Planning Proposal

EPS

R IVERINA SOLAR

E NVIRONMENTAL IMPACT STATEMENT

Pr epared by Environmental Property Services

Lot 54 – 57 DP 751728

Lot 2 DP 1105962 248 Ross Road, Yoogali NSW 2680

ENVIRONMENTAL PROPERTY SERVICES Reference No. 11234 February 2016

Contact Information and Declaration

Declaration: Submission of Environmental Impact Statement (EIS) prepared under the Environmental Planning and Assessment Act 1979 in respect of a proposed photovoltaic (PV) commercial scale solar station. The opinions and declarations in this Environmental Impact Statement are ascribed to Environmental Property Services (EPS) and are made in good faith and trust that such statements are neither false nor misleading. In preparing this EIS, EPS has considered and relied upon information obtained from the public domain, supplemented by discussions between key EPS staff, representatives from governing agencies and independents, including Shunfeng International Clean Energy Limited and specialist consultants. Applicant: Environmental Property Services (Aust) Pty Ltd PO Box 348 NELSON BAY NSW 2315 Ph: 02 4981 1600

…………………………………….. Director Prepared by: Stephen McCall

Bachelor of Environmental Science Principal Environmental Planner Environmental Property Services PO Box 348 NELSON BAY NSW 2315 ……………………………………….. Ph: 02 4981 1600 Stephen McCall Application 248 Ross Road, Yoogali NSW 2680 subject land Lot 54 DP 751728 address: Lot 55 DP 751728 Lot 56 DP 751728 Lot 57 DP 751728 Lot 2 DP 1105962

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Quality Assurance & Version Control Table

Project: Riverina Solar Farm

Proponent: Environmental Property Services (Aust) Pty Ltd (EPS) and SF Suntech Australia (Suntech)

Rev No. Date Our Reference Author Reviewer

V01 19/01/2016 20160119_11234_Riverina EIS_V01 T. Kelly S.McCall

Final 29/02/2016 20160229_11234_Riverina EIS_Final T. Kelly S. McCall

Checked by A. Tipper

Approved by S. McCall

ENVIRONMENTAL PROPERTY SERVICES Hunter Sydney 9 Yacaaba Street, Level 33, 264 George Street, Nelson Bay NSW 2315 Sydney NSW 2000 (02) 4981 1600 (02) 9258 1985

Website: www.enviroproperty.com.au

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EXECUTIVE SUMMARY

This Environmental Impact Statement (EIS) has been prepared by Environmental Property Services (EPS) in a joint venture with SF Suntech Australia (Suntech) to support a State Significant Development (SSD 16_1782) application under Part 4 of the Environmental Planning and Assessment Act 1979.

The proposal is to develop the Riverina Solar Farm, a photovoltaic (PV) commercial scale solar station designed to feed into the National Electricity Market (NEM) on five agricultural lots located at 248 Ross Road, Yoogali, NSW.

EPS has prepared this EIS in accordance with the requirements of the Secretary of the Department of Planning and Environment (DP&E), the EP&A Act and Schedule 2 of the Environmental Planning and Assessment Regulation 2000 (EP&A Regulation). The Secretary’s Environmental Assessment Requirements (SEARs) were issued by DP&E on 2 February 2016.

Site Description

The Project site is located near the regional township of Griffith in NSW. The site comprises 5 allotments currently utilised for irrigated cereal cropping. Immediately adjoining the site is the 33kV TransGrid Griffith Substation and the Yanco to Griffith freight/passenger rail line. Access to the site is available via Griffith Road (State Highway 94 – ‘Irrigation Way’) or the unsealed Ross Road.

Land within the immediate surrounding area of the site is predominately used as agricultural land with 22 dwellings located within 1.5km of the site.

Project Description

The Project Application Area is 110ha in size. The Riverina Solar Farm will comprise of a series of mounted photovoltaic modules set out in arrays, that may be either fixed or use single axis tracking. The proposal will have a minimum capacity of 30 alternating current (AC) megawatts (MW). The arrays will be connected to inverters and voltage step up transformers. The Project will connect to the adjacent TransGrid Griffith Substation via an underground 33 kV transmission line.

Due to extensive technical assessments and National Electricity Market rules for connection to the high voltage transmission network, a separate approval process for the connection to the substation is operating in tandem with the EIS. The relevant environmental approval for the connection works will occur under Part 5 of the EP&A Act.

Ancillary infrastructure associated with the proposal will include a site office, maintenance sheds, access tracks, landscaping and perimeter fencing.

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Construction will be undertaken seven days a week for approximately 6 months of the 12 month construction and commissioning process. Heavy vehicle access will be via Ross Road. All parking and loading requirements will be accommodated within the site.

Operations will be controlled by a supervisory control and data acquisition (SCADA) control system. Ongoing maintenance works will include componentry replacements, solar panel washing, farm maintenance activities and general stock and pasture management.

As the installation process is simple and does not involve mass excavation or concrete pours, decommissioning at the end of the projects operational life, will leave the land surface in a very similar condition to present.

Alternatives

Ultimately, the location of the Riverina Solar Farm was selected as the preferred location based on the following factors:

• Proximity to the nearest substation, adjacent to the boundary of the Riverina Solar Farm; • Sufficient capacity at the adjacent Transgrid substation for connection of the Solar Farm; • Access to the substation does not require crossing of major roads or highways; • Located within close proximity to the regional centre of Griffith, but equally provides sufficient distance between the site and populated areas; • Topography of the site is flat with even surface and no grade creating ideal conditions for the construction of a solar park; • Suitable infrastructure surrounding the site (rail access to Griffith and road access from State Highway 94 – Irrigation Way and the local road network) for construction and operation of a solar park; • High insolation of ~2,950kWh/m² year – i.e. readily available solar resource; and • The site is unlikely to contain significant areas of native vegetation, Aboriginal cultural heritage items, or other environmental constraints given that the site has previously been disturbed through agricultural land uses.

Statutory Context

Clause 34(7) of State Environmental Planning Policy (SEPP) Infrastructure permits the development of ‘solar energy systems’ with consent on any land.

The project is considered ‘State Significant Development’ (SSD) in accordance with Division 4.1 of Part 4 of the EP&A Act, being electricity generating works with a capital investment value greater than $30 million pursuant to Schedule 1 of the State Environmental Planning Policy (SEPP) – State and Regional Development.

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Therefore, the Minister is the consent authority and this EIS has been prepared in accordance with the Secretary’s Environmental Assessment Requirements (SEARs) as issued by DP&E on 2 February 2016.

An approval under s138 of the Roads Act 1993 will be required. Connection to the Griffith Substation will be obtained under a separate approval process with TransGrid in tandem with this EIS.

Environmental Impact Assessment

Technical studies for the Project have been completed in accordance with the SEARs and conclude that there will be minimal impact to the surrounding environment. These specialist reports underpin the key findings and recommendations outlined in this EIS. The key issues are summarised below:

• Environmental Risk - The risk assessment concludes that the Project will not result in any unacceptable environmental risks. • Visual – The Project is considered suitable within the rural context with regard to landscape and visual impact. In addition a vegetation screen will be provided along the State Highway 94 – Irrigation Way boundary to further minimise the visual impact. • Land Use – The medium-term loss of about 1,200 t of rice and 5 t/ha for wheat per year due to the Project is a very minor change on the district’s production potential. The Project site will be sown with permanent pasture under and around the panels and grazed for the life of the operation. On decommissioning of the Project, the land will be returned to its current agricultural production potential thereby not impacting upon the long-term use of the land. • Biodiversity – No native vegetation will be cleared. The project will not result in any significant impact on local biodiversity. • Flooding – The Project will not have a demonstrable impact on local flooding. • Hydrology – Basic landholder water rights and harvestable rights will not be affected by the Project and no water harvesting or water use from natural creeks or bores are proposed. • Soils and Salinity – The Project will involve minimal short term construction, followed by several decades of low intensity grazing of permanent pasture. It is predicted that proposed decades of minimal machinery on site and the long term effect of permanent pasture on soil structure, organic content and fertility, is expected to be beneficial for the soils. The limited use of watering for vegetation screening is expected to have a net beneficial effect on any incipient salinity issues in the area, as it will tend to reduce deeper soil moisture levels. • Surface Water and Erosion – During the construction phase, the Project will implement measures to include trackways and encourage ground cover to ensure peak runoff rates or long term runoff yields are not increase and that the soil is not eroded at the dripline of the panels. The Project will lead to a long term vegetative cover, and this will reduce the potential for erosion. • Groundwater – The Project site has no groundwater bores on site. The risk of groundwater contamination is very low as only a small volume of oils and lubricants are required during construction and will be stored in a locked and bunded facility.

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• Greenhouse Gas – The Project is expected to produce 7 times more energy than it consumes over its lifetime. Solar farms produce renewable energy and this in itself is a very significant mitigation

measure, which can offset the release of approximately 1.8 MtC02e over its lifetime. • Noise – Whilst the proposal is considered likely to exceed the Interim Construction Noise Guidelines (ICNG), given semi-intensive agricultural context, proximity to major road and rail corridors, and the low number of sensitive receivers, the proposal is not considered likely to produce an unacceptable impact. A Draft Construction Noise Management Plan has been prepared outlining proposed mitigation measures to minimise impacts. • Aboriginal and Cultural Heritage – Four Aboriginal artefacts were identified during a site inspection. These artefacts will be salvaged prior to construction as part of the consented SSD. • Bushfire – The risk of initiating fire from commercial solar panels and inverters is very low due to their high quality. The Project site does pose a risk of fire due to ground cover. To mitigate this, the perimeter track will be maintained as a firebreak. In addition, long-term liaison with neighbouring landholders will ensure that the Project site is staffed during nearby stubble burns. • Traffic and Transport – Materials will likely be delivered via container rail to Griffith and loaded onto B-doubles for delivery to site. Heavy vehicle access to the Project site will likely be via the unformed Ross Road, as this avoids the safety and congestion issues associated with crossing the rail line at the intersection of Irrigation Way and Hamilton Road. Excellent site distance is provided at each intersection. The local road impacts are not considered significant given the capacity of the State Roads. A Draft Construction Traffic Management Plan has been prepared outlining proposed mitigation measures to minimise impacts. • Air Quality – The Project is not expected to generate measurable dust during operations. Potential dust generated by construction traffic on internal access roads and the unsealed public roads will be mitigated by regular watering during construction. • Electric and Magnetic Fields – An assessment has been performed for the Project and it is not anticipated to infer with EMP or RFI. • Socio-Economic – The proposal will provide significant economic stimulus to the region, and provides an opportunity to further diversify the general industry. Overall, it is considered that the Solar Farm development will have significant positive social and economic impacts in the area compared to any potential negative impacts. • Glint and Glare – A detailed glare calculation was performed using the Solar Glare Hazard Analysis Tool. This assessment indicated that no glare will be experienced from the solar PV Plant when approaching Griffith Airport in the close proximity zone of 2 miles from the centre of each runway. Consultation with local agricultural aircraft operators similarly indicates no anticipated glint or glare impacts from the proposal. • Cumulative Assessment – The assessment of cumulative impacts has been considered including the nearby similar solar farm proposal by Neoen. Key cumulative impacts include air quality, traffic, noise, greenhouse gas and visual amenity. Implementation of the proposed mitigation and management measures will result in manageable and acceptable cumulative impacts.

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Consultation

Consultation with relevant stakeholders has been conducted in accordance with the project Consultation Program. The program is divided into the following phases:

 Phase 1 – Key stakeholders to determine enriovnmental assessment requirements;  Phase 2 – Community and stakeholder consultation;  Phase 3 – EP&A Act assessment process;  Phase 4 – Construction of the solar farm;  Phase 5 – Operation of the solar farm; and  Phase 6 – End of operation.

As a result of the program a broad range of consultation has been undertaken and is ongoing. Comments, views and concerns of stakeholders have been addressed in this EIS.

Conclusion

Pursuant to Section 79C of the EP&A Act, this EIS concludes that the Riverina Solar Farm Proposal:

• Is consistent with the relevant statutory provisions; • Will not result in significant environmental impacts; • Is suitable at the proposed site; and • Is in the public interest.

Therefore it is recommended that the proposal be approved in accordance with the mitigation measures proposed in this EIS.

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Table of Contents

Executive Summary ...... iv Abbreviations ...... xv 1 Introduction ...... 1 1.1 Objectives...... 1 1.2 Proponent ...... 1 1.3 ARENA Funding ...... 2 2 Strategic Justification ...... 3 2.1 Climate Change and Renewable Energy ...... 3 2.2 Site Selection and Alternatives ...... 3 2.2.1 Do Nothing Option ...... 4 2.3 Project Benefits ...... 5 3 Site Description ...... 7 3.1 Site Context ...... 7 3.2 Allotments ...... 7 3.3 Existing Land Use and Operations...... 8 4 Project Description ...... 12 4.1 Project Capacity ...... 12 4.2 Project Design and Layout ...... 12 4.2.1 Electrical Installations ...... 12 4.2.2 Site Office and Amenities ...... 15 4.2.3 Access and Parking ...... 15 4.2.4 Fencing ...... 15 4.3 Project Phases ...... 15 4.3.1 Construction ...... 15 4.3.2 Operation ...... 16 4.3.3 Decommissioning ...... 16 5 Statutory and Strategic Context ...... 18 5.1 Permissibility ...... 18 5.2 Commonwealth Legislation ...... 18

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5.2.1 Environment Protection and Biodiversity Conservation Act 1999 ...... 18 5.3 State Legislation ...... 19 5.3.1 Environmental Planning and Assessment Act 1979 ...... 19 5.3.2 Threatened Species Conservation Act 1995 ...... 23 5.3.3 Roads Act ...... 24 5.4 Relevant Environmental Planning Instruments ...... 25 5.4.1 State Environmental Planning Policy (State and Regional Development) 2011 ...... 25 5.4.2 State Environmental Planning Policy (Infrastructure) 2007 ...... 25 5.4.3 State Environmental Planning Policy (Rural Lands) 2008 ...... 26 5.4.4 State Environmental Planning Policy No. 44 – Koala Habitat Protection ...... 26 5.4.5 State Environmental Planning Policy No. 55 – Remediation of Land ...... 27 5.4.6 Griffith Local Environmental Plan 2014 ...... 29 5.5 Project Approvals and Licences ...... 30 5.5.1 Water Entitlements ...... 31 5.6 Relevant Strategies and Policies ...... 31 5.6.1 Commonwealth Renewable Energy Target Scheme ...... 31 5.6.2 NSW Renewable Energy Action Plan...... 32 5.6.3 NSW 2021 ...... 32 6 Consultation ...... 34 6.1 Key Stakeholders ...... 34 6.2 Community Consultation ...... 34 6.2.1 Consultation Program ...... 34 6.2.2 Consultation Program Phases ...... 35 6.2.3 Summary of Community Issues and Enquiries ...... 36 6.2.4 Contact for Public Enquiries ...... 36 7 Environmental Risk Assessment ...... 37 8 Key Environmental Issues ...... 43 8.1 Visual Impact and Landscape ...... 43 8.1.1 Existing Environment ...... 43 8.1.2 Impacts ...... 43 8.1.3 Mitigation Measures ...... 46

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8.2 Land Use ...... 47 8.2.1 Existing Environment ...... 47 8.2.2 Impacts ...... 47 8.2.3 Mitigation Measures ...... 48 8.3 Biodiversity ...... 49 8.3.1 Methodology ...... 49 8.3.2 Preliminary Analysis ...... 50 8.3.3 Field Investigations ...... 51 8.3.4 Existing Environment ...... 51 8.3.5 Impacts ...... 56 8.3.6 Mitigation Measures ...... 58 8.4 Soils and Salinity...... 59 8.4.1 Existing Environment ...... 59 8.4.2 Impacts ...... 59 8.4.3 Mitigation Measures ...... 60 8.5 Surface Water and Erosion ...... 61 8.5.1 Existing Environment ...... 61 8.5.2 Impacts ...... 61 8.5.3 Mitigation Measures ...... 62 8.6 Flooding ...... 65 8.6.1 Existing Environment ...... 65 8.6.2 Impact ...... 66 8.6.3 Mitigation Measures ...... 67 8.7 Groundwater ...... 68 8.7.1 Existing Environment ...... 68 8.7.2 Impact ...... 68 8.7.3 Mitigation Measures ...... 68 8.8 Greenhouse Gas ...... 69 8.8.1 Impacts ...... 69 8.8.2 Mitigation Measures ...... 70 8.9 Noise ...... 71

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8.9.1 Existing Environment ...... 71 8.9.2 Impact ...... 71 8.9.3 Mitigation Measures ...... 73 8.10 Aboriginal and Cultural Heritage...... 74 8.10.1 Existing Environment ...... 74 8.10.2 Impact ...... 74 8.10.3 Mitigation Measures ...... 75 8.11 Bushfire ...... 76 8.11.1 Existing Environment ...... 76 8.11.2 Impact ...... 76 8.11.3 Mitigation Measures ...... 76 8.12 Traffic and Transport ...... 77 8.12.1 Existing Environment ...... 77 8.12.2 Impact ...... 78 8.12.3 Mitigation Measures ...... 81 8.13 Air Quality ...... 82 8.13.1 Existing Environment ...... 82 8.13.2 Impacts ...... 83 8.13.3 Mitigation Measures ...... 83 8.14 Electric and Magnetic Fields, and Radio Frequency Interference ...... 84 8.14.1 Terminology and Existing Environment ...... 84 8.14.2 Impacts ...... 86 8.14.3 Mitigation Measures ...... 88 8.15 Socio-Economic ...... 89 8.15.1 Methodology ...... 89 8.15.2 Existing Environment ...... 90 8.15.3 Impact ...... 90 8.15.4 Mitigation Measures ...... 90 8.16 Glint and Glare ...... 91 8.16.1 Existing Environment ...... 91 8.16.2 Methodology ...... 91

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8.16.3 Impact ...... 92 8.16.4 Mitigation Measures ...... 92 8.17 Cumulative Assessment ...... 93 8.17.1 Air Quality ...... 94 8.17.2 Traffic ...... 94 8.17.3 Noise ...... 94 8.17.4 Greenhouse Gas ...... 95 8.17.5 Visual Amenity ...... 95 9 Summary of Mitigation Measures ...... 96 10 Environmental Management and Monitoring ...... 98 11 Ecologically Sustainable Development ...... 100 11.1 Precautionary Principle ...... 101 11.2 Inter-generational Equity ...... 102 11.3 Conservation of Biological Diversity ...... 103 11.4 Improved Valuation, Pricing and Incentive Mechanisms ...... 103 12 Conclusion ...... 104 13 References ...... 105

Table of Figures

Figure 3-1: Site Context Plan ...... 9 Figure 3-2: Site Plan ...... 10 Figure 3-3: Key Constraints ...... 11 Figure 4-1: Conceptual Site Layout ...... 13 Figure 4-2: Electrical Infrastructure ...... 14 Figure 7-1: Key Sensitive Receivers ...... 42 Figure 8-1: Threatened Species Records ...... 52 Figure 8-2: Mapped Remnant Vegetation ...... 53 Figure 8-3: Irrigation Supply Canals and Drains ...... 64

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List of Tables

Table 5-1: Section 79C Matters for Consideration...... 20 Table 5-2: SEARs Compliance ...... 21 Table 6-1: Consultation Program Phases ...... 35 Table 7-1: Environmental Risk Assessment Categories ...... 38 Table 7-2: Environmental Risk Assessment ...... 39 Table 8-1: Equipment SWL ...... 71 Table 8-2: Heavy Vehicle Contributions Due to Container Haulage ...... 79 Table 8-3: Heavy Vehicle Contributions Due to Container Haulage and Aggregate Deliveries ...... 80 Table 8-4: PM10 Data ...... 82 Table 8-5: Calculated EMF Values for Exposed 33kV Cable to Substation ...... 87 Table 8-6: Calculated EMF Values for Exposed 33kV Line Over Ross Road ...... 88 Table 9-1: Summary of Mitigation Measures ...... 96

Appendices

Appendix 1 – Secretary’s Environmental Assessment Requirements Appendix 2 – Community and Stakeholder Engagement Report Appendix 3 – Socio-economic Impact Assessment Appendix 4 – Capital Investment Value Report Appendix 5 – Visual Impact Assessment Appendix 6 – Draft Landscaping Plan Appendix 7 – Threatened Species Table Appendix 8 – Seven-Part Test Weeping Myall Appendix 9 – Draft Noise Management Plan Appendix 10 – Aboriginal Heritage Due Diligence Report Appendix 11 – Draft Traffic Management Plan Appendix 12 – Glint and Glare Assessment

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ABBREVIATIONS

Abbreviation Description

AADT Annual Average Daily Traffic ABARES Australian Bureau of Agricultural and Resource Economics and Sciences AC Alternating Current ACMA The Australian Communications and Media Authority AEP Annual Exceedance Probability ARPANSA Australian Radiation Projection and Nuclear Safety Committee DC Direct Current EMF Electromagnetic Fields EMP Environmental Management Plan EPBC Act Environment Protection and Biodiversity Conservation Act 1999 EP&A Act Environmental Planning and Assessment Act EPS Environmental Property Services GHG Greenhouse Gases Hz Hertz ICNG Interim Construction Noise Guideline ICNIRP The International Commission on Non-Ionizing Radiation Protection LAeq Equivalent Continuous Level. LGA Local Government Area LEP Local Environmental Plan AHD Australian Height Datum MIA Murrumbidgee Irrigation Area NEM National Electricity Market NHMRC The National Health & Medical Research Council PAA Project Application Area PM Particulate Matter PMF Probable Maximum Flood PV Photovoltaic RAV Restricted Access Vehicle RBL Rating Background Level RFI Radio Frequency Interface

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RMS Root Mean Square SCADA Supervisory Control and Data Acquisition SEPP State Environmental Planning Policy SF Suntech SF Suntech Australia SWL Sound Power Levels TEOM Tapered Elemental Oscillating Microbalances TSC Act Threatened Species Conservation Act 1995 TSP Total Suspended Particulates

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1 INTRODUCTION

This Environmental Impact Statement (EIS) has been prepared to demonstrate the environmental, social and economic matters associated with the proposal. The proposal is to develop the Riverina Solar Farm, a photovoltaic (PV) commercial scale solar station designed to feed into the National Electricity Market (NEM). The proposal will have a capacity of 30 alternating current (AC) megawatt (MW), located in Yoogali near Griffith in NSW.

