avena sativa), Barley Grass (Hordeum leporinum), Squirrel Tail Fescue (Vulpia bromoides) and Paterson’s Curse (Echium plantagineum). Native species persist in low densities within the cropping, included Speargrass species (Austrostipa sp.), Wallaby Grass species (Rytidosperma sp.), Salsola australis and Bluebush species (Maireana sp.).
Pockets of native vegetation remain and, in aligning them with Plant Community Types, these were found to differ slightly from the NSW State Vegetation Type Map – Riverina Murray and contained the following types:
PCT 74 Yellow Box - River Red Gum tall grassy riverine woodland of NSW South Western Slopes Bioregion and Riverina Bioregion – ‘poor’, ‘planted’ and ‘other’; PCT 13 Black Box - Lignum woodland wetland of the inner floodplains in the semi-arid (warm) climate zone (mainly Riverina Bioregion and Murray Darling Depression Bioregion – ‘regenerating’; PCT 16 - Black Box grassy open woodland wetland of rarely flooded depressions in south western NSW (mainly Riverina Bioregion and Murray Darling Depression Bioregion) – ‘poor’.
Using NSW DPIE’s Bionet records, the desktop assessment identified a total of six flora species, six mammals and 36 threatened birds which have been recorded within 10 km of the Project area. The Superb Parrot was the only species recorded directly adjacent to the site, with several records along the Cobb Highway.
The Commonwealth Department of Agriculture, Water and the Environment’s (DAWE’s) Protected Matters Search Tool (PMST) (which identifies matters protected by the Environment Protection and Biodiversity Conservation Act 1999) lists a total of five Threatened Ecological Communities (TECs) and 21 threatened species, comprised of five flora species, nine birds, three fish, two frogs and two mammals, which may occur within the vicinity of the Project area.
During the field survey, no threatened flora species were recorded, and these are unlikely to occur within the cleared areas of the site as a result of the cultivation and sowing of exotic pasture grasses. The woodland habitat is considered sub-optimal for threatened flora species given the high levels of disturbance and high prevalence of exotic species.
No significant fauna species were recorded during the survey. Fauna habitat is largely restricted to the woodland patches and scattered trees. These trees have the potential to support threatened bird and bat species, providing seasonal foraging resources for nectivores and nesting/roosting opportunities for hollow nesting birds and bats.
5.2.2 Preliminary Impact Assessment and Management 5.2.2.1 In general As the project is state significant, the NSW Biodiversity Offset Scheme (BOS) will be triggered which will likely require a Biodiversity Assessment Report (BDAR). All the woodland vegetation zones have the potential to require offsetting under the BOS, if they exceed the vegetation integrity score threshold (derived from plot data). The site contains a number of scattered trees, which will also be considered under the BOS. 5.2.2.2 Cleared areas Of the total development area, approximately 375 ha (96%) is cleared and the vegetation is highly modified from its original state, associated with a long history of agricultural land use and composed of exotic species. These areas are not likely to require any biodiversity offsets, given that any vegetation present is not native and habitat quality is very low. The majority of the solar farm will be built in these areas. 5.2.2.3 PCT 16 - Black Box grassy open woodland wetland of rarely flooded depressions in south western NSW (mainly Riverina Bioregion and Murray Darling Depression Bioregion) - POOR In total, there is approximately 6.77 ha of this PCT. This community type is not listed as a protected matter under the EPBC Act, nor does it have status under the NSW BC Act 2016. It does have the potential to generate
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ecosystem credits and species credits (the latter if threatened species are recorded or assumed). The preliminary design of the solar farm impacts some pockets of this PCT. The preliminary design is subject to the outcome of further investigations, including in respect of biodiversity offsets. 5.2.2.4 PCT 74 Yellow Box - River Red Gum tall grassy riverine woodland of NSW South Western Slopes Bioregion and Riverina Bioregion – POOR, PLANTED, OTHER Some of these PCTs have status conferred by the EPBC Act, and/or the BC Act and are candidates for the Project being assessed as causing Severe and Irreversible Impacts (SAII) on biodiversity values, under NSW BC legislation. These areas will be avoided, with no solar farm activity affecting them. 5.2.2.5 PCT 13 Black Box - Lignum woodland wetland of the inner floodplains in the semiarid (warm) climate zone (mainly Riverina Bioregion and Murray Darling Depression Bioregion) – REGENERATING This community is not listed under the EPBC Act or the BC Act. This area will be avoided, with no solar farm activity affecting it.
