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31 July 2015 Ms Jeanette Radcliffe Committee Secretary Senate Select Level 7, 111 Pacific Highway North Sydney NSW 2060 PO Box 1058 North Sydney NSW 2059 Telephone: +61 2 8913 9400 Fax: +61 2 8913 9423 www.ratchaustralia.com 31 July 2015 Ms Jeanette Radcliffe Committee Secretary Senate Select Committee on Wind Turbines PO Box 6100 Parliament House Canberra ACT 2600 By email: [email protected] Response to potentially adverse comments made to the Senate Select Committee on Wind Turbines Thank you for your letters of 24 July 2015 and 27 July 2015 providing RATCH-Australia Corporation Limited (“RAC”) with the opportunity to respond to potentially adverse comments made in submissions 338, 340 and 458 to the Senate Select Committee on Wind Turbines (“Committee”). We welcome this opportunity to assist the Committee, given that some of the issues raised in these submissions have previously been raised directly with RAC, notwithstanding the extensive stakeholder consultations that RAC has carried out in the Far North Queensland region. RAC’s response to the comments is as follows: 1. Noise performance of the proposed Mt Emerald Wind Farm (“Mt Emerald”) (submission 338) Both RAC and its joint venture partner Port Bajool Pty Ltd (“Port Bajool”) have always sought to be as transparent and accurate as possible in discussions with stakeholders on the Mt Emerald project. It was not the intention of either company to represent that the noise emissions of the wind farm would not exceed 35 decibels and any such references were erroneous. We note that the Marshall Day noise modelling report publically disclosed as part of the development approval process for the wind farm includes modelling of noise emissions at a range of levels.1 Both RAC and Port Bajool understand and fully support the priority given to ensuring that any noise generated by Mt Emerald does not negatively impact on surrounding residences. Condition 4 of the Decision Notice for the project granted on 24 April 2015 includes strict noise limits, including in respect of neighbouring residences. As stated at the Cairns hearings of the Committee on 18 May 2015, RAC and Port Bajool will ensure that these conditions are complied with. Following the completion of construction, compliance testing will be undertaken to verify the results of the noise impact assessment already carried out to ensure the wind farm noise complies with the estimates and the conditions of the development consent. 1 Marshall Day, Mt Emerald Wind Farm Noise Impact Assessment, 16 April 2014: http://mtemeraldwindfarm.com.au/Files/MEWF_project_approval_docs/Attachment%205%20- %20Noise%20Impact%20Assessment.pdf 2. Proximity of residences to the Mt Emerald project (338) Neither RAC nor Port Bajool has sought to intentionally mislead stakeholders on the proximity of residences to the project. Any reference to the contrary by RAC or Port Bajool was unintentional and has been corrected by the public release of the correct distances of the project from nearby residences. This information was included in the following publically available documents: (a) the Development Application Response to Information Request submitted with the development application for the project (at pages 9-10, response to information request 9): http://mtemeraldwindfarm.com.au/Files/MEWF_project_approval_docs/MEWF%2 0-%20Response%20to%20Information%20Request.pdf; and (b) Volume I of the Environmental Impact Statement submitted with the EIS documents for the project (section 2.2, particularly figure 2.3 and table 2.2): http://mtemeraldwindfarm.com.au/updates/mewf_eis_docs/new/R71972%20EIS %20MEWF%20Vol%201.pdf. 3. Independence of Queensland Health in relation to analysis of the potential health impacts of wind farms (338) As a responsible wind project developer, RAC supports evidence-based policymaking, including by Queensland Health. Neither RAC nor Port Bajool has, or sought to, interfere in the independence of Queensland Health in relation to the potential health impacts of wind turbines and we reject any implication to the contrary. We note that the implication in the 29 May 2012 article in The Australian appended to submission 338 that Queensland Health had sought to constrain the development of wind farms for health reasons was rejected on the same day by Queensland Health.2 4. Value of Community Service Obligation (“CSO”) payment savings facilitated by Mt Emerald (338) It is incorrect to imply, as the submission does, that RAC has suggested that the operation of the Mt Emerald wind farm alone could save the Queensland Government $600m in CSO payments. RAC has never suggested this. The $600m CSO liability is payable to Ergon based on the entirety of their customer base. This covers almost all of Queensland except for the south-east corner. To represent that a single wind farm or any single power station could eliminate the full payment would be incorrect and neither RAC