The EIS will be determined as State Significant Development (reference: SSD 16_7482) under Part 4 of the Environmental Planning and Assessment Act 1979 (EP&A Act). EPS has prepared this EIS in accordance with the requirements of the Secretary of the Department of Planning and Environment (DP&E), the EP&A Act and Schedule 2 of the Environmental Planning and Assessment Regulation 2000 (EP&A Regulation). The Secretary’s Environmental Assessment Requirements (SEARs) were issued by DP&E on 2 February 2016. A copy of the SEARs are provided in Appendix 1.

The following sections of the EIS examine the site location, the relationship of the proposal to the location, the environment and the planning qualities of the development including an assessment of the environmental issues associated with construction, operation and decommissioning of the proposal. The EIS provides the supportive documentation for the Development Application to seek consent for the proposal. In accordance with the SEARs, relevant specialist consultant assessments and input has been undertaken to support the Development Application.

1.1 Objectives

The objectives of the Riverina Solar proposal are:

 To provide a large-scale, grid connected solar power development that can contribute to NSW’s electricity supply;  To contribute to Australia’s competitive electricity market with a renewable energy resource;  To contribute to Australia’s growing solar industry;  To encourage development in regional NSW areas; and  To develop infrastructure and technical knowledge that will contribute to the Australian solar industry.

1.2 Proponent

The proponents of the proposal are Environmental Property Services (Aust) Pty Ltd (EPS) and SF Suntech Australia Pty Ltd (SF Suntech).

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EPS is an Australian firm with offices in Sydney and the Hunter Region, NSW. EPS is a development company specialising in planning, environmental and economic matters in the energy and linear infrastructure sectors. EPS advises companies, private individuals, Government and funding agencies throughout Australia as well as development of their own projects and prides itself on adding value to each project. EPS has significant major project experience within the renewable energy and infrastructure sectors including wind farms, solar, linear infrastructure and non- conventional energy developments.

SF Suntech are part of Shunfeng International Clean Energy (SFCE) which is a world leading independent large scale solar power service provider with grid-connected solar power capacity of 890 MW. SFCE manufactures photovoltaic panels, undertakes clean energy research and is an engineering, procurement and construction (EPC) and operations and maintenance (O&M) contractor globally. SFCE divisional office is in Sydney.

1.3 ARENA Funding

The Australian Renewable Energy Agency (ARENA) has identified at a Federal level a number of investment focus areas to help achieve the ARENA objectives. Large-scale solar photovoltaics has been identified as one of the five priority areas. ARENA is currently running a competitive funding process for up to 200MW of large-scale solar PV projects with the goal of reducing the current gap in commercial competitiveness between large-scale solar PV and wind generation. Individual proposals for the current investment round should be between 5 MW and 50 MW, as only a few systems of this size are currently built in Australia, despite having excellent solar resources.

The Riverina Solar Farm proposal has successfully submitted an Expression of Interest (EOI) to ARENA for funding under their Advancing Renewables Programme (ARP). The EOI comprised the first of two stages required to successfully receive ARENA funding for the Riverina proposal. The proposal was found to comply with the eligibility and merit criteria and is currently being considered as part of the final ‘Full Application’ stage. The Riverina proposal has received positive support from the NSW Resources and Energy Department and the NSW Department of Premier and Cabinet.

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2 STRATEGIC JUSTIFICATION

2.1 Climate Change and Renewable Energy

Changes in global climate conditions have been partially attributed to increased atmospheric greenhouse gas content. Generating solar power reduces emission of greenhouse gases, such as carbon dioxide, associated with traditional methods of power generation by offsetting electrical generation required from fossil fuel power stations.

The Riverina Solar Farm will increase Australia’s solar energy generating capacity and assist in meeting Australia’s obligations under international conventions and agreements, such as the Kyoto Protocol and the recent Paris Agreement.

The Australian Prime Minster, Malcom Turnbull, announced at the 2015 United Nation Climate Change Conference in Paris, France, that he would ratify the second commitment period of the Kyoto Protocol. The second commitment period (2013 – 2020) commits Australia to cut emissions 5% below 2000 levels by 2020. The Kyoto Protocol does not prescribe mechanisms by which Parties to the Protocol must meet their emissions target. However, it does indicate measures to be considered, such as promotion of renewable energy.

The 2015 Paris United Nation Climate Change Conference delivered the world’s first binding treaty under which all nations, developed and developing, agreed to limit global warming to below 2°C above pre-industrial levels and to pursue efforts to limit the temperature increase to 1.5°C above pre-industrial levels. Renewable energy projects, such as the Riverina Solar Farm, will assist Australia in meeting these targets.

2.2 Site Selection and Alternatives

Selecting the preferred project site required consideration of a number of factors. While the most important factor in selecting a project site to develop and harness solar energy is the availability of solar radiation, strategically, there are many other factors to consider as part of the decision.

The site selection process included a lengthy consideration of the following factors:

 Availability of solar energy – i.e. the greatest amount of solar irradiance (solar irradiance is the power per unit area produced by the Sun in the form of electromagnetic radiation);  Availability of suitable land to avoid land use conflict and biodiversity impacts;  Access to the NEM through existing substations and high voltage transmission lines;

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 Capacity of substation and transmission lines – needed capacity to receive a minimum of 30MW;  Access to major transport routes, including both rail and road networks;  Topography of the site – the preferred sites are flat or with little slope.

In addition to these primary considerations, other factors such as the variation in local climate, surrounding land uses, proximity of constraints to the site, geotechnical issues, soil stability and groundwater resistivity, as well as socio-economic and political acceptance issues were identified as factors that influence a solar proposal.

With these factors in mind, a number of alternative sites were considered, both within the Griffith region and in other western NSW regions.

Ultimately, the location of the Riverina Solar Farm was selected as the preferred location based on the following factors:

2.2.1 Do Nothing Option

During the site selection and project inception process, the option of not proceeding with the project was also considered, i.e. the ‘do nothing’ option. Doing nothing would prevent any identified environmental and social impacts associated with the project, including construction noise, increased traffic movements, visual impacts and a change in the agricultural production cycle currently undertaken on the site.

While these identified impacts would be avoided, equally, there are identified consequences if the project does not proceed. Doing nothing would result in:

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 The loss of employment generation during the construction and operational phases of the project;  The loss of a large-scale renewable energy source feeding 30MW to the NEM;  The loss of socio-economic benefits including indirect employment generation during both construction and operation;  The loss of a large-scale renewable energy project that is aligned with the Commonwealth Renewable Energy Target Scheme and the NSW Renewable Energy Action Plan; and  The loss of a contribution toward reducing greenhouse gas emissions and sustainable electricity generation.

Having identified both the positive and negative impacts of not proceeding with the proposal, it is considered that the potential impacts of the project are outweighed by its benefits. In this instance, the ‘do nothing’ option does not represent the preferred outcome.

Though a number of alternative locations and project layouts have been considered, the Riverina Solar Farm provides the greatest flexibility in terms of design, capacity and connection to the NEM, while equally avoiding any significant social, environmental or economic impacts. The chosen location has enabled an efficient infrastructure layout design that is flexible with the site benefits and constraints.

2.3 Project Benefits

The Riverina Solar Farm is a renewable and sustainable energy project with a proposed operating capacity of 30MW. Based on typical household energy use estimates by the Independent Pricing and Regulatory Tribunal (IPART), the annual electricity generation of the Project would be sufficient to power more than 9,200 households with sustainable energy.

Further, the project is making a significant contribution toward the Commonwealth’s Renewable Energy Target (RET) scheme of having 20% of Australia’s electricity generation from renewable sources by 2020.

The following specific benefits will result from the Riverina proposal:

 Economic stimulus through the generation of approximately 100 direct full time equivalent jobs and 350 indirect full time equivalent jobs;  Generation of renewable energy with an operating capacity of 30MW;  Opportunity to reduce greenhouse gas emissions – over the life of the project, the

Riverina proposal could offset approximately 1.8 MtC02e from traditional coal-fired power generation;

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 Contribute to Federal and State renewable energy targets;  Contribute to the development of knowledge and skills in the Australian solar industry;  Opportunity for ongoing agricultural land use compatible with the solar infrastructure on the site (sheep grazing for pasture management); and  No long term environmental or social impacts from the proposal on the site or the locality.

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3 SITE DESCRIPTION

3.1 Site Context

Yoogali is a small town of approximately 1,200 people across approximately 400 dwellings. Nearby Griffith is the regional centre, with a population of approximately 17,000 across approximately 7,000 dwellings. Griffith is ideally positioned in terms of both solar resources and its access to the NEM.

While there are currently no large-scale projects operating in Griffith, we are aware of a similar solar project proposed by Neoen Australia to be located across 120 hectares of adjacent land. Together, these projects have the potential to create a solar precinct in Yoogali, benefiting the region with commercially and socially viable large-scale solar PV facilities.

Figure 3-1 shows the contextual location of the Riverina Solar Farm proposal.

3.2 Allotments

The Riverina Solar Farm will be initially located across the following five allotments in the Parish of Jondaryan, County Cooper, with the potential for expansion in the future:

• Lot 54 in DP 751728; • Lot 55 in DP 751728; • Lot 56 in DP 751728; • Lot 57 in DP 751728; and • Lot 2 in DP 1105962.

The street address is 248 Ross Road, Yoogali NSW 2680 approximately 6 kilometres south east of Griffith. Combined, the total area covers ~110ha of land. The following key features characterise the proposed site:

 The site is located directly adjacent to the 33kV Transgrid Griffith Substation;  The site is bounded by Griffith Road (State Highway 94 – ‘Irrigation Way’) and the Yanco to Griffith freight/passenger rail line to the south and south-west;  The site is bounded by an unsealed dirt access way, Ross Road, to the east and north-east;  The site has been used for many years for cereal cropping and occasional grazing, and is clear of any additional development; and  The site is located approximately 1.5km from Yoogali town centre measured from the northern most boundary of the site.

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A Site Plan illustrating the above key characteristics has been prepared and included as Figure 3-2.

3.3 Existing Land Use and Operations

The site has been used for many years for cereal cropping and occasional grazing.

Land within the immediate surrounding area of the site is predominately used as agricultural land with viticulture, citrus, cereal crops and improved pastures most prominent. The site itself has no fruit trees or trees of any sort, apart from the very occasional tree along the property boundaries. The whole of the site is located within the Murrumbidgee Irrigation Area (MIA) and adjacent to the Clark Road irrigation channel.

A Constraints Map has been prepared and illustrated in Figure 3-3.

ENVIRONMENTAL PROPERTY SERVICES February 2016 - Page 8 Legend: (! Locality

Riverina Solar Project Application Area

Griffith Aerodrome

Yenda (!

Tharbogang Beelbangera (! (!

Bilbul (!

GRIFFITH CITY (!

Burley Griffin Way

Yanco Griffith Railway Yoogali Ross Road (!

Kurrajong Road Irrigation Way Hamilton Road

Hanwood Widgelli (! (!

Author: K. Lee Figure 3-1 SITE CONTEXT PLAN Reviewer: S. Duffy ´ 0 500 1,000 2,000 3,000 A3 Scale: 1:60,000 Metres Riverina Solar Project | Griffith, NSW, Australia ©Aerial imagery supplied by NearMap under Licence Job Ref: 11234 DCDB supplied by Land & Property Information 2016 26 February 2016 ENVIRONMENTAL PROPERTY SERVICES 2 1 67 DP 814842 102 DP 1157944 DP 751728 88 DP 751728Legend: 50 DP 751728 DP 751728 76 DP 751728 Riverina Solar Project 66 38 51 1942 DP 751728 Application2 Area DP 751728 DP 751728 DP 1195914 87 DP 1157944 DP 751728 Griffith Solar Project 2 Ross Road 77 DP 1203874 Application Area 1940 DP 751728 52 DP 1195914 1 TransGrid Yoogali DP 751728 DP 1203874 65 Substation Area 54 DP 751728 DP 751728 1941 53 DP 751728 DP 1195914 Clark Lane

78 1 DP 751728 DP 1078924

3 55 DP 1203874 751 DP 751728 418 DP 751728 DP 751709 2 DP 1105962 891 DP 751728 Hamilton Road 1 79 DP 1105962 DP 751728 2 DP 1078924 56 417 1371 DP 751728 DP 751709 DP 846809 84 125 416 DP 751728 DP 751709DP 1195114 420 1 80 DP 751709 DP 1175463 DP 751728 57 DP 751728 62 DP 751728 2 DP 788271 2500 DP 1195971 83 9971 DP 751728 DP 1195972 1 1 81 DP 788271 DP 865611 Irrigation Way DP 751728 2 11 1983 DP 1175463 138 DP 1198376 61 DP 44546 DP 751709 DP 751728 9970 DP 1195972 58 DP 751728 136 134 82 DP 751709 DP 751709 139 DP 751728 1134 DP 751709 127 DP 751709 DP 1199525 60 133 DP 751728 84 DP 751709 DP 751704 140 Yanco Griffith Railway DP 751709 132 DP 751709 9770 131 DP 1195978 DP 751709 59 DP 751728

Bob Irvin Road 141 DP 751709 135 DP 1199599 130 126 119 DP 751709 DP 1199525 93 DP 751709 142 DP 751704 101 DP 751709 2200 DP 751704 136 81 DP 723168 1312 DP 1199599 DP 751704 DP 751709 143 120 2199 128 DP 751709 DP 751709 DP 723168 DP 751709 125 DP 1199520 Author: K. Lee Figure 3-2 SITE PLAN Reviewer: S. Duffy ´ 0 100 200 400 600 A3 Scale: 1:10,000 Metres Riverina Solar Project | Griffith, NSW, Australia ©Aerial imagery supplied by NearMap under Licence Job Ref: 11234 DCDB supplied by Land & Property Information 2016 26 February 2016 ENVIRONMENTAL PROPERTY SERVICES Legend: Riverina Solar Project Application Area Main Drain J 1:100 Year High Flood Hazard Main Drain J 1:100 Year Low Flood Hazard

Remnant Native Vegetation

Aerodrome

Horticulture / Viticulture

Town Centre Broadscale Cropping, Yenda ! Industrial & Intensive Agriculture Tharbogang Beelbangera ! !

Bilbul !

GRIFFITH CITY !

Yoogali !

Hanwood Widgelli ! !

Author: K. Lee Figure 3-3 KEY CONSTRAINTS Reviewer: S. Duffy ´ 0 750 1,500 3,000 4,500 A3 Scale: 1:75,000 Metres Riverina Solar Project | Griffith, NSW, Australia ©Aerial imagery supplied by NearMap under Licence Job Ref: 11234 DCDB supplied by Land & Property Information 2016 26 February 2016 ENVIRONMENTAL PROPERTY SERVICES

4 PROJECT DESCRIPTION

4.1 Project Capacity

The Riverina Solar Farm proposal will provide a solar plant installation with a generating capacity of 30MW (AC).

4.2 Project Design and Layout

4.2.1 Electrical Installations

Photovoltaic (PV) panel arrays will be fitted onto single axis tracking supports in the area shown in Figure 4-1. The arrays will be connected to inverters and voltage step up transformers, with electricity transferred by underground cabling to connect to the 33 kV TransGrid Griffith Substation adjacent to the site. Figure 4-2 illustrates the electrical infrastructure adjacent to the subject site.

Site layout assessments and detailed engineering will define the preferred configuration of panels to ensure:

• Maximum exposure to sun; • Efficient layout of solar panels across the site; • Efficient connection to the substation; • Ease of construction; • Efficient access for maintenance and long-term operation; and • So that technology advances can be incorporated e.g. electricity storage, multi access tracking, new panels etc.

The two adjacent properties that form the PAA are divided by Ross Road and an adjacent irrigation supply canal and drainage channel. The power generated on the eastern property will require interconnection to the western property and thence to the sub-station. A final decision has not been made on whether the Ross Road interconnection will be 33 kV underground or overhead. To better consider the environmental and social impacts, the overhead option has been considered in relevant assessments. If the underground option is preferred the 33kV cable would be bored under Ross Road and the irrigation supply canal.

The Project will connect to the TransGrid Griffith Substation via an underground 33 kV transmission line, although this will be subject to a separate approval under Part 5 of the EP&A Act.

ENVIRONMENTAL PROPERTY SERVICES February 2016 - Page 12 Legend: Area of Proposed Landscaping Riverina Solar Project Application Area Burley Griffin Way Approximate Position of Perimeter Road Area for Panel Arrays (Subject to Final Design)

Pavese Road Ross Road

Clark Lane

Hamilton Road Irrigation Way

Yanco Griffith Railway

Author: K. Lee Figure 4-1 CONCEPTUAL SITE LAYOUT Reviewer: S. Duffy ´ 0 100 200 400 600 A3 Scale: 1:10,000 Metres Riverina Solar Project | Griffith, NSW, Australia ©Aerial imagery supplied by NearMap under Licence Job Ref: 11234 DCDB supplied by Land & Property Information 2016 26 February 2016 ENVIRONMENTAL PROPERTY SERVICES Legend: TransGrid Yoogali Substation Area Riverina Solar Project Application Area 132kV National Electricity Transmission Lines

Mackay Avenue Burley Griffin Way

Ross Road

Yanco Griffith Railway

Pavese Road

Clark Lane Kurrajong Road

Hamilton Road

Irrigation Way

Bob Irvin Road

Author: K. Lee Figure 4-2 ELECTRICAL INFRASTRUCTURE Reviewer: S. Duffy ´ 0 150 300 600 900 A3 Scale: 1:15,000 Metres Riverina Solar Project | Griffith, NSW, Australia ©Aerial imagery supplied by NearMap under Licence Job Ref: 11234 DCDB supplied by Land & Property Information 2016 26 February 2016 ENVIRONMENTAL PROPERTY SERVICES

4.2.2 Site Office and Amenities

Ancillary infrastructure associated with the proposal will include a site office, maintenance sheds, access tracks and perimeter fencing. Operations will be controlled by a supervisory control and data acquisition (SCADA) control system.

A pump out toilet will be provided in the site office. Telecommunications and electricity will be connected. Potable water will be supplied by truck for construction and operations.

The site office will be a standard transportable structure and maintenance sheds will be similar transportable sheds or shipping containers within the PAA. There is the potential as well to negotiate with landholders adjacent to the PAA for land access for construction facilities such as sheds and laydown areas.

The site will be fenced with standard rural fencing, inside of which will be a landscaping screen in selected locations. Located inward of the landscaping will be a single lane graveled perimeter access track and firebreak. Inside this track will be the PV panel installation.