Figure 5.1 Plant Community Types in the Project area
5.2.3 Need for further assessment 5.2.3.1 In general Amongst the potential threatened flora species, the two most likely species to occur are the Slender Darling Pea (Swainsona murrayana) and Silky Swainson-pea (Swainsona sericea). Whilst these species are most likely absent, for the EIS, juwi will implement the recommendation of our ecology consultants to undertake targeted surveys during the full biodiversity assessment to confirm their presence or absence.
Many of the threatened fauna species which will utilise the woodland vegetation communities are ecosystem credit species and do not require targeted field survey or additional credits beyond that generated by the vegetation community, under the NSW BOS. Of most relevance for this project are species credit species with
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potential breeding habitat such as Major Mitchells Cockatoo (Lophochroa leadbeateri) and the Superb Parrot (Lathamus discolor). 5.2.3.2 Cleared areas It is likely that further work within cleared areas will be limited to biometric plots to demonstrate that the vegetation is below the vegetation integrity offset score and therefore does not require offsets.
5.2.3.3 PCT 16 - Black Box grassy open woodland wetland of rarely flooded depressions in south western NSW (mainly Riverina Bioregion and Murray Darling Depression Bioregion) – POOR
Biometric plots will be required to determine if the zone is above or below the vegetation integrity score, for the purpose of the NSW BOS.
5.3 Aboriginal Cultural Heritage 5.3.1 Existing conditions A desktop due diligence assessment has been undertaken, including a literature review and relevant database search by an archaeological consultant. The historical context and recorded finds are of note.
The Murray River began to develop at the end of the Pleistocene (approximately 18,000 years ago), and by the Holocene (12,000 years ago) is considered to have been one of Australia's most productive riparian societies. This broad-based economy ensured that year-round there was an abundance of crayfish, wild fowl or freshwater fish and the topography around the river encouraged small game to the lagoons and billabongs surrounding the channel. River gums that lined the bank were ideal for materials used to manufacture watercrafts typically used on inland water systems and plant fibres were useful in weaving traps and nets in order to catch fish, ducks and emu (EMM, 2020).
The Project area is located approximately 80 m above sea level (ASL) on a gentle hill slope sloping towards the Edward River, which flows approximately 2.5 km east of the Project area. The soils of the Project area are known as the Bunnaloo soil landscape which is a residual soil type near higher alluvial plains near large river systems. This soil landscape follows the Cadell Scarp which sits upon the Cadell Faultline which runs directly
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under the Project area and which likely diverted the Murray and Goulburn river systems. The Cadell Fault is associated with Aboriginal cultural stories that are said to go back 30,000 years.
In the region there are a significant number of recorded burial sites, many near waterways, including sites recorded around Deniliquin.
In addition to the proximity of the existing Edward River, aerial photographs indicate the presence of dry riverbeds or paleochannels (an inactive watercourse which has potential of preserving Tertiary, Eocene and/or Holocene sediment) within the Project area.
An Aboriginal Heritage Information Management System (AHIMS) search was conducted on 16 December 2019. The search covered approximately 23 km x 23 km, only nine sites were identified: all scar or carved trees. It is considered that the small number of sites is likely due to a lack of surveys in the area, and not lack of sites.
The Local Aboriginal Land Council is Deniliquin.
5.3.2 Preliminary Impact Assessment and Management In NSW, Aboriginal objects, whether recorded or yet undiscovered, are afforded statutory protection under the National Parks and Wildlife Act 1974 (NPW Act). Under Section 86 of the Act, it is an offence to disturb, destroy or deface Aboriginal objects without approval. A breach of Section 86 of the NPW Act could result in prosecution and fines in excess of $1 million. The Aboriginal due diligence process is a first step in deciding if detailed investigation is required.