nor Port Bajool has done so. Rather, in oral testimony given to the Committee on 18 May 2015, Mr Anil Nangia cited analysis from ROAM Consulting that the operation of the Mt Emerald wind farm and the Collinsville solar PV project (a RAC development project) could result in a CSO saving to the Queensland Government of $11m to $24m. It is also incorrect to characterise the values of the potential savings identified by ROAM Consulting as being “excessive”, as the submission does. ROAM’s analysis was based on publically available data and market standard methodology. The below extract from their report explains the methodology used: This high level estimate of the potential reduction in CSO payment was based on changes in MLF due to increased generation in north Queensland. This assessment provides an estimate of the reduction in CSO payment that may result due to reductions in MLFs for the northern Queensland area franchise loads connected to the Ergon Energy network. 2 ‘Queensland Health rebukes The Australian on wind farms,’ Tristan Edis, Climate Spectator, 29 May 2012: http://www.businessspectator.com.au/article/2012/5/29/science- environment/queensland-health-rebukes-australian-wind-farms. The estimate of the reduction in CSO payment that may result due to reduced MLFs has been developed based on: • A review of a sample set of transmission connection point time weighted MLF estimates for a case in which the Mount Emerald wind farm and Collinsville Solar projects are developed, compared with • A review of a sample set of transmission connection point time weighted MLF estimates for a case in which the Mount Emerald wind farm and Collinsville Solar projects are not developed; • An estimate of the Ergon Energy franchise customer load. The Ergon Energy franchise customer load has been estimated based on a review of publicly available information. The Queensland Competition Authority (QCA) report titled Financial and Service Quality Performance 2008-09, Ergon Energy, March 2010. Based on the observed changes in MLF in the ROAM modelling and an estimate of the Ergon Energy franchise customer load for 2017-18, an upper and lower bound estimate of the possible reduction in CSO has been developed. 5. Transmission losses between generation in Central Queensland and the Far North Queensland region (338) The submission’s representation of the transmission loss data in the Advance Cairns Renewable Energy Solutions Tropical North Queensland report is incorrect. It implies that this report had wrongly stated that transmission losses to Far North Queensland are 40%. In fact, the report referred to transmission losses to the region of “up to 40%”.3 This appears to be a reference to maximum fluctuations, not annual averages. The latest reporting available to RAC indicates that transmission losses into the Cairns- Tablelands region average around 10%-12%. RAC’s modelling suggests that the connection of Mt Emerald to the electricity grid would see a reduction in this figure of around 3-4%. RAC and Port Bajool will not receive this benefit and have not claimed that they would. 6. Compliance of the Windy Hill Wind Farm (“Windy Hill”) with its development consent (submissions 340 and 458) The claim in this submission that the Windy Hill wind farm does not comply with its development consent is incorrect and completely without foundation. RAC is fully committed to continuing to operate Windy Hill in compliance with the development consent for the project, as RAC does for all of its operating assets. As stated by RAC in the 18 May 2015 hearings of the Committee, Windy Hill has been operated in accordance with its development consent, including the noise conditions. In relation to the noise complaint from Mr Colin Walkden, it is a matter of public record that Tablelands Regional Council concluded that the Windy Hill wind farm did comply with the noise conditions in its development consent and there was no basis upon which to conclude otherwise, as is in fact noted in submission 458. The claim in the submission that no further periodic noise monitoring has been carried out by RAC is also incorrect. As noted in the 18 May 2015 hearings, RAC is carrying out periodic monitoring at 3 yearly intervals. The latest round of monitoring commenced in 2013 and the next round will commence in 2016. The results of all monitoring will be provided to Tablelands Regional Council in accordance with the conditions of the Windy Hill development consent. 3 Advance Cairns, http://www.advancecairns.com/files/media/original/0c4/cb3/075/renewable- energy-solutions-in-tnq.pdf Thank you for the opportunity to provide this additional information to the Committee. If you have any questions in relation to this please contact me in any of the ways listed above or below. Kind regards Dr Thana Boonyasirikul Managing Director RATCH-Australia Corporation Limited Copy to: John Morris Director Port Bajool Pty Ltd .
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