4.2.3 Access and Parking

Operational access for light vehicles will be via Hamilton and Ross Roads and sufficient unmarked parking will be available on site.

Construction access will likewise be from either Hamilton or Ross Roads, and Section 8.12 discusses the existing intersection layouts and issues.

4.2.4 Fencing

The standard rural style fencing around the Project site will be retained to reduce the potential visual impact associated with security fencing. Temporary stock fencing might be required to protect sections of landscape plantings as the Project area will be grazed during operations.

4.3 Project Phases

4.3.1 Construction

Construction will be undertaken seven days a week for approximately 6 months of the 12 month construction and commissioning period, in the following partially concurrent sequence:

• Construction of internal access tracks and laydown areas;

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• Removal of internal irrigation bay separating bunds and minor grading for drainage; • Installation of site office and maintenance sheds; • Installation of panel supports; • Solar panel erection; • Underground electrical connection between solar panels and central inverters; • Provision of other utility services (electricity, communications, etc.) as required; • Underground electrical connection to the Griffith substation (including augmentation of switchyard or substation if required - as part of a separate approval); • Installation of balance of system components; • Landscaping, fencing and signage; • Commissioning; and • Operations.

Lay-down areas will be required for the delivery of electrical equipment, and while these locations have not been determined, given the land size they will most likely be within the PAA.

4.3.2 Operation

The Project is expected to operate for approximately 30 years. Maintenance and operational personnel will be required occasionally for the life of the project, although permanent staff are not expected to be based on site.

Maintenance activities will include:

• Solar panel washing; • General equipment maintenance; • Fence and landscape maintenance; • Stock management; and • Pasture management, weed spraying and general farm management.

Equipment updates and replacements will be required from time to time as equipment fails or is rendered obsolete by the rapid improvements in solar technology.

4.3.3 Decommissioning

The proposal would likely be decommissioned at the end of its operational lifespan. In consultation with the landowners, all project related infrastructure would be removed from the site, and the land would likely be returned back to its original condition and agricultural use.

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As the installation process is simple and does not involve mass excavation or concrete pours, decommissioning is also simple and will leave the land surface in a very similar condition to that which exists now.

The alternate to decommissioning will be to extend the life of the project. As this is too distance in time to determine at this stage, any extension of the project life would be subject to further consent at the appropriate time.

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5 STATUTORY AND STRATEGIC CONTEXT

The following section outlines the key legislation and planning instruments relevant to the proposed development.

5.1 Permissibility

The proposed electricity generating facility, is prohibited on land zoned RU1 under the Griffith LEP 2014. However, Clause 34(7) of State Environmental Planning Policy (SEPP) Infrastructure permits the development of ‘solar energy systems’ with consent on any land.

5.2 Commonwealth Legislation

5.2.1 Environment Protection and Biodiversity Conservation Act 1999

The primary objective of the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) is to ‘provide for the protection of the environment, especially those aspects of the environment that are Matters of National Environmental Significance’. Where there is potential for a proposal to have a significant impact on any Matter of National Environmental Significance, or it is unclear whether the proposal may have a significant impact, a Referral under the EPBC Act can be submitted to the Department of Environment for approval, concurrent with the State Significant Development process.

Based on a site inspection undertaken by EPS personnel, and assessment undertaken by EPS’ Principal Ecologist Toby Lambert (FBA Accreditation Number 0034), it is unlikely that the site contains any important habitat for threated species listed under the EPBC Act. In addition, it was considered unlikely that any biodiversity offsets would need to be provided for the project, given the identified lack of remnant native habitats within the PAA. Further comment on potential threatened species and ecological communities is provided in Section 8.3.

Following assessment of the proposal against the Matters of National Environmental Significance, it was determined that the Project does not trigger the need for a referral under the EPBC Act.

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5.3 State Legislation

5.3.1 Environmental Planning and Assessment Act 1979

The EP&A Act forms the statutory framework for environmental assessment and planning approval in NSW. The project is considered ‘State Significant Development’ (SSD) in accordance with Division 4.1 of Part 4 of the EP&A Act. Specifically, Section 89C of the EP&A Act states the following:

89C Development that is State significant development (1) For the purposes of this Act, State significant development is development that is declared under this section to be State significant development. (2) A State environmental planning policy may declare any development, or any class or description of development, to be State significant development.

In accordance with s89C(2), the development is declared to be SSD as it is a type listed in Schedule 1 of the State Environmental Planning Policy (SEPP) - State and Regional Development. Namely;

20 Electricity generating works and heat or co-generation 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.

The proposal has an estimated capital investment value of ~$62 million, therefore triggering clause 20 (a) by being greater than $30 million. The site is not identified as being located in an environmentally sensitive area of State significance. A copy of the Capital Investment Value estimation report is attached at Appendix 4.

Having triggered as SSD, the relevant consent authority is the Minister pursuant to s89D of the EP&A Act:

89D Minister consent authority for State significant development (1) The Minister is the consent authority for State significant development. Note. Section 23 enables the Minister to delegate the consent authority function to the Planning Assessment Commission, the Secretary or to any other public authority.

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Matters for Consideration

Section 79C of the EP&A Act identifies matters for the consent authority to take into account when determining a development application. A checklist of these matters and where they have been addressed in the EIS is provided in Table 5-1.

Table 5-1: Section 79C Matters for Consideration Section 79C Matters for Consideration Relevant Section within EIS The provisions of: (i) any environmental planning instrument Refer to Section 5.4. (ii) any proposed instrument that is or has No proposed instrument has been identified been the subject of public consultation under as relevant to this proposal. this Act and that has been notified to the consent authority (iii) any development control plan Development Control Plans do not apply to State Significant Developments pursuant to clause 11 of State Environmental Planning Policy (State and Regional Development) 2011. (iiia) any planning agreement that has been No planning agreement has been entered entered into under section 93F, or any draft into under section 93F. planning agreement that a developer has offered to enter into under section 93F (iv) the regulations (to the extent that they Refer to Section 5. prescribe matters for the purposes of this paragraph) (v) any coastal zone management plan No coastal zone management plans exist for (within the meaning of the Coastal Protection the site. Act 1979) that apply to the land to which the development application relates (b) the likely impacts of that development, Refer to Section 8. including environmental impacts on both the natural and built environments, and social and economic impacts in the locality (c) the suitability of the site for the Refer to Section 2.2 and Section 8. development (d) any submissions made in accordance with Comments will be addressed as received this Act or the regulations during the EIS exhibition period. (e) the public interest Refer to Section 6 and Section 11. Community Consultation undertaken for the proposal has indicated a strong sense of

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Section 79C Matters for Consideration Relevant Section within EIS The provisions of: public support for solar energy and specifically the Riverina project. A Consultation Report has been prepared and attached at Appendix 2. Further, a Socio- Economic Impact Assessment has been prepared and attached at Appendix 3. This assessment demonstrates the positive social and economic benefits attributed to the proposal including employment generation and contribution toward greenhouse gas reductions. The proposal is considered to be in the public interest.

Secretary’s Environmental Assessment Requirements

An important distinction for State Significant Development is the requirement of all applicants to apply to the Director-General of the Department of Planning and Infrastructure for SEARs, prior to the preparation of an EIS. The requirement for an EIS is specified by s78A (8A) of the EP&A Act.

EPS has prepared this EIS in accordance with project SEARs as issued by DP&E on 2 February 2016. Compliance with the SEARS is summarised in Table 5-2 below. A copy of the SEARs are provided in Appendix 1.

Table 5-2: SEARs Compliance Issue EIS Requirement Where addressed EIS A full description of the development, including: details of construction, operation and decommissioning; Section 4.3 a site plan showing all infrastructure and facilities (including Figure 3-2 any infrastructure that would be required for the development, but the subject of a separate approvals

process);

a detailed constraints map identifying the key environmental and other land use constraints that have Figure 3-3 informed the final design of the development; Strategic justification of the development focusing on site Section 2 selection and the suitability of the proposed site. An assessment of the likely impacts of the development on Section 8 the environment, focusing on the specific issues identified below, including: a description of the existing environment likely to be affected by the development;

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Issue EIS Requirement Where addressed an assessment of the likely impacts of all stages of the development (which is commensurate with the level of impact), taking into consideration any relevant legislation, environmental planning instruments, guidelines, policies, plans and industry codes of practice; a description of the measures that would be implemented to avoid, mitigate and/or offset the impacts of the development (including draft management plans for specific issues as identified below); a description of the measures that would be implemented to monitor and report on the environmental performance of the development A consolidated summary of all the proposed environmental Section 9 management and monitoring measures, identifying all the commitments in the EIS. The reasons why the development should be approved Throughout EIS having regard to the biophysical, economic and social costs and benefits of the development. Consideration of Attachment 1 list of relevant Throughout EIS environmental planning instruments, guidelines, policies, and plans. Inclusion of relevant information and documents set out in Throughout EIS Schedule 1 of the Environmental Planning and Assessment Regulation 2000. Signed report from a suitably qualified person that includes Appendix 4 an accurate estimate of the capital investment value of the development (as defined in Clause 3 of the Environmental Planning and Assessment Regulation 2000). Biodiversity Assessment of the likely biodiversity impacts of the Section 8.3 and development, having regard to the NSW Biodiversity Offsets Appendices 6 and 7 Policy for Major Projects, and in accordance with the Framework for Biodiversity Assessment, unless otherwise agreed by the Department. Heritage Assessment of the likely Aboriginal and historic heritage Section 8.10 and (cultural and archaeological) impacts of the development, Appendix 10 including adequate consultation with the local Aboriginal community. Land Assessment of the impact of the development on Section 8.6 and 8.2 agricultural land and flood prone land, paying particular attention to compatibility of the development with the existing land uses on the site and consistency with the zoning provisions applying to the land. Visual Assessment of the likely visual impacts of the development Section 8.1 and (including any night lighting) on surrounding landowners Appendix 5 and key vantage points in the public domain, and a draft

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Issue EIS Requirement Where addressed landscaping plan developed in consultation with affected landowners. Noise Assessment of the construction noise impacts of the Section 8.9 and development in accordance with the Interim Construction Appendix 9 Noise Guideline (ICNG) and sub-station noise impacts in accordance with the NSW Industrial Noise Policy (INP), and a draft noise management plan if the assessment shows construction noise is likely to exceed applicable criteria. Transport Assessment of the likely transport impacts of the Section 8.12 and development on the capacity, condition, safety and Appendix 11 efficiency of the local and State road networks, and a draft traffic management plan for the construction phase of the development. Water Assessment of the likely impacts of the development on Section 8.7, 8.6 and surface water resources (including any nearby 8.5 watercourses), details of water supply arrangements, and a draft erosion and sediment control plan prepared in accordance with Managing Urban Stormwater: Soils & Construction (Landcom 2004). Electromagnetic Assess the proposed transmission line and substation Section 8.14 Interference against the International Commission on Non-Ionizing Radiation Protection (ICNIRP) Guidelines for limiting exposure to Time-varying Electric, Magnetic and Electromagnetic Fields. Consultation Consult with, and report on the issues raised by relevant Section 6 and local, State or Commonwealth Government authorities, Appendix 2 infrastructure and service providers, community groups, affected landowners and Griffith City Council.

Explain how these issues have been addressed in the EIS.

5.3.2 Threatened Species Conservation Act 1995

Schedules 1 and 2 of the Threatened Species Conservation Act 1995 (TSC Act) contain lists of flora and fauna species and communities, which have been determined by the NSW Scientific Committee as being under threat of serious decline that could ultimately lead to extinction. Schedule 3 of the TSC Act contains a list of ‘Key Threatening Processes’ which threaten, or could potentially threaten the survival or evolutionary development of a species, population or ecological community. Threats to threatened species and other plants and animals in NSW include pest animals, weeds, diseases, and habitat loss or change.

The entirety of the PAA has been extensively disturbed and is currently used for agricultural purposes, including cropping and grazing. It has little ecological value, containing almost no

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remnant native vegetation, apart from a small number of scattered trees. As such, the Project will not threaten the survival or evolutionary development of a species, population or ecological community.

Section 8.3 provides further consideration of ecological values and impacts.

5.3.3 Roads Act

The NSW Roads Act 1993 (Roads Act) contains provisions for both classified and unclassified roads, as well as appointing the Roads and Maritime Services (RMS) and other public agencies as the relevant authorities for roads in NSW. Specifically, the Roads Act regulates any activity that is to be carried out in, on or over public roads. Clause 138 states:

(1) A person must not: (a) erect a structure or carry out a work in, on or over a public road, or (b) dig up or disturb the surface of a public road, or (c) remove or interfere with a structure, work or tree on a public road, or (d) pump water into a public road from any land adjoining the road, or (e) connect a road (whether public or private) to a classified road, otherwise than with the consent of the appropriate roads authority.

The two adjacent properties that form the PAA are divided by Ross Road, as well as an adjacent irrigation supply canal and drainage channel. This means that the power generated on the eastern property will require interconnection to the western property and thence to the sub-station. A final decision has not been made on whether the Ross Road interconnection will be 33 kV underground or overhead. In any case, an approval under s138 will be required from Griffith City Council to carry out this work.

It is noted that an approval under s138 must be applied consistently to the Riverina proposal in accordance with clause 89K of the EP&A Act, which states:

(1) An authorisation of the following kind cannot be refused if it is necessary for carrying out State significant development that is authorised by a development consent under this Division and is to be substantially consistent with the consent: (f) a consent under section 138 of the Roads Act 1993

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5.4 Relevant Environmental Planning Instruments

5.4.1 State Environmental Planning Policy (State and Regional Development) 2011

The Riverina Solar Farm is considered an SSD in accordance with Division 4.1 of Part 4 of the EP&A Act, because it is permissible with consent (pursuant to Cl34(7) of State Environmental Planning Policy (SEPP) Infrastructure), and a development type listed in Schedule 1 of the State Environmental Planning Policy (State and Regional Development) 2011. Pursuant to Clause 8 of the SEPP:

8 Declaration of State significant development: section 89C (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 or 2.

Specifically, Clause 20 of Schedule 1 lists “Electricity generating works and heat or co-generation” as SSD if the capital investment value of the development is greater than $30 million, or more than $10 million and is in an environmentally sensitive area of State significance. The site is not within an environmentally sensitive area of State significance, however the capital investment value of the Project exceeds $30M.

Therefore the Proposal constitutes an SSD, requiring preparation of an EIS and approval by the Minister.

5.4.2 State Environmental Planning Policy (Infrastructure) 2007

The aim of the State Environmental Planning Policy (Infrastructure) 2007 (Infrastructure SEPP) is to facilitate the effective delivery of infrastructure across NSW. The Infrastructure SEPP allows for certain types of infrastructure to be permissible with or without consent or as exempt or complying Development.

Specific to this proposal, Division 4 includes provisions for “electricity generating works and solar energy systems”. The following definitions are relevant:

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Clause 33 – Definitions

solar energy system means any of the following systems: (a) a photovoltaic electricity generating system, (b) a solar hot water system, (c) a solar air heating system.

Clause 34(7) of the Infrastructure SEPP expressly permits development of a solar energy system:

(7) Solar energy systems Except as provided by subclause (8), development for the purpose of a solar energy system may be carried out by any person with consent on any land.

Clause 34(8) only applies to residential zoned land, and does not apply here. Therefore the proposal can be carried out with consent.

5.4.3 State Environmental Planning Policy (Rural Lands) 2008

The State Environmental Planning Policy (Rural Lands) 2008 (the SEPP) was enacted in response to the recommendations from the Central West Rural Lands Panel (2007) advise on rural land use in the Central West Region of NSW. The focus of the Panel’s investigations was the importance of agriculture to the State’s economy, the proper planning of rural lands and the provision of opportunities for rural lifestyle, settlement and housing which contribute to the social and economic welfare of rural communities.

The principle objective of the SEPP is to provide a set of planning principles that will ensure that inappropriate siting of rural residential development and residential uses in rural areas that causes land use conflict between rural and non- rural uses that impact on farm activities does not occur.

The Riverina Solar Farm is not proposing any residential land-use, includes ancillary agricultural land uses i.e. growth of pasture and grazing and upon decommissioning the site can be returned to full time agricultural uses.

The review of the Rural Lands SEPP concludes the proposed Riverina Solar Farm development is not incompatible with the aims and objectives of the SEPP.

5.4.4 State Environmental Planning Policy No. 44 – Koala Habitat Protection

The aim of the State Environmental Planning Policy No 44—Koala Habitat Protection (Koala Habitat SEPP) is to encourage the proper conservation and management of areas of natural

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vegetation that provide habitat for koalas to ensure a permanent free-living population over their present range and reverse the current trend of koala population decline. Clause 5(1) provides for the land to which this policy applies.

5 Land to which this Policy applies (1) This Policy applies to each local government area listed in Schedule 1.

The Riverina Solar Farm site is located in the Griffith Local Government Area. Griffith is not included in the list of LGA’s contained in Schedule 1. Therefore, the Koala Habitat SEPP does not apply and has not been considered further.

5.4.5 State Environmental Planning Policy No. 55 – Remediation of Land

State Environmental Planning Policy No. 55 – Remediation of Land provides the statutory framework for addressing development on contaminated land. It specifies when consent is required for remediation work, specifies considerations that are relevant in rezoning land and in determining development applications and requires such remediation work to meet certain standards and notification requirements.

The Riverina Solar Farm project does not require rezoning of land therefore the SEPP No. 55 rezoning provisions do not apply.

Clause 7(1) of SEPP 55, prevents the DoP&E, as the consent authority, from issuing a consent for the Riverina Solar Farm on the site unless:

(a) it has considered whether the land is contaminated, and (b) if the land is contaminated, DoP&E is satisfied that the land is suitable in its contaminated state (or will be suitable, after remediation) for the purpose for which the development is proposed to be carried out, and (c) if the land requires remediation to be made suitable for any purpose for which the development is proposed to be carried out, it is satisfied that the land will be so remediated before the land is used for that purpose.

The Riverina Solar Farm site has been used for many years for cereal cropping and occasional grazing. Table 1 on page 12 of the “Managing Land Contamination Planning Guidelines” lists agricultural activities that may cause contamination.

Methods to control weed on the site have included the use of chemical controls i.e. approved herbicides. Herbicides control weed plants either by speeding up, stopping or changing the plant's normal growth patterns; by desiccating (drying out) the leaves or stems; or by defoliating the plant (making it drop its leaves). Once used the herbicides rapidly break down, through contact

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with the environment e.g. exposure to sunlight (photolysis), exposure to water (hydrolysis) exposure to other chemicals (oxidation and reduction), microbial activity (bacteria, fungi, and other microorganisms) and plants or animals (metabolism), to a level that is not a concern to human health by government standards

Methods to control pests have included the use of chemical controls i.e. approved pesticides. Pesticides control are used to destroy, suppress or alter the life cycle of any pest that may impact a particular crop. Once used the herbicides break down, through contact the environment e.g. exposure to sunlight (photolysis), exposure to water (hydrolysis) exposure to other chemicals (oxidation and reduction), microbial activity (bacteria, fungi, and other microorganisms) and plants or animals (metabolism), to a level that is not a concern to human health by government standards.

The other source of possible site contamination is from hydrocarbons e.g. diesel fuel associated with the use of farm machinery on the site. While it is likely minor diesel spills may have occurred on the site there is no evidence of either minor or major diesel spills/staining.

Cereal cropping has included both rice and wheat which have been sold for human consumption.

There are no indications that contamination from the use of approved herbicides and pesticides or petroleum products is present on the site.

The relevance of the possible contamination to the construction and operation of the Riverina Solar Farm is considered low. The Riverina Solar Farm will have ancillary agricultural uses in the form of planting and maintenance of pasture and the grazing of pasture.

The construction of the Riverina Solar Farm is commensurate to the construction of typical agricultural infrastructure on farming land e.g. digging of trenches to lay pipe or cable and the installation of posts. Construction will also include the planting of pasture under the solar panels. The operation of the Riverina Solar Farm will include management of pasture and weeds under the panels in accordance with usual farming practices e.g. grazing and use of approved herbicides.

The Riverina Solar Farm does not include residential, educational, recreational childcare or hospital uses.

In comparison Local Council’s use herbicides and pesticides and likely have minor petroleum spills in many public places that have high use over long periods of time .e.g. sports fields, parks and gardens.

The review of the SEPP 55 concludes the land is suitable for the proposed Riverina Solar Farm development.