Whilst most of the Project area has been subject to disturbance, it is unclear whether this level of disturbance has removed enough topsoil to reduce archaeological potential to ‘low’. Objects may survive ex situ (that is, not within the original deposit but left behind after erosion), which would be visible on the surface.
5.3.3 Need for further assessment Based on the environmental and archaeological background of the region, it is considered that the Project area has high potential for the presence of Aboriginal objects. juwi will follow the recommendation of our consultants and commission an Aboriginal Cultural Heritage Assessment (ACHA) with field survey, including consultation with the local Aboriginal stakeholders.
The ACHA will be guided by the following best practice documents:
Code of Practice for Archaeological Investigation of Aboriginal Objects in NSW (Department of Environment, Climate Change and Water NSW, 2020); Guide to Investigating, Assessing and Reporting on Aboriginal Cultural Heritage in NSW (Office of Environment and Heritage, Department of Premier and Cabinet, 2020); and Aboriginal Cultural Heritage Consultation Requirements for Proponents (Department of Environment, Climate Change and Water, 2020).
5.4 Other Impacts A Construction Environmental Management Plan (CEMP) will be prepared for the Project, which will detail the avoidance, mitigation, and management measures for all potential environmental impacts associated with construction of the Project. This will include (but not limited to) sediment and erosion, water quality, noise, dust, biodiversity, traffic and waste. Separate management plans will be prepared for social aspects including, community consultation, landscape and visual amenity, and cultural heritage. The CEMP will ensure the Project is delivered in accordance with relevant environmental legislation and guidelines. All construction staff will be trained and inducted to ensure construction works comply with the CEMP and construction activities will be routinely audited against the CEMP.
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The following table outlines other potential environmental or social impacts, management and mitigation procedures and the need for further assessment during the EIS.
Table 5.1 Assessment of other project impacts and need for further assessment Existing conditions Preliminary impact assessment and Need for further assessment management
Land use impacts
The project area is currently There will be loss of land and production An assessment of the impact of the used for agriculture. for the duration of operation of the solar Project on land use (during construction, farm. The loss is unlikely to significantly operation and decommissioning) would The Project area is designated impact the region’s overall agricultural be undertaken as part of the EIS Class 4 under the NSW Land output. process. and Soil Capability assessment (NSW Government, 2020). Construction and operation of the Project This would include an assessment of the is expected to result in only minor ground impact of the development on disturbance, primarily associated with agricultural land and paying particular access road construction within the site, attention to the compatibility of the pile driving and trenching. However, development with the existing land uses where soils are disturbed, soil erosion and on the site and adjacent land during sedimentation issues can result. All soil construction, operation and and erosion impacts will be managed by a decommissioning, with reference to the Sediment and Erosion Control Plan, zoning provisions applying to the land. included in the CEMP. All infrastructure to a depth of 1 metre below the existing surface level would be removed during project decommissioning.
Rehabilitation will ensure the land is returned to its former agricultural capability. A Decommissioning Plan will be prepared for the Project.
Hydrology and water resource management
The Project area is not in a Flood Construction and operation of the Project Impacts to water quality, Planning Area, as designated in is expected to result in only minor ground waterways and surface the Murray Local Environmental disturbance, primarily associated with the hydrology during construction Plan 2011. The site is elevated construction of access roads, pile driving above the Edward River and and trenching. The risk of impacts to and operation would be slopes gently towards it. water quality, surface hydrology, dams assessed as part of the EIS and local waterways from erosion runoff process, and include an or disturbance of acid sulphate soils (if assessment of the potential present) is considered low. Erosion and sediment control measures, and water impacts on: quality monitoring, will be managed in surface water and accordance with the Sediment and groundwater resources, Erosion Control Plan, included with the including (where identified) CEMP. watercourses, wetlands, The Project and associated infrastructure riparian land, groundwater are unlikely to have significant impact on
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Existing conditions Preliminary impact assessment and Need for further assessment management the surface flow of water and will be sited dependent ecosystems and to avoid impact on retained farm dams. acid sulphate soils The Project is not expected to present a related infrastructure and flood hazard. water management systems The Project is not expected to disrupt including dams and flood current water management systems within the project area. management measures adjacent licensed water users The risk of groundwater impacts during construction is expected to be low as measures proposed to excavation will not be required to erect the monitor, reduce and mitigate solar panels and trenches for these impacts underground cables will be shallow. soil and sediment Water use during project construction and management measures will be operation will be minimal and water will be undertaken in accordance with either sourced from existing bores on site or brought to site as required. Managing Urban Stormwater: Soils & Construction (Landcom, 2020). Traffic and transport
The Project site adjoins the Cobb Access to the site during construction and A traffic impact assessment will be Highway, which is a State- operation is expected to be from Cal Col undertaken as part of the EIS process managed road. Road (see Figure 1.4, page 10). including an assessment of the site access route, site access point and likely The Cobb Highway is a sealed, Transport impacts as a result of the transport impacts of the development on single carriageway road, running proposed project would be largely limited the capacity and condition of roads, and broadly North-South for 570 km, to the construction phase and result from a description of the measures that would with a short section in Victoria. haulage of plant, equipment and be implemented to mitigate any impacts materials, and movements of workers to Access to the site will be from the during construction. and from the site. Cal Col Road, an unsealed Council-managed road, running, It is expected there would be an increase East-West for around 3 km. in traffic on the local road network during construction. However, this would occur during normal hours of construction and would be managed in consultation with Transport for NSW and local Councils, where relevant, to minimise the risk of adverse impacts to local road users.
Road upgrades are expected to be required for the Highway intersection. Standard traffic management measures would be implemented, such as ensuring vehicle road-worthiness, enforcing speed limits, erecting signage, proper design of site access points, and ensuring access roads within the site are properly engineered.
Socio-economic impacts
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Existing conditions Preliminary impact assessment and Need for further assessment management
The project area is in the Murray Construction of the project would provide The EIS would assess the potential River LGA which had a immediate social and economic benefits impacts of the project on the local population of approximately to the local community. The project would community and include consideration of 12,000 in 2018 (ABS, 2020). increase local employment opportunities, accommodation and other services for whilst helping NSW to sustainably meet construction workers. The LGA covers an area of its energy needs. 1,186,348 ha. The EIS would assess potential Pressure on local services including accommodation in Deniliquin and other The area’s primary income is accommodation, health services and regional towns within acceptable from agriculture. schools has the potential to increase due commuting time, such as Moama and The main town in the LGA is to the relocation of construction workers Finley. Moama. into the area. However, Deniliquin’s
experience of providing accommodation The nearest town to the Project for workers during the construction of the is Deniliquin, in the Edward River Finley Solar Farm was positive (Muir, LGA. Deniliquin has a population 2020). of approx. 7,800 (ABS, 2020). The Edward River LGA has a population of around 8,995 and an area of 888,345 ha (ABS, 2020).
Noise
There are seven residences Impacts from noise would occur mostly An assessment of construction noise within 2 km of the proposed site, during construction of the Project due to impacts will be undertaken in which have the potential to be the use of vehicles and plant, such as accordance with the Interim Construction impacted by noise during graders and piling-machines. Best Noise Guidelines (ICNG), and construction of the Project (see practice mitigation measures will be operational noise impacts in accordance Figure 3.3 on page17). implemented to reduce potential noise with the NSW Industrial Noise Policy, as disturbance, for example, working within part of the EIS. normal construction hours and will be Should noise levels be likely to exceed managed by a Noise Management Plan relevant criteria, a noise management included in the CEMP. plan would be developed. Noise during operation, including any maintenance works, would be minimal, short in duration, and unlikely to disturb surrounding residences.