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5.4.6 Griffith Local Environmental Plan 2014

The site is subject to the provisions of the Griffith Local Environmental Plan 2014 (Griffith LEP). The objectives of the Griffith LEP are listed under Clause 1.2 ‘Aims of Plan’:

(2) The particular aims of this Plan are as follows: (a) to prevent unnecessary urban sprawl by promoting business, industrial, rural and residential uses within and adjacent to existing precincts related to those uses, (b) to minimise land use conflict in general by creating areas of transition between different and potentially conflicting land uses, (c) to provide a variety of development options to meet the needs of the community with regard to housing, employment and services, (d) to manage and protect areas of environmental significance, (e) to recognise the historical development of the area and to preserve heritage items associated with it.

This proposal is generally in accordance with the aims of the Griffith LEP by providing a variety of development options to meet the needs of the community.

The subject allotments are zoned ‘RU1 – Primary Production’ pursuant to the LEP. The objectives of the zone 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;  To permit a range of activities that support the agricultural industries being conducted on the land and limit development that may reduce the agricultural production potential of the land; and  To permit tourist facilities that promote an appreciation of the rural environment and associated agricultural and horticultural activities, while ensuring the continued economic viability of the land.

The proposal promotes the principle of sustainability by providing an electricity generating facility through a natural and inexhaustible resource to the benefit of the community and the

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environment. Though the Riverina Solar Farm would use land currently utilised for primary production, the development will not result in fragmentation of resource lands nor will it restrict the medium to long term use of the site for agricultural purposes, following the likely decommissioning of the project after a period of about 30 years. While not explicitly in accordance with the objectives, the proposal will provide suitable diversity of land use, including grazing of sheep, in the area with low to negligible impact on the quality of agricultural land.

The development of an electricity generating facility, such as the proposed Riverina Solar Farm, is not listed as permissible on land zoned RU1 under the Griffith LEP. However, as outlined above, Clause 34(7) specifically permits the development of a solar energy system on any land where consent is granted. The exceptions to Clause 34(7) do not apply here as the allotments are not residentially zoned.

Accordingly, the development is permissible with consent.

5.5 Project Approvals and Licences

Approval/Licence Relevant Legislation Comment Development Section 89E - EP&A Act This EIS forms the supporting document for a Consent 1979 Development Application under Part 4 of the EP&A Act. The project requires development consent from the Minister pursuant to clause 89E. Construction Section 81A and Part 4A - A Construction Certificate is required prior to the Certificate EP&A Act 1979 commencement of construction activities. Section 138 Roads Section 138 - Roads Act An approval under s138 will be required prior to Approval 1993 construction, however in accordance with clause 89K of the EP&A Act, this approval cannot be refused for an SSD with development consent. Aboriginal Heritage Section 90 - National Parks An AHIP is not required for this proposal pursuant Impact Permit and Wildlife Act 1974 to clause 89J(1)(d) of the EP&A Act. Environment Section 48 - Protection of An EPL is not required for this proposal. While Protection Licence the Environment clause 17, schedule 1 of the POEO Act lists Operations Act 1997 electricity generation works with a capacity of 30MW or greater as a scheduled activity, thus requiring an EPL, the definition specifically excludes solar power by stating: general electricity works, meaning the generation of electricity by means of electricity plant that, wherever situated, is based on, or uses, any energy source other than wind power or solar power.

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Grid Connection NEM Rules Connection to the Griffith Substation will be obtained under a separate approval process, with TransGrid as the nominated determining authority.

In the event that any additional approvals or licenses are required for the proposal, these will be obtained prior to construction, or the relevant activity.

5.5.1 Water Entitlements

The property is located within the MIA and adjacent to the Clark Road irrigation channel.

Properties in this locale rely heavily upon water entitlements for the production of agriculture. In this region the allocation of water is separated in to four categories, Towns, Stock & Domestic, General Security and High Security. General and High security entitlements may be purchased and sold independently to the land.

The allocation of water is determined by calculating the volume of water that is available for consumption and a percentage is allocated to the entitlement. The allocation is subject to change, usually on a monthly basis. General security entitlements are more susceptible to fluctuating changes and are always allocated a smaller percentage due to a country-wide over allocation of water resources. In most years, the total irrigation allocation is a fraction of the licence. For example, in 2016 the allocation was ~37% of the licenced volume.

The landowners of the PAA currently hold a general security water entitlement for irrigation which is used across an area of land much larger than the PAA. This water entitlement is not attached to the land and will remain in the control of the landowners. No changes are proposed to the existing water entitlements.

5.6 Relevant Strategies and Policies

5.6.1 Commonwealth Renewable Energy Target Scheme

The Renewable Energy Target is an Australian Government scheme designed to reduce emissions of greenhouse gases in the electricity sector and encourage the additional generation of electricity from sustainable and renewable sources. The RET is divided into two schemes, including:

 The Large-scale Renewable Energy Target, which encourages investment in renewable power stations to achieve 33,000 gigawatt hours of additional renewable electricity generation by 2020 (approximately 20% of energy in Australia); and

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 The Small-scale Renewable Energy Scheme, which supports small-scale installations like household solar panels and solar hot water systems.

Essentially, the large-scale scheme will deliver the majority of the 20% renewable generation target, while the small-scale scheme will implement on the ground changes such as solar rooftop panels and solar hot water systems to increase the take up of renewable energy.

The Riverina proposal will specifically contribute to the large-scale RET scheme through the generation of electricity from a renewable solar resource, thereby meeting a key objective of the Renewable Energy (Electricity) Act 2000.

5.6.2 NSW Renewable Energy Action Plan

In September 2013, the NSW Government released the NSW Renewable Energy Action Plan to guide NSW's renewable energy development and to support the former national target of 20% renewable energy by 2020. The NSW Government's vision is for a secure, reliable, affordable and clean energy future for the state. The 2015 Annual Report outlines three important goals, with a series of 24 actions to successfully execute the plan. The three identified goals are to: attract renewable energy investment, build community support, and attract and grow renewable energy expertise.

The Plan positions the state to increase energy from renewable sources at least cost to the energy customer and with maximum benefits to NSW. Consistent with the Plan and the identified goals, the proposal:

 Attracts investment in renewable energy and brings this investment to the Griffith region;  Relies on knowledge and expertise within NSW to build renewable energy resources; and  It increases the mix of energy sources within NSW.

The proposal is strategically aligned with the NSW Renewable Energy Action Plan and is considered to be a positive contribution to the State’s energy industry.

5.6.3 NSW 2021

‘NSW 2021’ is the NSW Government’s 10 year plan to guide policy and decision making in order to deliver a series of identified economic and community priorities. The foremost priority of the Plan is to restore economic growth in NSW and make this State the first place to do business in Australia.

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The Riverina proposal will contribute to this priority through the delivery of additional infrastructure and economic stimulus in regional NSW. The remaining priorities under the 2021 Plan are to:

 Return quality services;  Renovate infrastructure;  Strengthen our local environment and communities; and  Restore accountability to Government.

In addition to providing economic stimulus within NSW, the Riverina proposal is representative of a sustainable development with minimal impact on the local environment with no greenhouse gas emissions. Further, the NSW 2021 Plan refers to the NSW Renewable Energy Action Plan as a priority action. The proposals consistency with the Renewable Energy Action Plan has been addressed above.

Overall, the Riverina Solar Farm represents a private investment in renewable energy that directly assists the NSW Government in meeting their priority actions under the NSW 2021 plan.

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6 CONSULTATION

A Stakeholder Engagement and Community Consultation Report has been prepared that outlines the steps and tools used to provide consultation between the project proponents and the key stakeholders. The full report is provided at Appendix 2 and is summarised in the following sections.

6.1 Key Stakeholders

The relevant local stakeholders were:

• Landholders and occupiers of affected lots; • Landholders and occupiers of adjacent lots; • Griffith Local Aboriginal Land Council (GLALC); and • The wider community.

The relevant government departments and authorities who have been consulted regarding the proposal include:

• NSW Department of Premier and Cabinet (DP&C); • NSW Department of Planning and Environment (DP&E) • NSW Department of Industry (DoI); • NSW Department of Primary Industries (DoPI); • Office of Environment and Heritage (OEH); • Griffith City Council (GCC); and • Transgrid.

6.2 Community Consultation

6.2.1 Consultation Program

EPS and Suntech developed a Community Consultation Program at the project inception stage. The consultation program has three key objectives and four distinct phases to ensure consultation obligations were met during the preparation of the EIS.

The consultation program objectives were as follows:

• To raise awareness of the proposal with adjacent landowners, Council, Government Agencies, key stakeholders and community groups;

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• To provide the opportunity for all community, key stakeholders and interested parties to comment and provide feedback on the proposal; and • To provide the opportunity for the proponent to interact with the local community, key stakeholders and interested parties to establish and maintain open and good working relationships.

6.2.2 Consultation Program Phases

The Consultation Program has four phases which provide effective consultation from Project inception through to construction and operational stages. This program aimed to ensure that all relevant environmental, social and economic issues raised by stakeholders and the community were considered and addressed within the EIS.

These consultation phases are as follows:

Table 6-1: Consultation Program Phases Phase Actions Preparatory Stage • Preparation of database of contacts; • Preparation of data collection material; • Preparation of presentation materials for briefings – including factsheets and project information sheets; • Preparation of project website; and • Preparation of timetable of visits and presentations. Phase 1 – • Communication with adjacent residents, key community groups Project Meetings with and Government Agencies; Key Stakeholders • Face to face meetings with adjacent landholders, Government Agencies and key stakeholders; • Councils and Key Government Agency introductory briefings; • Publishing of project website and a dedicated contact avenue for solar farm information; and • Follow up meetings with the adjacent landholders, Local Council and other Key Government Departments. Phase 2 – • Media release i.e. local newspaper of project information and Community Information updates; • Introductory letter/flyer to relevant community members; and • Project information and updates on website. Phase 3 – • Lodgement of Environmental Impact Statement; and Part 4 of the EP&A Act • Community opportunity to provide submissions. Assessment Process Phase 4 – • Communication with adjacent landholders including establishment of complaints line;

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Phase Actions Construction and • Media releases; and Operation of Solar Farm • Ongoing community liaison.

6.2.3 Summary of Community Issues and Enquiries

A total of approximately forty three (43) interested parties attended the community information sessions. Attending parties were generally interested in the purpose and design of the proposal. Notably, no serious concerns or objections to the proposal were expressed. Enquiries generally related to the positive socio-economic impacts of the proposal, the potential visual impacts and potential for generation for EMF. This is consistent with the responses received through other consultation methods, with a total of two (2) emails enquiries and seven (7) phone-calls received to date. Generally, the response and interest from the community has been positive, and indicates a broad acceptance of the proposed solar farm.

In relation to targeted consultation meetings with neighbouring properties, no serious concerns or objections have been recorded. Many neighbouring properties have expressed interest in being involved in any future expansion of the project.

6.2.4 Contact for Public Enquiries

Project contact details are provided via the project website. All enquiries from members of the general public with regard to the project will be recorded on an electronic database. Details of the person are logged including their address and contact details, nature of the concern and response from EPS and SFCE. At the time of writing this EIS, nine (9) public enquiries have been made regarding the project.

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7 ENVIRONMENTAL RISK ASSESSMENT

This section provides a risk assessment of the potential environmental impacts of the development, identifying the key issues for further assessment. The purpose of the environmental risk assessment is to assign a qualitative environmental risk category to each of the identified environmental issues. Accordingly, this section considers:

• The potential environmental impacts associated with the Project including, where relevant, the environmental performance criteria and development standards; • The proximity of nearby residences identified as key sensitive receivers shown in Figure 7-1; and • The nature and extent of environmental impacts likely to remain after the implementation of mitigation and control measures.

The following key environmental issues are identified in the SEARs:

• Biodiversity; • Heritage; • Land - Primary agriculture; • Visual amenity; • Noise; • Traffic and transport; • Water; and • Electromagnetic interference.

Table 7-1 provides the risk categories used to guide the identification and application of an appropriate risk rating. The risk category is determined on the basis of likelihood of an impact occurring and the consequences if it did occur.

Each environmental issue was initially rated based on potential unmitigated or uncontrolled impacts, ignoring current site mitigation and management practices. A residual risk rating was assigned based on consideration and implementation of proposed mitigation and control measures. A summary of the environmental risk analysis is provided in Table 7-2.

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Table 7-1: Environmental Risk Assessment Categories

Likelihood Negative risk or Certain Probable Possible Remote probable positive risk Could happen May and has Practically impossible Common happened happened in Not likely or positively probable within RSP non-RSP projects Unlikely to May occur in occur, very exceptional Consequence - single impact and cumulative Frequent Regular Infrequent Rating few recorded circumstances - Incidents incidents incidents or known almost no recorded incidents incidents Within 3 Within 2 Within 5 Within 10 Negatively improbable Economic Social Environmental months years years years or positively probable Impact to Negatively or Business Personal Occupational Health & Every Every 2nd One project One project Annual Legal Reputation Environment positively with Disruption Injury Safety project project in five in ten Business frequency Exposure to a severe, Litigation, Prolonged Long term 1 - Multiple adverse long-term heavy fines, international impairment > $5m > 1 month Catastrophic Fatalities health impact or life- criminal media habitats / 1 2 5 7 11 threatening hazard charge attention ecosystem Exposure to a hazard Major breach International Long term $3m - 1 week to 1 Single 2 - Major that results in surgery or / major media effects on $5m month Fatality 3 4 8 12 16 permanent disablement litigation attention ecosystem Exposure to a hazard Serious that could cause injuries Serious medium Serious / breach of National $0.5m - 1 day to 1 or health effects term 3 - Moderate Disabling regulation - media $3m week requiring treatment by a environmental 6 9 13 17 20 Injury prosecution/ attention physician or effects fine hospitalisation Exposure to a hazard Non- that could cause injuries Adverse local Minor effects to $100k - 12 hrs to 1 Lost Time compliance 4 - Minor or adverse health effects public biophysical $0.5m day Injury breaches in 10 14 18 21 23 requiring treatment by a attention environment regulation qualified person An injury or ailment that Minimal 5 - <$100k Low level Limited or no < 12 hours does not require opposition or Insignificant/ or First Aid compliance physical or positive medical treatment by a positive 15 19 22 24 25 Positive positive issues damage qualified professional. influence

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Table 7-2: Environmental Risk Assessment Issue Potential Initial Risk Control Measures Residual Impacts Final Impacts Rating (no Risk mitigation) Rating Construction Nuisance to 14 Water cart on unsealed haul roads. Distance to receptors No nuisance predicted. 18 Dust adjacent and minimal earthmoving. residents Aboriginal Damage to 18 Due diligence survey conducted to locate artefacts. Identified artefacts of low 24 Heritage artefacts or significance due to other items agricultural disturbance. Construction Exceedance of 22 Nature of works similar to agricultural activities in the Exceedance Interim 24 Noise criteria area. Distance to receptors, plant maintenance and minor Construction Noise construction scope. Guidelines predicted. Visual Impact on 10 Landscaping proposed and consultation with Visual impact during 22 neighbours and neighbouring landholders. construction and while travellers landscaping is established. Glint and Impacts on 12 Consultation with aviation organisations and selection of No glare impacts on 21 Glare pilots and air panel materials. approach or departure from safety, Griffith Aerodrome, minimal disturbance to glare impacts on low flying neighbours agricultural aircrafts Erosion Offsite pollution 24 Site is flat and enclosed by irrigation bunds. Sediment Nil. 24 unlikely to be generated and leave site. Flooding Diversion of 17 Panel support unlikely to collect flood debris and No diversion of flows or 20 flows or impact consequently divert flood flows. Sensitive electrical impact to facility to facility. components located above PMF level. Standard rural anticipated. fence in keeping with existing and adjacent fences proposed.

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Issue Potential Initial Risk Control Measures Residual Impacts Final Impacts Rating (no Risk mitigation) Rating Traffic Heavy vehicle 14 Routine truck scheduling, dilapidation survey, community Minimal effect on other 21 on road surface consultation as per the Traffic Management Plan. road users and and road users. Selection of heavy vehicle route in consultation with infrastructure. Griffith City Council. Biodiversity Impact on 24 Minimal removal of native vegetation. Minimal impact predicted. 24 native species. Fire Damage to 13 Perimeter firebreaks will be maintained and the operator Remote possibility of 17 facility or will liaise with the local RFS Fire Controller. Installation of damage to crops or facility. adjacent crops. only Australian Standard compliant components. Installation and management of SCADA system to monitor system performance. Installation of thermal overload protection on inverters. Controlled grazing of pastures under panel arrays. EMF EMF exceeds 14 The majority of connections will be shielded underground No exceedances predicted. 24 the cables that do not produce measurable EMF. The two International above ground connections (the interconnection to the Commission on TransGrid substation and the interconnection over Ross Non-Ionizing Road) have calculated EMF below criteria. Radiation Protection criteria. Loss of Long term loss 14 The nature of the project means that there will be little Reduced production during 25 agricultural of productive land disturbance and on decommissioning of the plant, the operational phase. land land the land will revert to its former agricultural capability. Diversification of farm There will be reduced grazing potential during operations. income. The project allows for diversification of farm income against a backdrop of decreasing irrigation allocations that restrict traditional farm incomes.

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Issue Potential Initial Risk Control Measures Residual Impacts Final Impacts Rating (no Risk mitigation) Rating GHG Contribution to 25 Nil. The project will have significant beneficial impacts. Significant beneficial 25 global warming impacts

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Location of Residence

Riverina Solar Project Application Area Yoogali (! Mackay Avenue Burley Griffin Way 1.5km Radius from Centre

(! Locality Ross Road

Pavese Road

Kurrajong Road Yanco Griffith Railway

Clark Lane

Hamilton Road

Irrigation Way

TransGrid Yoogali Substation

Bob Irvin Road

Author: K. Lee Figure 7-1 KEY SENSITIVE RECEIVERS Reviewer: S. Duffy ´ 0 100 200 400 600 A3 Scale: 1:14,000 Metres Riverina Solar Project | Griffith, NSW, Australia ©Aerial imagery supplied by NearMap under Licence Job Ref: 11234 DCDB supplied by Land & Property Information 2016 26 February 2016 ENVIRONMENTAL PROPERTY SERVICES

8 KEY ENVIRONMENTAL ISSUES

8.1 Visual Impact and Landscape

A Visual Impact Assessment has been completed for the Project and is provided in Appendix 5. Below is summary of the key findings.

8.1.1 Existing Environment

The following key features characterise the landscape of the proposed Riverina site:

 The site is located directly adjacent to the 33kV TransGrid Griffith Substation;  The site is bounded by Griffith Road (State Highway 94 – ‘Irrigation Way’) and the Yanco to Griffith freight/passenger rail line to the south and south-west;  The site is bounded by an unsealed dirt access way, Ross Road, to the east and north-east;  The site has been used for many years for cereal cropping and occasional grazing, and is clear of any additional development; and  The site is located approximately 1.5km from Yoogali town centre measured from the northern most boundary of the site.

The sites landscape is characterised by flat land predominantly used for agriculture. The land is approximately 134m above sea level with a gradient of less than 0.5 percent.

The site has been used for many years for cereal cropping and occasional grazing, and is clear of any additional development. The Immediate Visual Catchment (<1km) and the Local Visual Catchment (1-3km) are both dominated by agricultural uses.

The scenic quality of the PAA and surrounding area can be identified as containing flat terrain with rural structures and prominent areas of farmland. The scenic quality is rated as moderate for the degree of naturalness as it is dominated by agricultural landscape forms.

8.1.2 Impacts

Sensitive receptors

23 dwellings are located within 1.5km radius of the site. Each of the sensitive receptor locations where visited to assess the visual potential from each to the Riverina Solar Farm. As illustrated in Figure 7-1 in the Visual Impact Assessment report, the receptors (excluding the project land owners [receptors 22 & 23] and the Neon Griffith Solar Farm host land owner [receptor 21]) that

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could have a view towards the Riverina Solar Plant are receptors 1, 2, 3, 4 & 20. The views toward the solar farm from some of these residences will be mitigated by the proposed landscape screen planting.

Landscape receptors

Landscape receptors are considered less sensitive to change than ‘sensitive receptors’. Landscape receptors include pedestrians and motorists that would view the Project infrequently, intermittently and/or over a short timeframe. Landscape receptors have less vested interest and emotional connection to the landscape.