Air quality and dust
Existing sources of air pollution Construction has the potential to increase An Air Quality Management Plan will be in the vicinity of the Project are dust through movement of traffic on included in the CEMP to manage likely to result from vehicle unsealed roads on dry days, vegetation potential air quality impacts during emissions and dust from removal and construction activities (such construction. agriculture and may increase as access road construction). However, No specific investigation is required as during the colder months from dust impacts are unlikely to be significant part of the EIS. solid fuel heating and during and standard dust suppression measures summer periods if bushfires or will be used. dust storms occur in the region. Impacts to air quality during operation would be negligible and there is the potential to improve existing levels of air
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Existing conditions Preliminary impact assessment and Need for further assessment management quality by maintaining vegetative ground cover beneath the solar panels and other areas of the site.
Visual amenity
The proposed project area is The Project area is already suitably A visual impact assessment will be located approximately 10 km screened from the majority of the 12 undertaken as part of the EIS process south of the township of residences. The terrain is relatively flat and would include an assessment of the Deniliquin. The Project may and therefore strategically placed likely visual impacts of the development have the potential to create landscape screening from sensitive (including any glare, reflectivity and night visual amenity impacts to road receptors (i.e. dwellings within close lighting) on surrounding residences, users and nearby rural residents. proximity to the solar farm infrastructure) scenic or significant vistas, air traffic and would significantly reduce the visual road corridors in the public domain. The There are seven residences impact. assessment report will include a occurring within 2 km of the landscaping plan for on-site perimeter Project boundary (see Figure 3.3 Solar farms are designed to absorb light planting, in consultation with affected on page 17). and reflect only a tiny fraction of the light nearby landowners. received and much less than from bodies of water of similar area. They are generally not considered to be reflective, and therefore potential glint and glare impacts to surrounding areas are considered to be low.
Airport
Deniliquin airport is It is unlikely that air traffic would be juwi will consult with the airport operator. approximately 3 km south of the affected by the Project as it is It is likely that a ‘glint and glare’ report will town and is managed by Edward approximately 6 km of the airport. be commissioned, as part of the EIS River Council. There are no process. regular passenger services, but a flying training school operates from the airport.
Historic heritage
A search of the Australian None of the results were near the Project As part of the EIS process, an Heritage Database using the area and due to the disturbance of the assessment of the likely historic heritage terms ‘Deniliquin’ and ‘NSW’ site, as a result of agricultural practices, it impacts of the development will be returned 15 results. is very unlikely there are any unidentified undertaken. items of historic heritage in the project area.
Bushfire hazard
The Project area is largely The proposed project is unlikely to pose a The local Rural Fire Service will be cleared of vegetation for significant bushfire risk. consulted as part of the EIS. agricultural purposes. Part of the Bushfire response will be part of Projct site is shown as ‘bushfire- emergency management planning for prone’ land, according to the the project and a Bushfire and Rural Fire Service Online Search
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Existing conditions Preliminary impact assessment and Need for further assessment management Tool (search undertaken 24 Emergency Response Management March 2020). Plan will be included in the CEMP.
Contamination
A search of the NSW EPA Existing contamination of the project area Risks associated with existing or project- contaminated land records could be present as a result of past related contamination are low. returned no results for the LGA fertiliser, herbicide, pesticide, and other Therefore, an assessment of of Murray River Council. chemical use on the land, and may be contamination risks would not be uncovered during excavation works at the required as part of the EIS process, site. provided that any use of hydrocarbons and hazardous materials is subject to Only very minor quantities of hazardous standard management practice. materials or dangerous goods will be used or stored on site during project construction or operation. Hydrocarbons and hazardous materials onsite will be managed in accordance with a Hazardous Materials Management Plan included in the CEMP and relevant EPA guidelines.
Waste management
Not applicable. The majority of waste will be generated A specific assessment of waste during construction. The project will be management issues would not be managed in accordance with the POEO required as part of the EIS process, Act (see Section 2.2.3) and will aim to provided that standard waste reduce the volume of waste produced, management practices are implemented promote re-use and recycling of materials as part of the Waste and Recycling and aim to avoid storage and waste Management Plan. handling methods that may pose risks to environment or health.
Waste material generated during construction will be managed in accordance with the Waste and Recycling Management Plan, included with part of the CEMP.
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6 Community and Stakeholder Consultation 6.1 Consultation activities undertaken juwi has identified a range of groups and individuals that are stakeholders in the development of the Southdown Solar Farm. The stakeholders include regulators who have a decision-making role in project approvals, and groups or individuals who may be directly or indirectly affected by the project. Initial consultation has included formal and informal engagement with the following: Murray River Council – juwi first discussed the project with Council in early February 2020 and met with three representatives of Council’s Planning Department on 27 February 2020 Essential Energy – the preliminary connection enquiry was submitted on 21 March 2019 Landowners within 2 km of the Project area – letters were sent on 13 January 2020; three landowners responded soon after. One of those was not concerned and did not wish to discuss the Project, but the other two requested face-to-face meetings which were held over 27 and 28 February 2020. A fourth landowner has since discussed their concerns by ‘phone, with juwi. Deniliquin Business Chamber – juwi met with the Chamber on 27 February 2020 and discussed the opportunities for local business and how to communicate them and took advice on other parties to consult with Edward River Council (as the closest town) – Deniliquin is located in the Edward River LGA and is the closest town to the Project. juwi had an initial discussion with a Planning Officer on 14 February 2020, who had no immediate concerns. juwi will provide regular updates to Edward River Council Department of Planning, Industry and Environment – juwi met with PIE on 26 September 2019 to discuss the Project, preparation of the Scoping Report and EIS process.
The EIS process requires project proponents to undertake detailed consultation with affected landowners surrounding the development, the local community and local Council. juwi is preparing a Community and Stakeholder Consultation Plan which sets out the objectives and requirements for consultation with the identified stakeholders. In addition to those listed in Section 6.1 (above) stakeholders will include:
Neighbours yet to receive more than the first contact letter The recognised Aboriginal party (or parties) NSW Rural Fire Service Deniliquin Airport (operated by Edward River Council) Transport for NSW Department of Industry NSW Environment Protection Agency NSW Office of Environment and Heritage
A formal process of consultation will be implemented in support of the EIS process and in accordance with any requirements set out in the SEARs.
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7 Proposed Environmental Assessment Requirements Based on the preliminary environmental assessment for the proposed Southdown Solar Farm in Section 5, it is considered that the EIS should address the following specific issues:
Biodiversity – including an assessment of the likely biodiversity impacts of the development, (including potential impacts on threatened species and the determination of appropriate buffer zones around potential habitat) having regard to the NSW Biodiversity Offsets Policy for Major Projects, and in accordance with the Framework for Biodiversity Assessment Aboriginal cultural heritage – including an Aboriginal Cultural Heritage Assessment (ACHA) and field survey, including consultation with the local Aboriginal community Socio-economic – including an assessment of the likely impacts of the project on the local community and including consideration of accommodation and other services for construction workers Land use impacts – including an assessment of the impact of the development on agricultural land and paying attention to the compatibility of the development with the existing land uses on the site and adjacent land during operation and after decommissioning, with reference to the zoning provisions applying to the land Traffic and transport – including an assessment of the site access route, site access point and likely transport impacts of the development on the capacity and condition of roads (including on any Crown land), and a description of the measures that would be implemented to mitigate any impacts during construction Noise – including an assessment of construction noise impacts in accordance with the NSW Interim Construction Noise Guidelines and operational noise impacts in accordance with the NSW Industrial Noise Policy. Visual amenity – including an assessment of the likely visual impacts of the development (including any glare, reflectivity and night lighting) on surrounding residences, scenic or significant vistas, air traffic and road corridors in the public domain, including a draft landscaping plan for on-site perimeter planting, with evidence it has been developed in consultation with affected landowners Historic heritage – including an assessment of the likely historic heritage impacts of the development
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8 Conclusion This Scoping Report has been prepared in accordance with the requirements of DPIE for projects identified as SSDs and therefore requiring an EIS to be prepared under Part 4 of the EP&A Act. The report will support a request to DPIE from juwi Renewable Energy for the Secretary’s Environmental Assessment Requirements (SEARs) for the EIS.