As the site is flat and mostly cleared of vegetation, the site can be clearly seen from several offsite locations. The Visual Impact Assessment report identifies various that have informed this visual assessment. In assessing the impact from these viewpoints, the following ratings have been applied:

 High – The construction and operation of the Project may result in a very prominent physical change to the landscape, and extensive portions of the Project will dominate the landscape from sensitive view locations.  Moderate – The construction and operation of the Project may result in a noticeable physical change to the landscape although the Project would not appear to be substantially different in scale and character to the existing landscape from surrounding view locations;  Low – The construction and operation of the Project is unlikely to result in a prominent change to the landscape and views from surrounding locations toward the Project may be difficult to distinguish from elements within the surrounding landscape.; and  Nil – The construction and operation of the Project would not create a noticeable change to the landscape or surrounding view locations.

The Visual Impact Assessment concludes that the impact on the viewpoints were all rated as low to moderate.

As part of the assessment process, the study area has been divided into zones categorised by spatial or character properties. Two landscape character zones have been identified within the Project study area:

 Zone 1 – Rural Agricultural; and  Zone 2 – Utilities.

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An assessment of the landscape sensitivity was undertaken based upon an evaluation of the physical attributes identified within each landscape zone and the extent to which it could accommodate the Project without demonstrable change to the character.

Zone 1 – Rural Agricultural

This zone is identified as being the most prominent in the area surrounding the PAA. The rural agricultural landscape is large and open, with typically flat terrain and simple uniform and linear patterns with little variation. Views are occasionally interrupted by scattered vegetation, as well as drainage and irrigation networks. Although the landscape is generally open and flat, rural fencing, road networks and drainage and irrigation channels adjoin the rural areas. Rural dwellings are scattered through the landscape.

Given the low height of the solar panels (approximately 3-4m above ground level), the linear composition (consistent with the pattern of cropping and citrus plantations), ongoing cropping/grazing use of the site and screen planting, the proposal will be of a scale consistent with the rural landscape. Therefore the landscape sensitivity impact for this zone is considered to be low to moderate at most.

Zone 2 – Utilities

This zone is generally characterised by simple patterns and flat terrain, with higher visibility than the previous zone. The height of transmission line poles and wires are distinct within the landscape, given the simplicity and limited landscape variability within the rural backdrop. The sub-station built form is imposing and dominates the skyline. The solar panels will be orientated to the north away from Irrigation Way minimizing the visible bulk and mass of the project in this landscape.

The main transport corridor is Irrigation Way. Griffith City Council has conducted recent daily traffic counts in the area and the data relevant to Irrigation Way adjacent to the TransGrid Substation, 1,434 AADT both ways. This section of the Irrigation Way is a 100km per hour speed zone.

Traffic approaching the site from Griffith along this road will only have a view from approximately 400-500m of roadway towards the Riverina Solar Farm. Vehicles travelling towards the site and Griffith will have a view from approximately 500m of roadway towards the Riverina Solar Farm. Vehicles travelling at 100km per hour will cover the 500m distance in approximately 18 seconds. As the solar plant will present a different and unique view from the highway compared to the surrounding landscape, to prevent driver distraction a landscape screen is proposed. The view of the solar infrastructure will be screened by 3-4m high landscape trees when they mature.

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The sensitivity of this zone with the landscape screening is considered to be low.

8.1.3 Mitigation Measures

To ameliorate the appearance of the project the following mitigation will be adopted:

 A 5m wide double row planting landscape screen will be established along the PAA boundary fronting Clark Road and along Irrigation Way (Griffith Road) and a small section along the north western boundary to reduce visibility of the Project from these aspects. The intention of this screen is to ameliorate any driver distraction the proposal may result for passing vehicles and screen the proposal from adjacent residences as requested by landowners.

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8.2 Land Use

8.2.1 Existing Environment

The Mirrool Irrigation Area and the MIA generally are important agricultural production and processing region, producing citrus, grapes, wine, cereals, rice, cotton, nuts, and other crops, poultry and pigs as well as providing grazing for other livestock. The MIA produces on average a quarter of NSW’s fruit and vegetable. The NSW Farmers’ Association 2014 Triennial Assessment of the National Water Initiative reports that the MIA contributes over $5 billion annually to the Australian economy.

Singh et al (2005) report the following areas under various agricultural production:

• Horticulture (primarily grapes and citrus): 24,800 ha; • Vegetables: 3,000 ha; and • Broadscale agriculture (primarily wheat and rice) and pasture: 157,000 ha.

Crops change over time, according to market prices, changing demand and water availability. While irrigated rice production had increased over the past years, it is increasingly being replaced by irrigated cotton.

The Project site operates as an irrigated cropping enterprise, commonly growing summer irrigated rice and winter cereals, primarily wheat. This type of double cropping is common in areas of heavy soils such as the Darling Downs and the Gunnedah basin, but very much less common in the rest of the country. In the dry climate of Griffith, only irrigation allows double cropping, which consequently significantly improves the total annual production from the site and the gross financial returns from the land.

Adjacent to the Project site are a variety of primarily irrigated horticultural and broadscale agricultural farms. To the north and west, horticulture and viticulture predominate on the better drained red-brown earths and sandier soils. To the south and east, generally on heavier soils, larger annual cropping enterprises predominate. Figure 3-3 (Constraints Map) shows the approximate distribution of the primary farming enterprises.

8.2.2 Impacts

The Project will, in the medium term, curtail the cropping opportunity on approximately 100 ha of the Project site that is cultivated. Consequently, annual crops of both rice and wheat, averaging 12 and 5 tonnes per ha respectively, will be curtailed for the operating life of the Project.

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Assuming a regular double cropping regime on the entire cultivated part of the Project area, and further assuming an average production rate of 12 t/ha for rice and 5 t/ha for wheat, approximately 1,200 t of rice and 500 t of wheat would be grown annually.

Rice production in the MIA is highly dependent on the availability of irrigation water. After some years of low production due to drought, more recent rice harvest have increased: 963,000 t in 2012, 1,166,000 t in 2013 and 829,000 t in 2014. ECOS (2010) reports that “Australian rice production from 1999 to 2002 averaged more than 1.3 million tons per year. In the seven years from 2003 to 2009, the average was less than 360 000 tons.”

An average annual rice production figure is somewhat misleading, but it is apparent that the medium-term loss of 1,200 t of rice per year due to the Project is a very minor change on the district’s production potential, whatever the weather conditions.

ABARES reports that the 2014/15 NSW wheat crop was 7.2 Mt, and while wheat crops rise and fall with seasonal conditions, the wider spread of wheat crops across the continent tends to balance these changes more so than for rice, which is primarily grown in NSW alone. The medium- term loss of 500 t of wheat crop per year is a very minor reduction in the state crop.

With regards to areas of cultivation rather than tonnage production, Singh et al report that in 2000, the MIA as a whole has 26,853 ha under wheat cultivation, and 53,000 ha under rice cultivation. The Project would reduce these totals (based on 2000) by 0.4 % and 0.2 % respectively. This very minor reduction is not expected to measurable affect the various support industries such as share farming, harvesting services, grain transport, grain storage or marketing services. Nor is such a minor reduction expected to have any effect on food security or grain supply to local livestock businesses.

In any event, on decommissioning of the Project facilities, the land will be capable of being returned to its previous agricultural production.

8.2.3 Mitigation Measures

To maintain some agricultural production, the Project site will be sown with permanent pasture and grazed for the life of the operation. On decommissioning, the facility will be demolished and the land will be returned to its current agricultural production potential.

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8.3 Biodiversity

8.3.1 Methodology

The SEARs outlined that a biodiversity assessment should be prepared in accordance with the Framework for Biodiversity Assessment (FBA) process.

The entirety of the PAA has been extensively disturbed and is currently used for agricultural purposes, including cropping and grazing. It has little ecological value, containing almost no remnant native vegetation, apart from a small number of scattered trees. Water supply canals and drainage channels occur adjacent to the site however these are not natural structures and are regularly maintained to ensure their continuing effective operation, and are mostly dominated by weeds.

The intensity of biodiversity assessment reflects the high level of disturbance to the site. The biodiversity assessment has been written within this section of the EIS rather than as a stand- alone Biodiversity Assessment report due to the simplistic and disturbed nature of the site. It has been prepared by an accredited person (Principal Ecologist Toby Lambert – Accreditation Number 0034) under the FBA.

This EIS section includes consideration of:

• “Field survey methods” as outlined on the OEH website; • The draft “Threatened Biodiversity Survey and Assessment: Guidelines for Developments and Activities” (Department of Environment and Conservation 2004); • Threatened Species Survey and Assessment Guidelines: field survey methods for fauna – amphibians (Department of Environment and Climate Change 2009); • BioBanking Assessment Methodology 2014 (OEH 2014a); • Framework for Biodiversity Assessment (OEH 2014b); • BioBanking Assessment Methodology and Credit Calculator Operational Manual (DECC • 2009a) and the current draft revision as updated for the FBA; • Assessors Guide to Using the BioBanking Credit Calculator v.2 (OEH 2012); • Policy and Guidelines for Fish Habitat Conservation and Management Update 2013 (Department of Primary Industries 2013); • NSW State Groundwater Dependent Ecosystems Policy (DLWC 2002); • Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act); • NSW Environmental Planning and Assessment Act 1979 (EP&A Act); • NSW Threatened Species Conservation Act 1995 (TSC Act); • NSW Fisheries Management Act 1994 (FM Act);

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• Mapped vegetation communities in the OEH Vegetation Information System (VIS) Map Catalogue; and • Biodiversity mapping prepared as part of the Griffith LEP 2014.

A review of ecological studies and various databases (NSW Bionet, Threatened Species, Populations, and Ecological Communities of NSW, Spatial Information Exchange, and Commonwealth Protected Matters search tool) provided a list of threatened species, populations, ecological communities, and invasive species that had been previously reported, known or predicted to occur on or adjacent to the PAA.

Figure 8-1 shows the locations of threatened species records within a 10km radius of the PAA. This shows that threatened species in the locality are primarily threatened woodland bird species. The closest records of any threatened species are of Pied Honeyeater and Painted Honeyeater approximately 2km to the south-east of the PAA where Weeping Myall vegetation occurs alongside water supply channels.

Figure 8-2 shows the location of mapped remnant native vegetation in the locality. This shows that Weeping Myall open woodland of the Riverina and NSW South-western Slopes Bioregions is mapped as occurring outside but alongside the PAA in roadside areas. No remnant native vegetation is mapped as occurring within the PAA.

The tables in Appendix 7 provide the locally relevant threatened species, populations and threatened ecological communities and related consideration of likely significance of impacts of the project.

8.3.2 Preliminary Analysis

The preliminary analysis of the site identified the following:

• The individual allotments included as part of this proposal are not identified on the Griffith LEP 2014 ‘Terrestrial Biodiversity’ Maps; • A total of 23 threatened fauna species listed under TSC Act and / or EPBC Act had either been recorded, known or predicted to occur within the PAA; • A total of 3 threatened flora species listed under TSC Act and / or EPBC Act had either been recorded, known or predicted to occur within the PAA; • A total of 11 Endangered Ecological Communities (EEC) listed under TSC Act and / or EPBC Act had either been recorded, known or predicted to occur within the PAA; • A total of 8 Listed Migratory species, listed under EPBC Act were likely to occur within the PAA; • No critical habitat listed under the EPBC Act occurred within the PAA;

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• A total of 33 Key Threatening Processes (KTP’s) listed under the TSC Act were predicted to occur within the PAA; and • A total of 28 invasive species listed under the EPBC Act were predicted to occur within the PAA.

Based on this preliminary analysis, it was considered unlikely that any threatened species, population or endangered ecological community are present on the site, nor would they be impacted by the project. In addition, it was considered unlikely that any biodiversity offsets would need to be provided for the project, given the identified lack of remnant native habitats within the PAA.

8.3.3 Field Investigations

Detailed biodiversity surveys were not considered to be required due to the extensive disturbance and agricultural history of the PAA. EPS inspected the PAA to confirm the existing condition and be able to make further comment on potential threatened species and ecological communities. During the Planning Focus meeting in February 2016 the existing highly disturbed nature of the PAA was recognised by OEH.

8.3.4 Existing Environment

Flora and Vegetation Description

The entire PAA is situated on working agricultural lands. No intact native remnant vegetation communities are present on the PAA. The majority of the site is occupied by cropping land, which is also grazed by sheep and cattle at certain times as shown in Plate 1.

The only area of the PAA that contained any semblance of native vegetation was in a small area at the northern edge of the PAA, as shown in Plate 2 and Plate 3. It cannot be certain whether these trees were planted or have regrown naturally. Up to ten Weeping Myall (Acacia pendula) occurred in this area, with the understorey being a completely modified agricultural environment as shown below.

The water supply canals and drainage channels occurred outside of the PAA but did not contain any intact remnant native vegetation. A photo of a typical canal next to the PAA is shown in Plate 4. The vegetation along the canal and drainage channels was dominated by exotic vegetation.

No threatened flora species were observed or considered likely to occur due to the high level of disturbance and weed invasion, and due to the absence of natural topsoil that would otherwise potentially provide a native seedbank.

ENVIRONMENTAL PROPERTY SERVICES February 2016 - Page 51 Legend:

Riverina Solar Project Application Area

5 Locality

#* Diamond Firetail ") ") #* Australasian Bittern #* Yenda Black Falcon 5 )" Grey Falcon Grey-crowned Babbler Tharbogang Beelbangera )" 5 5 (eastern subspecies)

)" 5 Little Eagle *# %, ") Major Mitchell's Cockatoo ") Painted Honeyeater Bilbul 5 Pied Honeyeater 1 6 ") %,%, %, Locality With Multiple Sightings *# (Refer to Table Below) ") GRIFFITH CITY 5 Table of Multiple Sightings Locality No. of Species 2 No. Sightings %, Burley Griffin Way Yoogali Ross Road 1 Little Eagle 1 5 Hooded Robin 1

2 Australasian Bittern 1 Black Falcon 1 Irrigation Way Kurrajong Road 3 Superb Parrot 1 Hamilton Road Painted Honeyeater 1

4 Pied Honeyeater 3 Painted Honeyeater 2 Mirool Creek 4 %, 5 Blue-billed Duck 1 Freckled Duck 1 Hanwood Widgelli*# 3 5 5%, Little Eagle 5 Barking Owl 1 Brown Treecreeper 3 Painted Honeyeater 1 Grey-crowned Babbler 5 Hooded Robin 1

6 Little Eagle 12 Black Falcon 1 Brown Treecreeper 15 Grey-crowned Babbler 19 Hooded Robin 9

Author: K. Lee Figure 8-1 THREATENED SPECIES RECORDS Reviewer: S. Duffy ´ 0 600 1,200 2,400 3,600 A3 Scale: 1:65,000 Metres Riverina Solar Project | Griffith, NSW, Australia ©Aerial imagery supplied by NearMap under Licence Job Ref: 11234 DCDB supplied by Land & Property Information 2016 26 February 2016 ENVIRONMENTAL PROPERTY SERVICES Legend: Riverina Solar Project INSET Application Area Belah Woodland on alluvial plains and low rises in the central NSW wheatbelt to Pilliga and Liverpool Plains regions Black Box - Lignum woodland wetland of the inner floodplains in the semi-arid (warm) climate zone Black Box grassy open woodland wetland of rarely flooded depressions in south western NSW Common Reed - Bushy Groundsel aquatic tall reedland grassland wetland of inland river systems Cumbungi rushland wetland of shallow semi-permanent water bodies and inland watercourses Currawang very tall shrubland on siliceous rocky ridges and cliffs mainly in the NSW South Western Slopes Bioregion Derived mixed shrubland on loamy-clay soils in the Cobar Peneplain Bioregion Yenda (! Weeping Myall open woodland of the Riverina and NSW South-western Slopes Bioregions Tharbogang Beelbangera Native grassland complex (! (! Planted woody vegetation

Sandplain mallee of central NSW Swamp Complex Dwyers Red Gum - White Cypress Pine - Currawang Bilbul shrubby woodland mainly in the NSW South Western (! Slopes Bioregion Western Grey Box - Poplar Box - White Cypress Pine tall woodland on red loams mainly of the eastern Cobar Peneplain Bioregion GRIFFITH CITY White Cypress Pine woodland on hills in the eastern (! Riverina to western NSW SW Slopes Bioregions Yarran shrubland of the NSW central to northern slopes and plains Yoogali (! SEE INSET

Hanwood Widgelli (! (!

Author: K. Lee Figure 8-2 MAPPED REMNANT VEGETATION Reviewer: S. Duffy ´ (Source: Griffith City Council) 0 750 1,500 3,000 4,500 A3 Scale: 1:75,000 Metres Riverina Solar Project | Griffith, NSW, Australia ©Aerial imagery supplied by NearMap under Licence Job Ref: 11234 DCDB supplied by Land & Property Information 2016 26 February 2016 ENVIRONMENTAL PROPERTY SERVICES

Plate 1: Typical representation of cropping lands which comprise the majority of the PAA

Plate 2: Small number of trees at northern end of PAA

Plate 3: Small number of trees at northern end of PAA

Plate 4: Adjoining water supply canal

Habitats and Connectivity

Habitat quality is generally poor. A majority of the PAA supports intensive agriculture, which provides virtually no significant habitat for native flora and fauna species. The few trees that do exist provide minor habitat for common native and introduced birds.

No significant habitat features such as tree hollows, rocky areas, native structural layers of vegetation or wetland / riparian environs were present. The native landscape plantings provided habitat for an assemblage of common native birds and potential habitat for a range of other native fauna. This included thick grass and exotic understorey and some minor occurrences of occasional small logs and leaf litter outside of the PPA allotment boundaries. Highly mobile native species such as Microchiropteran bats could potentially forage in this area, although this habitat would be of low importance due to its isolation and simplistic nature.

The adjoining water supply canals are generally isolated from any natural environments, being within an intensive agricultural area. No connectivity exists to any substantive areas of natural habitats.

No groundwater dependent ecosystems are present within the site.

No threatened fish under the Fisheries Management Act 1994 have suitable habitat on the site.

The site does not provide suitable habitat for species requiring special consideration such as the Koala.

Fauna

Due to the highly disturbed nature of the site, extensive fauna surveys were not considered to be required.

It is unlikely that the site contains any important habitat for threated species listed under the EPBC Act, TSC Act or FM Act.

8.3.5 Impacts

Threatened Flora Species

No detailed impact assessments were completed for any threatened flora species as no suitable habitat was present for threatened flora, and none were recorded. None were recorded within the 10km radius Wildlife Atlas Database search. No further assessment is required under the TSC Act or EPBC Act.

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Threatened Ecological Communities

The only area containing scattered native trees (planted or remnant) was the small pocket (0.13ha) at the northern end of the site, as previously described. This area did not display any affinities to naturally occurring threatened ecological communities. While a small number of Weeping Myall (Acacia pendula) trees existed, larger areas of this species occur throughout the locality along roadsides and other private properties and it is considered that the removal of this small number of trees (<10) for the project would not be likely to result in any significant impacts.

From a State perspective, as a precaution, a seven part test has been completed in relation to potential impacts of the project to the Endangered Ecological Community “Myall Woodland in the Darling Riverine Plains, Brigalow Belt South, Cobar Peneplain, Murray-Darling Depression, Riverina and NSW South Western Slopes bioregions”. Refer to Appendix 8. The seven part test concluded that a significant impact was unlikely to occur.

From a Commonwealth perspective, the small patch would not be classified as the Weeping Myall Woodlands endangered community as it is much less than the required 0.5ha minimum area and is highly disturbed.

The remainder of the PAA is subject to intensive agriculture and does not contain any remnant native vegetation.

No further assessment is required under the TSC Act or EPBC Act. A Species Impact Statement or EPBC Referral should not be required for the project.

Fauna

No threatened fauna species have been subject to detailed impact assessments under the TSC Act or EPBC Act due to the absence of any habitat that could be considered to be important for threatened fauna.

The NSW Department of Primary Industries threatened & protected species records viewer showed a record of the Southern Pygmy Perth (Nannoperca australis) from 1976 in Mirrool Creek, which is 28 km to the north west of the PAA. Suitable habitat for this species is not considered to exist within the PAA. Suitable habitat is not considered to exist for other threatened fish within the PAA.

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8.3.6 Mitigation Measures

The previous information forms all of Stage 1 and the first part of Stage 2 of the required FBA process. Stage 2 also requires consideration of avoidance of direct and indirect impacts to biodiversity and where such impacts cannot be avoided or minimised, biodiversity offsetting to be implemented.

The avoidance and minimisation of direct and indirect impacts to biodiversity for the Project is not strictly warranted, due to the absence of any remnant native vegetation or important habitats on the site.