Potential environmental and social issues associated with the project have been identified in this Scoping Report. Based on a preliminary assessment of the potential issues, juwi has proposed further assessment requirements for consideration by DPIE.
A key finding of the Scoping Report is the potential for threatened species habitat to be present within remnant vegetation in the Project site. juwi proposes managing the potential presence of threatened species habitat during the EIS process by undertaking targeted surveys, where required, to determine the presence of threatened species and by locating the project footprint where practical, to avoid impacts on important habitat. juwi proposes placing a strong primary emphasis on impact avoidance and a strong secondary emphasis on impact minimisation. The company is of the opinion that it will have sufficient space within the Project area to locate the solar farm without significant environmental impact.
The project is expected to be a relatively low impact development, due to the inherently low impact nature of solar farm construction and operation, and the location of the project in an area is distant from areas of high environmental sensitivity. In addition, the project is expected to result in significant benefits to the local community and State of NSW by generating economic activity and contributing to the transition to cleaner, cheaper electricity generation and increased energy security through a more diverse energy mix.
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9 References
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AEMO. (02. April 2020). Victoria to New South Wales Interconnector West (VNI West) regulatory investment test for transmission (RIT-T). Von AEMO: https://aemo.com.au/en/initiatives/major-programs/victoria-to-new-south-wales- interconnector-west-regulatory-investment-test-for-transmission abgerufen
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Department of Environment, Climate Change and Water. (15. April 2020). Aboriginal Cultural Heritage Consultation Requirements for Proponents 2010. Von NSW Department of Planning, Industry and Environment: https://www.environment.nsw.gov.au/research-and-publications/publications-search/aboriginal-cultural-heritage- consultation-requirements-for-proponents-2010 abgerufen
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ICNIRP. (15. April 2020). ICNIRP GUIDELINES FOR LIMITING EXPOSURE TO TIME-VARYING ELECTRIC, MAGNETIC AND ELECTROMAGNETIC FIELDS (UP TO 300 GHZ). Von INTERNATIONAL COMMISSION ON NON-IONIZING RADIATION PROTECTION : https://www.icnirp.org/cms/upload/publications/ICNIRPemfgdl.pdf abgerufen
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Muir, L. (27. February 2020). President, Deniliquin Business Chamber. (juwi, Interviewer)
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NSW Department of Planning, Industry and Environment. (17. April 2020). State Environmental Planning Policy - Koala Habitat Protection. Von webmap.environment.nsw.gov.au: https://webmap.environment.nsw.gov.au/Html5Viewer291/index.html?viewer=KoalaSEPP.htm5 abgerufen
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NSW State Government. (16. April 2020). Riverina Murray Regional Plan 2036. Von NSW Deprtment of Planning, Industry and Environment: https://www.planning.nsw.gov.au/Plans-for-your-area/Regional-Plans/Riverina-Murray/Riverina-Murray- regional-plan abgerufen NSW Government. (21. May 2020) Show on SEED Web Map. Data.Gov: https://geo.seed.nsw.gov.au/Public_Viewer/index.html?viewer=Public_Viewer&locale=en- AU&runWorkflow=AppendLayerCatalog=SEED_Catalog.111 Office of Environment and Heritage, Department of Premier and Cabinet. (15. April 2020). Guide to Investigating, Assessing and Reporting on Aboriginal Cultural Heritage in New South Wales. Von NSW Department of Planning, Industry and Environment: https://www.environment.nsw.gov.au/research-and-publications/publications-search/guide-to- investigating-assessing-and-reporting-on-aboriginal-cultural-heritage-in-nsw abgerufen
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10 Appendices 1. Southdown Solar Farm Biodiversity Constraints Assessment (EMM February 2020) 2. Southdown Solar Farm - Aboriginal Due Diligence Assessment (EMM February 2020) 3. First contact letter to neighbours within 2 km of Project boundary
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