As the Project will not impact upon any native vegetation communities, the FBA indicates in Section 9.4 and 9.5 that an offset is not required to be determined or provided. No offsets are proposed to be provided for the Project and as such “Stage 3 - Biodiversity Offset Strategy” of the FBA process is not required to be enacted.

No specific biodiversity mitigation measures are proposed, although the water management mitigation measures outlined in Section 8.5 will provide protection for downstream environments.

Also, screening vegetation is proposed to occur alongside the project to screen views from surrounding areas. This is likely to result in a net increase in refuge habitat for native fauna in the immediate locality post-construction.

In addition, existing roadside Weeping Myall individual trees will be retained wherever possible.

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8.4 Soils and Salinity

8.4.1 Existing Environment

Surface samples from the Project site exhibit a topsoil texture of silty light clay and are described locally as grey loams over clays. Bore logs for the two nearest groundwater monitoring bores, some 500 m from the site, describe surface soils as sandy loam and clay loam. These varying descriptions are expected as the site is on the boundary of lighter soils generally used for horticulture and viticulture, and the heavier soils generally used for rice and other broad-acre crops. Figure 3-3: Key ConstraintsFigure 3-3 shows these general land uses, which are generally aligned with soil type.

Parts of the MIA have been affected by irrigation-induced salinity since the 1940s. Salinity is essentially caused by an imbalance of water application (or rainfall) and water use by vegetation. Increased soil moisture at depth has the effect of leaching out natural salts within the profile and capillary action can bring this salt higher and so harm or kill plants. A very obvious sign of irrigation or dryland salinity is the presence of salt scalds in lower areas, where saline groundwater seeps out. There are no such salt scalds in the Project site or immediately adjacent areas, although they have been observed some 8 km from the site, east of Widgelli alongside Mirrool Creek.

8.4.2 Impacts

The potential for the Project to exacerbate soil erosion is addressed in Section 8.5 while this section addresses the potential impacts of the Project on soil physical and chemical attributes.

Agricultural soils are commonly detrimentally affected by compaction, acidification, structural decline, loss of organic matter and fertility, and salinity. These can due to a combination of factors such as removal of native vegetation, cultivation, the type of crop or pasture grown, irrigation and specific farming practices.

The site soils are understood to be in good condition, with none of the listed impacts reported. Nonetheless, it is likely that when compared to native soils in their pre-farming condition, that there have been changes due to irrigation and cultivation.

The Project will involve minimal short term construction, followed by several decades of low intensity grazing of permanent pasture. Construction is not expected to impact the soils any more than regular farming machinery movements (cultivation, weed spraying, harvesting etc). The proposed decades of minimal machinery usage on the site and the long term effect of permanent pasture on soil structure, organic content and fertility, is expected to be beneficial for the soils.

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The issue of dryland and irrigation-induced salinity is a major one for Australia. Many agricultural areas of Western Australia, NSW and Victoria are affected. The Project area is not known to be affected by salinity. Given that the Project will not require regular irrigation and that the planned permanent pasture will consume soil moisture year round (the rate depending on water availability and species selection), it is reasonable to conclude that the Project would have a net beneficial effect on any incipient salinity issues in the area, as it will tend to reduce deeper soil moisture levels, when compared to irrigation farming systems.

8.4.3 Mitigation Measures

No specific mitigation measures are required.

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8.5 Surface Water and Erosion

8.5.1 Existing Environment

The site is on flat land that is part of the Mirrool Creek floodplain, the channel of which is approximately two kilometres south of the site. The region is within the Mirrool Irrigation Area, a part of the MIA, supplied by waters stored in Burrinjuck Dam, 250 km away near Yass. Surface flows in the Mirrool Irrigation Area are to a large extent controlled by a series of main drains and Figure 8-3 shows the major natural and artificial water supply canals and drains.

The site naturally drains generally south southeast towards Mirrool Creek, although several of the paddocks have been laser levelled and runoff is intercepted by the artificial drainage network parallel with Mirrool Creek Branch Canal.

No erosion was noted on the site, although minor wind erosion and water erosion could be expected from time to time. The potential for wind or water erosion is very much reduced by the double cropping practices that provide crop or stubble cover for most of the year. Additionally, the irrigation bays act and perimeter banks to retain any eroded sediment, so that none would flow off the site, expect in very major storm events.

8.5.2 Impacts

Hydrology and Erosion

The internal irrigation bay dividing bunds will be removed and minor grading undertaken to facilitate drainage. The PV panels could theoretically could increase runoff rates, however, given that rain will run off each panel directly onto the ground below, this is not necessarily the case. Research by Cook and McCuen (2013) modelled this potential effect and found that solar panels did not have a significant effect on runoff volumes, peaks, or times to peak, if vegetative groundcover under the panels was maintained. They also found that peak discharges could increase significantly if the ground under the panels was bare or gravelled, and that the increased erosive force of drips off the panels could cause erosion at the dripline.

This finding is not surprising as the infiltration capacity of most vegetated soils is relatively high, but many bare soils or those compacted by construction machinery have relatively low infiltration rates. Cook and McCuen’s main recommendation is that the grass underneath the panels be maintained or that a vegetated buffer strip is grown downslope of each row of panels.

The Project design includes the growth of short pasture underneath the panel arrays, and has the following features and procedures that will minimise erosion:

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• During construction, access paths for equipment will not be routinely gravelled, although main access tracks will be permanently gravelled; • Rows of PV panels will be separated from the next row, so providing an infiltration area and sunlight to pasture; • The ground under and adjacent the PV panels will be sown with a permanent pasture mix, suitable to the region and long term stock grazing; and • The Project area will be controlled grazed (most likely with sheep) to maintain ground cover density and manage the sward length.

With these design controls and procedures, the Project is not expected to measurably increase peak runoff rates or long term runoff yields, nor is it expected to erode the soils at the dripline of the panels. The Project will lead to a long term vegetative cover of what is now a rotational cropping area, and so will reduce the potential for erosion.

Licensing

The Project will require water for construction (mostly for dust suppression) and during operational maintenance (PV panel washdown). Construction water will be sourced from the adjacent water supply canals. Suntech will purchase water rights for the use of stored water supplied by the MIA network.

PV panels collect dust and require occasional washdown to maintain performance. Irrigation water has suspended fine clays that would dry as a dusty film on the panels and so is not suitable for this purpose. Panel washdown will require clean water, which will be sourced from town supplies.

Given that in most years, irrigators receive an allocation that is only a fraction of the total water licence, forgoing regular irrigation of the Project site will simply mean that the landholders will water other paddocks. There will be no effect on licensing for the landholders.

Landholder and Harvestable Rights

Basic landholder water rights and harvestable rights will not be affected by the Project as no water harvesting or water use from natural creeks is proposed.

8.5.3 Mitigation Measures

The following mitigation measures will be implemented:

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• The ground under and adjacent the PV panels will be sown with a permanent pasture mix, suitable to the region and long term stock grazing; and • The Project area will be controlled grazed to maintain ground cover density and manage the sward length.

Given that the Project will reduce the erosion risk (which is already low), no further mitigation measures or management plans are required.

ENVIRONMENTAL PROPERTY SERVICES February 2016 - Page 63 Legend: Riverina Solar Project Application Area

Yoogali Irrigation Supply Canal Yoogali Irrigation Drain Mackay Avenue

Burley Griffin Way

Yanco Griffith RailwayMain Drain J Ross Road

Pavese Road

Clark Lane

Kurrajong Road

Main Drain J Hamilton Road

Irrigation Way

Mirrool Creek Branch Canal

Bob Irvin Road

Author: K. Lee Figure 8-3 IRRIGATION SUPPLY CANALS AND DRAINS Reviewer: S. Duffy ´ 0 200 400 800 1,200 A3 Scale: 1:20,000 Metres Riverina Solar Project | Griffith, NSW, Australia ©Aerial imagery supplied by NearMap under Licence Job Ref: 11234 DCDB supplied by Land & Property Information 2016 26 February 2016 ENVIRONMENTAL PROPERTY SERVICES

8.6 Flooding

8.6.1 Existing Environment

The site is located on the Mirrool Creek floodplain, the channel of which is approximately two kilometres south of the site. The site is within the MIA and as part of the development of the system, several large drains were constructed along with irrigation supply channels. The nearest major drainage channel to the site is Main Drain J, while a series of irrigation water supply channels also occur near the site. Figure 8-3 shows the key natural and artificial water supply canals and drainage channels.

Given that the site and much of the area is on a floodplain, numerous floods have been recorded since the establishment of the MIA. Flood prone land can be defined as that which is susceptible to flooding by either the 1% annual exceedance probability levels (1% AEP) or the probable maximum flood (PMF). The 1% AEP level is equivalent to a 1 in 100 year flood level, while the PMF is the largest flood that could conceivably occur at a particular location and is estimated from probable maximum precipitation coupled with the worst flood-producing catchment conditions.

The Griffith Flood Liable Lands Policy (CS-CP-403) dated 2013, applies to all lands in the Griffith LGA that are affected by floods up to PMF. The policy sets the minimum residential floor level at 100 year ARI plus 500 mm. The site is above the Griffith Council Flood Planning Level for 1 in 100 year floods, although it may be subject to localised or exceptional flooding. The site is not identified as flood prone land in accordance with the Flood Prone Land Map (Map 11) included in the ‘Griffith Land Use Strategy – Beyond 2030’.

Local floods in March 2012 were the largest recorded in the catchment, with rain measured in the catchment equivalent to 0.1% AEP (BT WBM 2014). The Main Drain J catchment, in which the site is located, experienced partial flooding. Consequently Council commissioned a flood study in response to the 2012 flood, and simulations in that study show that the western part of the Project site would not be affected by a 2012 flood event (considerably higher than 1 in 100 years), allowing for flooding from both the Main Drain J and Mirrool Creek catchment (BT WBM 2014).

BT WBM (2014) simulations of the 0.1% AEP flood indicate minor flooding in parts of the eastern Project area up to 10 cm deep.

BT WBM (2014) also modelled a range of floods at a number of locations in the Griffith area, the nearest modelling location being Main Drain J at Yoogali, approximately 2 km from the Project site. The predicted PMF, at Main Drain J at Yoogali has an estimated elevation of 125.1 mAHD, an estimated velocity of 1.3 m/s and an estimated flood volume of 3250 ML/day. For the same parameters for 1% AEP flood, BT WBM (2014) estimated 124.7 mAHD, 1.3 m/s and 2380 ML/day.

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The nearest permanent marks to the site with established height (SSM 16145) is immediately adjacent to the PAA along Irrigation Way, has an elevation of 126.576 mAHD, well above the 1% AEP and PMF estimate.

BT WBM (2014) adopted the following hydraulic categories:

• Floodway: Velocity Depth > 0.1 at the 1% AEP event • Flood Storage: Velocity Depth < 0.1 and Depth > 0.3 at the 1% AEP event • Flood Fringe: Lateral extent of the 1% AEP event

Based on modelling at Main Drain J Yoogali, BT WBM (2014), defined the western section of the Project site as none of these categories, with parts of the eastern section being flood fringe with low hazard. The Main Drain J flood mapping for High Flood Hazard and Low Flood Hazard areas are illustrated on Figure 3-3.

8.6.2 Impact

In 2005 the NSW Government introduced the Floodplain Development Manual to better manage flood liable land by a process of setting flood planning levels for certain developments on urban and rural floodplains throughout NSW. The overall policy is: The primary objective of the policy is to reduce the impact of flooding and flood liability on individual owners and occupiers of flood prone property, and to reduce private and public losses resulting from floods. The policy recognises that “floodprone land is a valuable resource that should not be sterilised by unnecessarily precluding its development.”

The Manual notes that flood planning levels for dwellings would normally be set to 1% AEP plus 0.5 m freeboard. While flood studies show that the Project site would not be affected by a 1% AEP flood, the general objectives of the Manual are relevant. Previous assessments show that the site is on a floodplain and is subject to regional flooding in extreme events, but is in a low risk flood area, due to the shallow depth of flooding and low velocities of flood water. Nonetheless, it is reasonable to consider how extreme floods might be affected by the Project, and how this might consequently affect flood behaviour.

While most flood behavioural changes in floodplains are due to catchment-wide land use changes, or extensive earthworks, smaller structures in floodplains can and have detrimentally concentrated flood flows and caused consequent erosion or damage to infrastructure. The relevant Project elements with regards to the potential to trap debris and so back-up or deflect flows are fencing, panel support poles and sheds.

The existing fences are standard ringlock and barbed wire stock fences, supported by steel posts and wooden poles and strainers. This type of fence can trap finer debris such as grass and stubble,

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and so divert flood flows, but as even the 0.1% AEP level is only an estimated 10 cm, the potential to divert floods or topple fences is limited. The site will maintain the use of rural type fencing, which is not predicted to cause additional potential impacts.

The panel support poles are well spaced, and along with the array tracking assemblies, are very unlikely to retain debris that might damage the poles themselves, redirect flood flows or cause floodwaters to back up, particularly as flood debris in this area can be expected to be relatively fine, consisting mostly of grass, stubble and similarly fine debris. Similarly, the isolated sheds to be used to house equipment would not provide significant flood stoppages. Where electrical equipment is installed in shipping containers, these will be located outside of the 0.1% AEP zone or anchored to prevent floating. The PV panels and sensitive electricals will be placed on poles well out of even PMF levels as the predicted PMF levels are well below the panel footing level.

Any trenches dug for transmission lines will be backfilled and compacted to ensure no windrows remain that might divert surface flows.

The Project would be located on a floodplain, but as the Project would not modify flood behaviours and nor would it involve an intensification of population various specific aspects of the Manual are not triggered, such as asset management, flood education, emergency response or indemnities.

8.6.3 Mitigation Measures

Apart from backfilling and compacting trenches, no specific flood mitigation measures will be required.

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8.7 Groundwater

8.7.1 Existing Environment

The Griffith LEP 2014 ‘Groundwater Vulnerability’ Maps do not identify the site within a groundwater vulnerability area. The Project site has no groundwater bores but the NSW Office of Water database shows two registered bores close to the site (GW405751 and GW405897). The logs relevant to these bores show that they are both monitoring bores accessing shallow groundwater (between 14 and 34 m below ground level). The landholder reports that groundwater under the Project site tends to be around 6 m below ground level.

8.7.2 Impact

The project will not extract groundwater and the very minor excavations involved with panel installation and trenching for electrical services are not expected to intercept groundwater. The potential for groundwater contamination is limited as when the Project is operational, only small amounts of fuels, lubricants or chemicals would be stored on site.

There is a minimal risk of hydrocarbon spills during construction, and site plant will be filled by mini-tankers to avoid the need to store fuel. A small volume of oils and lubricants will be stored in a locked and bunded facility during construction.

8.7.3 Mitigation Measures

Diesel fuel will not be stored on site during construction or operation. Oils and lubricants used during construction will be kept in a bunded and secured store.

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8.8 Greenhouse Gas

8.8.1 Impacts

To assess the greenhouse impact of the Project, an inventory of greenhouse gases (GHG) produced by the construction and operation of the facility is required. This inventory can then be compared against any greenhouse positive aspects of the Project or compared to the degree of GHG offsetting.

Wright and Hearps (2010) considered the lifecycle emissions of various electricity generating technologies. Most of electricity that supplies the NEM is produced by large coal-fired thermal power stations, without carbon capture and disposal, facilities which are estimated to have lifecycle GHG emissions of between 800 to 1000 gC02e/kWh. Wright and Hearps’ estimate solar

PV installations to have lifecycle emissions of 19 to 59 gC02e/kWh.

Lenzen (2008) provides similar estimates, with black coal power stations reported to have average

GHG emissions of 941 gC02e/kWh and PV facilities generating 106 gC02e/kWh.

In other words, solar PV facilities can produce electricity with between 10 and 42 times lower GHG emissions per kWh of electricity produced when compared to traditional coal-fired thermal power stations.

To better understand the GHG implications of the Project, the energy yield ratio is required. This is simply the ratio of energy used to manufacture, install, operate and decommission the facility against the amount of energy it produces in its lifetime. Mackay (2009) estimates the energy yield ratio of similar PV plants to be over 7. In other words, the plant will produce 7 times more energy than it consumes over its lifetime.

By contrast, a coal-fired power station consumes a fossil fuel that is converted to heat energy, which boils water to produce steam, which drives turbines that transform this energy into mechanical energy, which in turn spin generators that transform this into electrical energy. All the various transformative steps have efficiency losses, which means that a fossil fuel driven power station can only ever produce a fraction of the embedded energy that fuels it. The Australian Institute of Energy (http://www.aie.org.au/AIE/Energy_Info/Power_Station_Efficiency.aspx) estimates that Australia’s coal-fired power stations operate at an average efficiency of 33%. The National Greenhouse Account Factors 2015 (Table 41) estimate the GHG emissions of an NEM purchased electricity at 0.96 kg C02e/kWh produced, based on the full fuel cycle.

The Project will produce an estimated 2 MkWh over its lifetime. If this electricity was produced by a coal-fired power station, an estimated 1.44 MtC02e would be liberated to add to the

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greenhouse effect and consequently exacerbate global warming. Allowing for the greenhouse gases liberated by the manufacture, installation and demolition of the Project, only 72,000 tC02e would be produced, saving approximately 1.8 MtC02e.

8.8.2 Mitigation Measures

The Project itself is a very significant mitigation measure, which will save the release of approximately 1.8 MtC02e over its lifetime. Other measurable GHG mitigation measures to be undertaken are:

 Selecting the most efficient PV components and Project design to maximizes electricity production;  Updating components as they become obsolete or are superseded by more efficient technologies; and  Washing panels occasionally to maximize solar collection.

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8.9 Noise

8.9.1 Existing Environment

The Project site is rural and has an assumed background noise level of 30 dB(A).

8.9.2 Impact

Construction

The NSW Department of Environment, Climate Change and Water released the Interim Construction Noise Guideline in 2009 (ICNG).

The ICNG recommends maximum levels for construction noise at noise sensitive locations based on the rating background level (RBL), as defined in the NSW Industrial Noise Policy, 2009. For construction longer than three weeks, the ICNG provides the following recommended management Levels:

 RBL plus 10 dBA Leq, 15 min for works in standard hours (Monday to Friday 7am to 6pm and Saturday 8am to 1pm); and  RBL plus 5 dBA Leq, 15 min outside standard hours.

The ICNG provides a highly noise affected limit of 75 dB(A).

Expected construction equipment and their sound power levels (SWL) are provided in Table 8-1.

Table 8-1: Equipment SWL Item Function SWL dB(A) Rough terrain crane Lifting panels, parts, conductors, poles. 105 Backhoe Trenching, track maintenance, aggregate spreading. 101 Rigid tipper Aggregate supply (if needed). 102 Concrete agitator truck Concrete supply. 109 Skidsteer loader Pile installation, general materials handling. 105 Small piling rig or excavator Pile installation. 114 with hammer Diesel generator Electricity supply 100 Hand power tools General construction 109

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While all the equipment listed in Table 8-1 would most likely not be operated at the same time, assuming that it does, provides a conservative impact assessment. Accordingly, the total SWL of all the equipment if it were used together is 117 dB(A).

The nearest non-Project residence is approximately 150 m from the Project site. Allowing for distance to the receiver, a semi-quantitative prediction of noise from construction would be approximately 65 dB(A), which is significantly more than the ICNG criteria for either standard or non-standard hours, but is below the highly noise affected limit of 75 dB(A).

The predicted construction noise should be considered against the background of existing land uses on the site and adjacent areas. Specifically the area supports broad acre and semi-intensive agriculture, with significant noise producing activities year round, including:

• Ground preparation (ploughing, rolling); • Cereal sowing, harvesting, stubble baling, stubble burning, spraying. Some of these activities, especially grain harvesting, can occur throughout the day or night); • Grape harvesting and transport (generally at night); and • Citrus transport.

Given the existing land uses and associated noise environment, it is not expected that predicted construction noise will cause community concern. A draft Noise Management Plan has been prepared (see Appendix 9) and will be completed in consultation with Griffith City Council and local residents.

Construction Traffic Noise

Section 8.12 provides details of predicted heavy vehicle traffic due to the Project. A conservative prediction, assuming that the maximum rate of both container and aggregate deliveries occur on the say day, would see 46 additional heavy vehicle movements per day. For the arterial roads (Irrigation Way and Burley Griffin Way), the Project heavy traffic will contribute up to 46 additional traffic movements and 3.2% of total flows respectively. It is not expected that these minor additions, based on conservative estimates, will generate noticeable additional noise.

The Project may generate significant additional heavy traffic for the construction period on either Ross or Hamilton Roads compared to current heavy vehicle traffic. Both roads have houses within 40 m of the roadway and so Project heavy vehicles would be audible at these residences.

The NSW Road Noise Policy (2011) provides guidance and limits to manage road noise in NSW. The Policy defines the residential daytime criteria for existing residence on arterial roads with respect to additional traffic to be LAeq, (15 hour) 60 (external). The Policy notes that “For isolated residences in industrial or commercial zones, the external ambient noise levels can be higher than

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those in residential areas”. The Policy does not provide specific guidance for rural residences apart from suggesting that research “suggests that noise assessment criteria for areas of higher existing background noise typical of urban/suburban settings, and areas of lower existing background noise typical of rural settings, should remain consistent”.

It is not expected that road traffic noise due to the Project heavy vehicles will exceed LAeq, (15 hour) 60 (external).

8.9.3 Mitigation Measures

A draft Noise Management Plan is provided in Appendix 9 and will be completed in consultation with Griffith City Council and local residents.

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8.10 Aboriginal and Cultural Heritage

An Aboriginal Heritage Due Diligence Report has been prepared by RPS (2016) and is provided in full in Appendix 10. Below is summary of the key findings.

8.10.1 Existing Environment

A review of the environmental background reveals that the area was suitable for Aboriginal occupation and likely occurred along the edges of permanent watercourses such as Mirrool Creek and the Murrumbidgee River, and their associated drainage lines. Extensive modern disturbances of the land through farming practices and agricultural crops suggest there is low potential for artefacts to be located in situ. The majority of the Project Area has been disturbed over many decades through various landuses, including the current irrigated agricultural cropping use.

The Project Area is within the southern boundaries of the territory of the Wiradjuri tribal and linguistic group (Tindale 1974). A search of the Aboriginal Heritage Management Information System (AHIMS) was conducted on 17 February 2016 for the Project Area (refer Appendix 10). This search revealed that no previously registered Aboriginal sites or objects were located within the Project Area.

A review of the site data from previous archaeological works in the locality, indicate a low potential for surface artefacts and a low potential for subsurface Aboriginal objects due to the long periods of natural and historic disturbances and land modifications. Potential Archaeological Deposits (PADs) are not likely to be located within the Project Area as they are generally only located on undisturbed land.

A visual inspection of the Project Area was undertaken by foot on 17 February 2016, by EPS personnel, Simon Duffy, Alina Tipper and Richard Finlay-Jones and, Griffith Local Aboriginal Land Council representative Max Harris. Four new sites were identified within the Project Area:

• Site 1: one silcrete core; • Site 2: one millstone; • Site 3: artefact scatter of two silcrete flakes; and • Site 4: artefact scatter of one quartz vein pebble flake and one milky quartz flake.

8.10.2 Impact

Vehicle movements and the installation of solar panels have the potential to impact the four identified Aboriginal Sites.

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8.10.3 Mitigation Measures

In order to mitigate the impacts on the identified artefacts, the following mitigation measures are proposed:

• The four identified artefacts will be subject to surface salvage (collection) under an approved development consent for the project (SSD16_7482); • All staff and contractors accessing the site will be made aware of their statutory obligations for heritage under the National Parks and Wildlife Act 1974 and the Heritage Act 1977 as part of the site induction; • If unrecorded Aboriginal object/s are identified in the Project Area during works, then all works in the immediate area must cease and the area should be cordoned off. OEH must be notified by ringing the Enviroline 131 555 so that the site can be adequately assessed and managed; and • In the unlikely event that skeletal remains are identified, work must cease immediately in the vicinity of the remains and the area must be cordoned off. The proponent must contact the local NSW Police who will make an initial assessment as to whether the remains are part of a crime scene or possible Aboriginal remains. If the remains are thought to be Aboriginal, OEH must be contacted by ringing the Enviroline 131 555. An OEH officer will determine if the remains are Aboriginal or not; and a management plan must be developed in consultation with the relevant Aboriginal stakeholders before works recommence.

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8.11 Bushfire

8.11.1 Existing Environment

Due to the lack of woody vegetation in and adjacent to the PAA, it is not within a bushfire area per se. However, due to the inherent combustibility of dry pastures and crop stubble, combined with potential ignition sources such as stubble burning, cigarettes thrown from passing car, and short circuiting electrical equipment, there is a risk of ground cover fires.

8.11.2 Impact

Fires that might spread to the facility would cause significant damage to wiring, panels and other components. Conversely, fires ignited on site, could spread to neighbouring crops and infrastructure.

To prevent the incursion of stubble or grass fires onto the PAA, the perimeter track will be maintained as a firebreak. Ongoing, long-term liaison with adjacent landholders should ensure that the Project site is staffed during neighbouring stubble burns.

Fires due to household solar systems have occurred throughout Australia and are reported to be mainly due to faulty inverters or isolating switches. Commercial components used in large scale plants such as the Project, are of infinitely higher quality than lower cost household systems and are equipped with thermal overload cut outs. In any event, the SCADA system will monitor performance of, and faults in, key components. Nonetheless to reduce the risk of a fire spreading through and off the site, the pasture under the panels will be grazed and the perimeter firebreak maintained.

8.11.3 Mitigation Measures

The following mitigation measures will be further considered in the site EMP and implemented:

• Installation of only Australian Standard compliant components; • Installation and management of SCADA system to monitor system performance; • Installation of thermal overload protection on inverters; • Controlled grazing of pastures under panel arrays; and • Maintenance of perimeter firebreak.

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8.12 Traffic and Transport

8.12.1 Existing Environment

Figure 3-1 shows the main transport links to and around the site. Irrigation Way (also known as Griffith Road) is adjacent to the western edge of the PAA and is an approved Restricted Access Vehicle (RAV) route for B doubles up to 26 m long. Burley Griffin Way to the north of the PAA provides similar access. These highways provide unbroken B Double access from Griffith, Port Botany, Port Kembla, and Port Melbourne.

Figure 3-1 shows the location of Hamilton Road and Ross Road, that both lead to the Project site.

The single line Yanco-Griffith Railway Line is located adjacent to the site, and the Yoogali East Station, which was closed in 1975, is close to the TransGrid sub-station. The site is approximately 655 km by rail from Sydney.

The Yanco-Griffith Railway Line remains open to freight trains and provides a potential access for the facility components. There is a Patricks’ rail facility adjacent to Griffith Railway Station on a spur line that can hold up to a 500m long train set. This is a container and break bulk facility only and can store up to approximately 300 40 foot containers. A new Western Riverina Intermodal Facility at Wumbulgal, approximately 13 km from the Project site is a bulk terminal only, built for agricultural commodities such as grain, cotton etc. It is not suitable for shipping containers.

The Griffith City Council Heavy Vehicle Strategy (2013) notes that the “area generates in excess of 250,000 tonnes of road freight annually, in addition to this a further 36,000 containers of produce are transported to and from the Patrick Port Logistics Freight Terminal situated in Griffith’s Central Business District. The transport industry has been investing heavily in developing measures to combat the increasing running costs of heavy vehicles, the decreasing numbers of transport operators across Australia, increase heavy vehicle access and transport efficiency throughout Griffith.”

Griffith City Council has conducted recent traffic counts in the area and the data relevant to the Project are as follows:

• Irrigation Way adjacent to the TransGrid Substation, 1,434 AADT both ways; • Mackay Avenue near Burley Griffin Way intersection 5,404 AADT both ways; • Burley Griffin Way adjacent to Yoogali, 4,491 AADT both ways; • Burley Griffin Way adjacent to Ross Road, 3,217 AADT both ways; and • Hamilton Road near the TransGrid substation, 181 AADT both ways.

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There is no data available for Ross Road. Griffith City Council (Mathew Vitucci pers comm 23/2/2016) noted that on the arterial roads, the heavy traffic contribution was approximately 20% of AADT.

8.12.2 Impact

The component delivery route and method remains undecided. The feasible main trucking options are:

• Components shipped to Port Botany or Port Kembla and trucked direct to site via the Hume Motorway, Burley Griffith Way and Irrigation Way; or • Components shipped to Port Melbourne and trucked direct to site via the Hume Freeway, Goulburn Valley Highway, Newell Highway, Kidman Way, Burley Griffin Way and Irrigation Way.

Rail provides a feasible container delivery option and is the preferred delivery method. The Yooglai East railway station is adjacent to the Project site but does not have a siding or laydown area, so is not suitable for offloading or storage of offloaded shipping containers. However, it is feasible to offload containers at Patricks’ Griffith facility, which has a separate siding and hardstand. Containers could then be trucked direct to the site. This preferred option is assessed.

The Project components will be imported in approximately 285 standard 40 foot shipping containers. Numerically, most containers will hold PV panels, followed by the mounting systems, followed by the balance of system parts.

It is unworkable to have 285 containers stored at a construction site or in transit when they are not all needed at once. Accordingly, the containers will be railed from port (most likely Port Botany) in consignments over a 27 week period. The containers will be offloaded at Patricks’ rail facility at scheduled intervals. Given the limited storage space at the Patricks railhead, the offloaded containers will be trucked to the site in batches on flatbed semi-trailers with container twist locks.

The stop sign at the level rail crossing on Hamilton Road means that a turn from Irrigation Way would entail standard length semi-trailers partially blocking the highway when stopping. As this is not an acceptable situation, the two following options are currently being discussed with Griffith City Council:

1. Provide a left turn entry for container trucks from Patricks via Mackay Avenue, Irrigation Way and onto Hamilton Road via a temporary turning lane built adjacent to the railway. This would enable trucks to stop at the level crossing without blocking the highway.

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2. Deliver containers from Patricks via Mackay Avenue, Burley Griffin Way and Ross Road return via the same route, or onto Hamilton Road and Irrigation Way.

Option 1 provides a possible access, but there are some doubts about the adequacy of the swept path of the tight proposed turn. Additionally, construction and operation in what is a live rail corridor might be problematic.

Option 2 is favoured as it provides protected left turns from Mackay Avenue, left onto Burley Griffin Way. From here there is a simple at-grade right turn into the unsealed Ross Road. While there is no right turn bay, sight distances are excellent for this 100 km/h posted section of the highway. The excellent site distances at the Ross Road-Burley Griffin Way intersection allow safe left turns for returning empty trucks. Similarly, a return route for empty trucks along Hamilton Road exiting onto Irrigation Way provides excellent site distances. This route passes through a 40 km/h school zone adjacent to the Yoogali Public School, but that school is located alongside Burley Griffin Way, with its existing heavy vehicle flows.

Analysis of the container receipt requirements, based on estimated construction schedules, shows that the maximum weekly content delivery will be 28, and would average 10 per week. Average truck movements will be 4 per day with maximum movements of 12 per day (rounded up) assuming that empty shipping containers will go back to the rail yard as backloads.

Table 8-2 provides an estimate of maximum heavy vehicle contributions per day for each segment of the optional haulage routes due only to container haulage. All data refers to bi-directional traffic flows.

Table 8-2: Heavy Vehicle Contributions Due to Container Haulage Road Current AADT Heavy Project Project Project (v/day s) vehicle addition contribution contribution AADT (maximum to total AADT to heavy heavy v/day) vehicle AADT Option 1 Mackay 5,404 1,080 12 0.2% 1.1% Avenue Irrigation Way 1,434 286 12 0.8% 4.2% Hamilton Road 181 no data 12 6.2% - Option 2 (preferred option) Mackay 5,404 1,080 12 0.2% 1.1% Avenue

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Burley Griffin 3,217 643 12 0.4% 1.9% Way Ross Road No data, but low no data 12 Unknown but - usage significant. presumed.

Table 8-3 provides an estimate of maximum heavy vehicle contributions per day for each segment of the optional haulage routes due to container haulage and aggregate deliveries for the perimeter road. All data refers to bi-directional traffic flows. It should be noted that aggregate deliveries will be spasmodic and difficult to estimate due to the vagaries of the construction schedule, weather and quarry supplies. Further, it is not possible to predict whether the container delivery and aggregate delivery schedules will coincide day to day, but it can be expected to occur on occasions during the commencement of construction. Table 8-3 provides an expected maximum daily impact due to both container haulage and aggregate deliveries, on the worst case assumption that daily deliveries coincide.

Table 8-3: Heavy Vehicle Contributions Due to Container Haulage and Aggregate Deliveries Road Current AADT Heavy Project Project Project (v/day s) vehicle addition contribution to contribution AADT (maximum total AADT to heavy heavy v/day) vehicle AADT Option 1 Mackay Avenue 5,404 1,080 46 0.9% 4.3% Irrigation Way 1,434 286 46 3.2% 16% Hamilton Road 181 no data 46 Unknown but Unknown but significant. significant. Option 2 (preferred option) Mackay Avenue 5,404 1,080 46 0.9% 4.3% Burley Griffin 3,217 643 46 1.4% 7.2% Way Ross Road No data, but no data 46 Unknown but Unknown but low usage significant. significant. presumed.

Reference to Table 8-2 shows that for the major arterial roads of Irrigation Way and Burley Griffin Way, that Project container delivery will provide very minor contributions to total or heavy vehicle traffic flows. Data is limited for Hamilton and Ross Roads, but it is reasonable to assume that they have relatively minor heavy vehicle flows, expect during harvest. The Project container haulage therefore would provide significant flows on these minor roads compared to the current operations.

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Reference to Table 8-3 shows that for the major arterial roads of Irrigation Way and Burley Griffin Way, that the Project container and aggregate deliveries will provide minor contributions to total traffic flows and measurable contributions to heavy vehicle traffic flows. Data is limited for Hamilton and Ross Roads, but it is reasonable to assume that they have relatively minor heavy vehicle flows, expect during harvest. The Project container and aggregates haulage therefore would provide significant flows on these minor roads when deliveries coincide.

It is predicted that the increases in arterial flows will be unnoticeable, given the ebbs and flows in regional trucking due to harvest peaks and troughs. Project heavy traffic on the minor roads (Hamilton and Ross Roads) will be noticeable and will most likely contribute the majority of traffic on given days during construction.

8.12.3 Mitigation Measures

A draft Traffic Management Plan outline is provided in Appendix 11 and will be completed in liaison with Griffith City Council’s traffic engineers and local residents to ensure traffic is adequately managed.

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8.13 Air Quality

8.13.1 Existing Environment

Dust is most commonly measured in the following units:

 Deposited dust, measured in grams per square metre per month (g/m2/month). This is the dust that residents would commonly see on window sills, and it can be generated from within and outside the house;  Total suspended particulates (TSP), measured in micrograms per cubic metre (µg/m3);

 A subset of TSP are particles with a diameter of 10 microns or less (PM10) measured in µg/m3. Particles between 10 and 2.5 microns in diameter are ‘inhalable coarse materials’, meaning the particles of dust would not be seen but can be inhaled; and

 A subset of TSP are particles with a diameter of 2.5 microns or less (PM2.5) measured in µg/m3 and are categorised as ‘fine particles’. These can be found in smoke and haze, or they can form when gases from power plants, industries and automobiles react in the air.

The NSW EPA operates dust monitoring stations at both Wagga Wagga North and Albury, the former being the closer to Griffith. Both sites operate tapered elemental oscillating microbalances

(TEOM) that record PM10 concentrations. Table 8-4 provides data recorded since 2013.

Table 8-4: PM10 Data

Parameter (PM10 µg/m³) Year Wagga Wagga North Albury Annual average 2013 22.1 15.8 2014 20.4 15.9 2015 20.1 14.7 Daily maximum 2013 110.7 59.2 2014 88.2 159.6 2015 145.1 92.5 Daily minimum 2013 4.6 3.8 2014 3.7 3.8 2015 3.1 3.2

3 3 The criteria for PM10 is 50 µg/m daily maximum and 30 µg/m annual average (Approved Methods, NSW DEC 2005). Reference to Table 8-4 shows that that the annual averages at both stations are well below the criteria, but that the daily maximum criteria has been exceeded in each year at both stations. Further analysis of the data shows the following exceedances of the daily criteria for Wagga Wagga North:

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 2013, 13 exceedances;  2014, 13 exceedances; and  2015, 8 exceedances.

Similarly for Albury, there were:

 2013, 15 exceedances;  2014, 13 exceedances; and  2015, 8 exceedances.

The similarity in the data with regards to annual averages and number of daily exceedances suggests that the two sites have a similar dust environment. Yoogali is 140 km from Wagga Wagga and 200 km from Albury, with Wagga and Yoogali both being in the Riverina Region and Albury in the adjacent Murray-Lower Darling Region.

There is no known dust deposition, TSP or PM2.5 data for the site or adjacent areas. It is expected that the local air quality is typical of rural areas, with irregular peaks due to dust storms, regional fires, local stubble burns, cultivation and crop stripping.

8.13.2 Impacts

Installation of the facility will involve trenching, plant and vehicular movements over soil and local unsealed roads, and general movement of construction vehicles over approximately 12 months. This limited activity is not expected to generate anymore dust that the regular cultivation and crop stripping that occurs on the site and adjacent paddocks, or any more than the background levels measured at Wagga Wagga and Albury. To manage dust raised during construction, internal access roads and the unsealed public roads used by construction traffic will be regularly watered.

The Project is not expected to generate measurable dust during operations and the establishment of a permanent pasture on what is now a series of cropping paddocks will reduce the dust generation potential of the PAA.

8.13.3 Mitigation Measures

Internal access roads and the unsealed public roads used by construction traffic will be regularly watered during construction.

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8.14 Electric and Magnetic Fields, and Radio Frequency Interference

8.14.1 Terminology and Existing Environment

A brief discussion of electrical terminology is useful to aid an understanding of electric and magnetic fields (EMF) and the separate question of radio frequency interference (RFI). Important terms in this context are:

 Voltage: a measure of electrical potential difference between two points, one usually being earth;  Current: the rate of flow of electric charge through a conductor;  Current density: the electric current flowing through a given conductor cross-sectional area;  Electric fields: produced by voltage, irrespective of current. Measured in volts per metre (Vm-1);  Magnetic fields: produced by current, irrespective of voltage. Measured in microTesla (µT) or milligauss (mG), where 1 µT = 10 mG;  Direct current (DC): the unidirectional flow of electrons. Most electronic apparatus use DC to operate, and solar panels produce DC power;  Alternating current (AC): the bipolar flow of electrons, whereby the current periodically reverses direction. AC is used in high and low voltage transmission and many electrical apparatus. Homes connected to mains power received AC power, which is used by many household devices. Any devices that are connected to AC and require DC to operate need a rectifier (although these are commonly called transformers as they often reduce current voltage as well);  Frequency: the number of alternating current cycles per second measured in Hertz (Hz). In Australia this cycle is repeated 50 times per second (50 Hz).  Conductors: the wires that transmit electricity. These can either be exposed or insulated cables attached to poles or lattice towers, or can be insulated buried cables;  kV: kilovolt or one thousand volts; and  rms: root mean square is a statistical term, which in the electrical industry is a calculation used to estimate the value of the DC that would produce the same power as the AC source.

Electric and magnetic fields (EMF) are produced by all electrical equipment, from high voltage power lines to hair dryers, with fields increasing with voltage and current respectively. Both fields drop away rapidly with distance from the source, or due to shielding by insulation or earth (in the case of buried installations). For comparative purposes, in unshielded overhead high voltage

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transmission wiring, both electrical and magnetic fields would drop to approximately zero within 60 metres from the centreline of the transmission line’s conductor bundles.

While the potential effects of EMF are debated, the general approach to EMF management is “prudent avoidance”. The National Health and Medical Research Council (NHMRC) recognised the potential effects of EMF and provided interim guidelines for EMF for occupational and public exposure in 1989. The NHMRC provides the following public exposure limits:

 Exposure to electrical fields between 5 and 10 kVm-1 m should be limited to a few hours per day: and  Exposures to magnetic flux densities between 0.1 and 1.0 mT should be limited to a few hours per day. When necessary, exposures to magnetic flux densities in excess of 1.0 mT should be limited to a few minutes per day.

NHMRC no longer manages this aspect of public health, which is now under the auspices of the Australian Radiation Projection and Nuclear Safety Agency (ARPANSA). The ARPANSA Radiation Health Committee agreed at its 24 June 2015 meeting that it would withdraw the existing NHMRC RHS30 guidance on exposure. The International Commission on Non-Ionizing Radiation Protection (ICNIRP) has issued Guidelines for Limiting Exposure to Time-Varying Electric and Magnetic Fields. The ICNIRP EMF guidelines are consistent with ARPANSA’s and the committee’s understanding of the scientific basis for the protection of people from exposure to EMF.

The ICNIRP EMF guidelines (Table 7) provide the relevant limits as follows:

 E field strength: 5000 V/m;  H field strength: 80 A/m; and  B field: 100 µT.

RFI can be generated by a range of electrical apparatus. The Australian Communications and Media Authority (ACMA) is the Australian regulator of radio communications, telecommunications, broadcasting and the internet, responsible for ensuring compliance with the Radio Communications Act, 1992. Part of ACMA’s role is to regulate the use of equipment that might affect important telecommunications.

There have been reports of household solar installations detrimentally affecting televising reception. It appears that this reported interference is not strictly due to RFI affecting reception, but are generally due to poor quality inverters inserting RFI into the household wiring system that disturbs the television set power supply, which in turn cause screen distortion.

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8.14.2 Impacts

In the case of the Project, the various EMF generating components would be the PV panels

(1000 VDC), the interconnecting buried cables (400 V), the direct to alternating current inverters

(1000VDC to 400 VAC), step up transformers to 33 kVAC and the short section of underground/overhead 33 kV connection between the two parts of the Project on either side of Ross Road. The interconnecting underground 33 kV cabling to the TransGrid substation is not specifically part of the Project and will be part of a separate application under Part 5 of the EP&A Act. However for completeness and to provide a rigorous cumulative assessment, this section of line is included in this EMF assessment.

Essentially EMF increases with voltage and proximity to the apparatus producing, transmitting or consuming electricity. EMF does vary according to specific design and construction parameters such as conductor height, electrical load and phasing, and most importantly, whether the conductors are overhead or buried. Useful technical information can be obtained from www.emfs.info, an industry maintained website (UK National Grid). This webpage provides the following EMF estimates:

• For overhead 33 kV lines on wooden poles and 5.5 m clearance from conductors to the ground, maximum electric field of 505 Vm-1 directly under the line, falling to 16 Vm-1 25 m from the line; and • For overhead 33 kV lines on wooden poles and 5.5 m clearance from conductors to the ground, maximum magnetic field of 14.8 µT directly under the line, falling to 0.5 µT 25 m from the line.

Underground cables always include a metal sheath that screens the electric field, so an underground cable produces magnetic fields only. However the underground cabling on the Project will be three phase that will produce a near zero magnetic field assuming a symmetric load, as is produced by the solar inverters.

The cabling from the panels, inverters and transformers (both low and high voltage) will be underground shielded types and so will not produce measurable electrical or magnetic forces. While not part of the Project application, the underground interconnection to the TransGrid substation will need to surface near the substation.

The component of the Project that will generate the highest EMF is the Ross Road interconnection, if it is built as an overhead line. This section of line has yet to be designed but approximately a 40 m section is required to clear the road and water supply canal. There is an existing low voltage transmission line along Ross Road that would need to be cleared by the interconnection.

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ICNIRP provide basic restrictions to prevent effects on nervous system functions of members of the public. For the 50 Hz AC power commonly transmitted in Australia, the current density exposure limit is 2 mA m-2 rms. Current density is calculated by the following formula:

Current density=π*radius of body*50Hz*0.2 S/m*magnetic flux density

For the short section of the exposed ground level 33 kV cable near the substation, the following assumptions are made:

 Distance to the anti-personnel fence 10 m; and  Maximum current for 30 MVA is 524 A.

Calculations for the ICNIRP E, H and B fields are as follows:

E=33,000 V/10 m=3,330 V/m

H= I/(2*π*r)=524/(2 x 3.14156 x 10) = 8.35 A/m

B=4*π*10-7*H=10.48 µT

Table 8-5 compares the calculated EMF values of the 33 kV substation connection against ICNIRP criteria and shows that all values are well under criteria.

Table 8-5: Calculated EMF Values for Exposed 33kV Cable to Substation Field Calculated value ICNIRP criteria Compliance E field strength 3,330 V/m 5000 V/m Yes H field strength 8.35 A/m 80 A/m Yes B field 10.48 µT 100 µT Yes

For the 40 m (nominal) section of the overhead 33 kV Ross Road interconnection, the following assumptions are made:

 Distance to the ground 6.7 m (based on NSW Code of Practice Electricity transmission and Distribution Asset Management 2009, Table 1 Minimum Clearance For Exposed Conductor Over Carriageway);  The calculated receiver is in the centreline of Ross Road; and  Maximum current for 30 MVA is 524 A.

Calculations for the ICNIRP E, H and B fields are as follows:

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E=33,000 V/6.7 m=4,925 V/m

H= I/(2*π*r)=524/(2 x 3.14156 x 6.7) = 12.44 A/m

B=4*π*10-7H=15.6 µT

Table 8-6 compares the calculated values against ICNIRP criteria and shows that all values are under criteria.

Table 8-6: Calculated EMF Values for Exposed 33kV Line Over Ross Road Field Calculated value ICNIRP criteria Compliance E field strength 4,925 V/m 5,000 V/m Yes H field strength 12.44 A/m 80 A/m Yes B field 15.6 µT 100 µT Yes

With regards RFI, solar inverters do emit harmonics but not radio frequency waves and so will not directly affect television transmissions. As discussed previously, poor quality household solar inverters can insert undesirable interference into wiring systems and so indirectly reduce picture quality. Inverters should be tested according to International Electrotechnical Commission (of which Australia is a full member) standards for radio interference, and, depending on the make and model may emit some radiation within acceptable limits. SMA inverters, the current type proposed for the Project, have been tested to rigorous German and international standards and have proven to not disturb radio signals except in the immediate area around the inverter (<5m).

As no houses will be within the facility, disturbance of internet reception and TV is not expected. Further, the Project central inverters will be connected to the 132 kV grid through a set of step up transformers rather than directly into household wiring. The step-up transformers, and the step down transformers at the supply end of the network will filter out any harmonics inserted by the Project inverters. Therefore no harmonics from inverters will be able to reach any household.

8.14.3 Mitigation Measures

No specific EMP mitigation measures are required apart from installing electricals to the relevant Australian Standards and guidelines. No specific RFI mitigation measures are required apart from the use of International Electrotechnical Commission compliant inverters.

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8.15 Socio-Economic

A Socio-Economic Impact Assessment has been prepared to assess the social and economic impacts of the Project. A full copy of this report is attached at Appendix 3.

8.15.1 Methodology

The socio-economic impact assessment is based on an analysis of the existing local area including the wider Griffith LGA and regional NSW. The methodology identifies the social and economic effects of the Project allowing the positive externalities (an economic activity that has a positive effect on an unrelated third party) to be magnified and any potential negative impacts mitigated.

The social impact assessment methodology included:

• Review of socio-demographic data from the Australian Bureau of Statistics (ABS); • Review of additional published and publicly available social and demographic data; and • Review of Griffith City Council’s and wider strategic plans.

The economic impact assessment methodology included:

• Economic and employment data from the ABS; • Review of Griffith City Council’s strategies and plans; • Review of published and publicly available economic data; and • Identification of economic impacts of the proposed Solar Farm.

Using the above methodology, the objectives of the assessment were to:

• Establish baseline data for the existing social environment; • Assess potential social and cultural impacts during the construction and operational phases; • Where appropriate, identify mitigation measures for the social, cultural and economic environment; • Identify the key economic considerations for the local and regional economy; and • Identify the potential positive and negative social and economic impacts on the locality and wider region.

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8.15.2 Existing Environment

The social infrastructure within the immediate locality of the proposal is limited and typical of a rural agricultural/rural residential region. The town centre of Griffith is approximately 6km from the project site which provides sufficient social and community infrastructure for the local residents, including facilities and amenities.

8.15.3 Impact

The Project will provide positive social and economic outcomes for the region by the way of employment generation and the promotion of renewable energy as an alternative to traditional coal-fired power generation.

The following positive social and economic impacts are expected to result from the Project:

• The proposal will deliver clean and renewable energy to in the face of climate change and help to meet renewable energy targets for the nation; • The proposal will create employment opportunities for the Griffith area; • The proposal provides a suitable alternative land use for the site that meets the needs of the wider community and promotes industry diversity; and • No substantial shifts in local demographics or population during construction or operational phases.

Notwithstanding the positive outcomes of the Project, the following potential negative impacts have been identified:

• Perceived visual impacts including general amenity and glint/glare; • Perceived impact on agricultural land; • Impacts arising from construction phase including dust and noise; and • Impacts from electromagnetic fields.

Each of these impacts have been specifically addressed within the EIS and no significant long term impacts are expected.

The Project will provide significant economic stimulus to the region while the listed mitigation measures will effectively ameliorate any actual or perceived negative social impacts.

8.15.4 Mitigation Measures

No specific mitigation measures are required.

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8.16 Glint and Glare

A Glare Study Report has been prepared to assess the effects on aircraft safety, particularly during the final approach to each of the runways located at Griffith Aerodrome. A copy of the Report is attached at Appendix 12.

8.16.1 Existing Environment

The glint and glare assessment is specifically concerned with impacts on aircraft, requiring consideration of local airports and low-flying operators. The Griffith Aerodrome is located north of the town of Griffith, NSW with centre runway coordinates of 34° 15′ 03″ S, 146° 04′ 02″E.

The main paved runway 06/24 is 1704m in length and oriented SW-NE (055°/235°) and the second alternative grass/dirt runway 18/36 is 600m in length and is oriented approximately S – N (178°/358°). Therefore main approach paths are considered to be SW or NE with alternate approaches for light aircraft from S or N.

8.16.2 Methodology

Appropriate modelling has been undertaken to assess the glint and glare impacts of the Riverina Solar Farm. In calculating the intensity of glint and glare for aircraft routes into Griffith Airport, a number of factors were considered including:

• Distance between panels and viewpoint; • Horizontal title angle of panels; • Time of day and season; • Time exposed to glare angle; • Cloud cover; and • Screening vegetation.

Based on these factors, a glare calculation was performed for the aircraft routes using the Solar Glare Hazard Analysis Tool (SGHAT V2B) developed by the Sandia National Laboratories of the US Department of Energy. The calculation also considered sun intensity for Griffith using insolation data from the NASA Surface Meteorology.

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8.16.3 Impact

The reflective nature of PV Panels is less than many other common surfaces including steel and standard window glass. By way of comparison, typical agricultural surfaces and airport buildings such as metal roofs, dams & lakes, car windscreens and farmland have higher reflectivity than solar PV panels.

Griffith Airport is approximately 6.9km north-west of the PAA. The glare calculation performed for the aircraft routes using the Solar Glare Hazard Analysis Tool revealed that no glare was calculated for any approach path.

As the main flight approaches are from SW or NE, no point of any approach will be closer than 6km from the proposed solar plant and thus should provide suitable distance to not generate sufficient light intensity for having a blinding effect on the pilot’s view. As the runway is NE to SW, pilots viewing the runway during close proximity on final approach, will not have any direct view of the solar plant aligned with the runway approach.

Similarly, for the smaller alternate runway, the approach from the south to the runway will not have a line of sight of the solar farm and will be travelling away from the solar farm towards the runway. The approach from the north may see the solar farm off in the distance over 7km to the left of the runway however, the alignment of the runway is not in alignment with the solar farm. No point of the approach will be closer than 7km from the proposed solar plant and therefore should provide enough distance to not generate sufficient light intensity for having a blinding effect on the pilot’s view.

Consultation with local low-flying agricultural aviation organisations occurred as part of the stakeholder engagement process for the proposal. No concerns were raised by these organisations in relation to glint and glare. All organisations noted they were aware of the reflective properties of PV panels. Furthermore, all organisations indicated they regularly operate over solar installations of 10 – 20 panels in the Yoogali area and there have be no incidence of interference with flying operations.

It can therefore be concluded that glare or glint from the proposed solar PV Plant is not a concern for air traffic safety by reason of intensity, configuration or colour, cause confusion or glare to pilots that would endanger the safety of aircraft, particularly on final approach to the aerodrome.

8.16.4 Mitigation Measures

No mitigation measures are required.

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8.17 Cumulative Assessment

This section considers the potential cumulative impacts that may arise as a result of the Project at different spatial and temporal scales. The cumulative impact assessment combines the residual impacts of the Project with the impacts of existing and approved development in the immediate locality and wider Region. The cumulative impact of the Project necessarily considers the mixed developments and land uses adjacent to the site, and has been prepared in accordance with the following objectives:

• To identify and assess the cumulative impacts of existing, approved and proposed developments within the locality; • To determine how the construction and operation of the Project may contribute to the overall impacts on environmental, social and economic values of the Region; and • To identify mitigation strategies to minimise the Project’s contribution to negative cumulative impacts.

The following land uses currently occur or are planned adjacent to the PAA:

• Neoen Solar Farm; • Various citrus and grape farms; and • Various broad acre farms (primarily cereals).

Further from the PAA but still within the region, the following major land uses occur:

• Various citrus and grape farms; • Various broad acre farms (primarily cereals); and • Community and commercial centres such as Griffith, Hanwood, Bilbul and Yoogali.

Given the proximity of the Project to other existing and proposed land uses, certain impacts such as dust, traffic, noise, greenhouse gases and visual impact can and will add to existing emissions from other facilities.

The following technical studies assessed cumulative impacts within the context of existing and future land uses.

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8.17.1 Air Quality

The air quality predictions are to an extent cumulative as they consider baseline data. The Project will have little effect on air quality, either as deposited dust or suspended dust concentrations, particularly against the background of periodic background exceedances of criteria and regular agricultural activities.

The Neon project could be expected to have similarly limited effects on local air quality, and even if both projects are built concurrently, they are not expected to cause a significant cumulative impact.

8.17.2 Traffic

The traffic assessment is cumulative in that it considered baseline traffic counts, to which the Project traffic predictions were added. Trip generation from the Project is relatively minor and short term, and will have no significant impact on the levels of service or capacity of the existing road network.

The assessment has not considered the potential contribution of heavy vehicles used for the Neoen project, however, assuming a similar rate of trucking from that Project, even if the two projects were built concurrently, it is anticipated that no significant delays would be noticed by other road users on the arterial roads.

Local roads should not be significantly affected by any cumulative impact of the two projects, with the Neoen Project proposing a different access route via Irrigation Way and Poletta Road.

8.17.3 Noise

The noise predictions are cumulative in that they account for assumed background noise emissions, to which were added Project contributions. Predicted construction noise levels are above the Interim Construction Noise Guidelines, and if the Neoen Solar Farm was built at the same time as the Project, there would be seem level of cumulative impacts for receptors to the south of the Project.

No construction details are available for the Neoen project but it is reasonable to assume that construction plant similar to the Riverina Project would be used. Accordingly, as a worst case prediction, totalling the two projects sound pressure levels would provide a total of 120 SWL. Calculated to the Wallace residence “The Farm”, assuming that the two separate projects were using all their equipment at the same time, both situated in the centre of the respective sites, the received noise at “The Farm” would be 55 dB(A). This is significantly more than the ICNG criteria of background plus 10 although less than the ICNG highly affected criteria of 75 dB(A).

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Owing to the calculated noise loss for distance, it is expected that the cumulative noise would be less than the noise received during construction of the Project close to the southern edge of the PAA of approximately 65 dB(A). The cumulative prediction is below the ICNG highly noise affected limit of 75 dB(A).

A Noise Management Plan will be finalised in consultation with Griffith City Council and adjacent landholders to minimise Project noise impacts.

8.17.4 Greenhouse Gas

The Project will supply an estimated 2 MkWh of electricity to the NEM over its lifetime. If this electricity was produced by a coal-fired power station, an estimated 1.44 MtC02e would be liberated to exacerbate the greenhouse effect and consequently global warming. Allowing for the greenhouse gases liberated by the manufacture, installation and demolition of the Project, only

72,000 tC02e would be produced, saving approximately 1.8 MtC02e.

Assuming that the similar capacity Neoen project makes the same GHG savings, between them the two projects will preclude the generation of approximately 3.6 MtC02e.

8.17.5 Visual Amenity

The Project and the Neoen Solar Farm to the south east will have a cumulative visual impact. It is anticipated that the Neoen Solar Farm will be employing similar measures to mitigate visual impacts, such as vegetative screening. Noting that both projects front Irrigation Way, where practicable, EPS and Suntech will endeavor to work with Council and Neoen to incorporate unifying elements into the design of key visual features (i.e. landscaping).

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9 SUMMARY OF MITIGATION MEASURES

Table 9-1 provides a summary of mitigation measures for the Riverina proposal:

Table 9-1: Summary of Mitigation Measures Issue Mitigation Measure Section of EIS Visual Impact A 5m wide double row planting landscape screen will be established 8.1 along the PAA boundary fronting Clark Road and along Irrigation Way (Griffith Road) and a small section along the north western boundary to reduce visibility of the Project from these aspects. Land Use The Project site will be sown with permanent pasture and grazed for 8.2 the life of the operation. On decommissioning, the facility will be demolished and the land will be returned to its current agricultural production potential. Surface Water Short pasture will be grown underneath the panel arrays. 8.5 and Erosion During construction, access paths for equipment will not be routinely graveled, although main access tracks will be permanently graveled. Rows of PV panels will be separated from the next row, so providing an infiltration area and sunlight to pasture. The ground under and adjacent the PV panels will be sown with a permanent pasture mix, suitable to the region and long term stock grazing. The Project area will be controlled grazed (most likely with sheep) to maintain ground cover density and manage the sward length. Flooding Any trenches dug for transmission lines will be backfilled and 8.6 compacted to ensure no windrows remain that might divert surface flows. Groundwater Oils and lubricants used during construction will be stored in a 8.7 locked and bunded facility. Greenhouse The Project design and PV component selection will maximize 8.8 Gas electricity production. Components will be replaced as they become obsolete or are superseded by more efficient technologies. Panels will be washed occasionally to maximize solar collection. Noise The Draft Construction Noise Management Plan will be updated and 8.9 implemented prior to construction. Aboriginal and The four identified artefacts will be subject to surface salvage 8.10 Cultural (collection) under an approved development consent for the project Heritage (SSD16_7482).

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Issue Mitigation Measure Section of EIS All staff and contractors accessing the site will be made aware of their statutory obligations for heritage under the National Parks and Wildlife Act 1974 and the Heritage Act 1977 as part of the site induction. If unrecorded Aboriginal object/s are identified in the Project Area during works, then all works in the immediate area must cease and the area should be cordoned off and OEH contacted. In the unlikely event that skeletal remains are identified, work must cease immediately in the vicinity of the remains and the area must be cordoned off. The proponent must contact the local NSW Police and OEH. Bushfire Installation of only Australian Standard compliant components. 8.11 Ongoing, long-term liaison with adjacent landholders will ensure that the Project site is staffed during neighbouring stubble burns. Installation and management of SCADA system to monitor system performance. Installation of thermal overload protection on inverters. Controlled grazing of pastures under panel arrays. Maintenance of perimeter firebreak. Traffic and The Draft Construction Traffic Management will be updated and 8.12 Transport implemented prior to construction. Air Quality Internal access roads and the unsealed public roads used by 8.13 construction traffic will be regularly watered during construction.

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10 ENVIRONMENTAL MANAGEMENT AND MONITORING

While the purpose of the EIS and environmental assessment process is to identify and measure the actual environmental impacts resulting from the Project, the role of an ongoing environmental management system is to ensure that the identified controls and commitments are maintained throughout the construction and operational phases of the Project. Further, a formal environmental management system will implement and monitor the objectives and measures outlined in the development consent, relevant licenses and legislation. Accordingly, this section outlines an overall environmental management framework to guide the development and management of the Project.

Following a positive determination and development consent, an Environmental Management Plan (EMP) will be prepared taking into account the following documents:

 This Environmental Impact Statement;  Issued conditions of consent; and  Any other approval, licence or permit required, including but not limited to grid connection to the TransGrid Griffith Substation.

A suite of EMPs will be prepared including a Construction Environmental Management Plan and an Operational Environmental Management Plan. These EMPs will be drafted and finalised following development consent. Notwithstanding, the EMPs are expected to specify all environmental management activities and measures used to control, prevent or minimise environmental impacts. In addition, the plan will assign responsibility for mitigation measures to specific personnel and allocate quantitative or qualitative criteria to the performance of each measure where applicable. The following matters are likely to be addressed in the suite of EMPs:

 Project Description;  Environmental management structure and responsibilities;  Approval and licensing requirements;  Environmental training requirements;  Emergency contacts and response procedures;  Risk assessment;  Environmental management maps as required;  Environmental monitoring requirements;  Environmental auditing as required;  Weed monitoring and control;  Corrective action; and  Review.

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The nature of the Project means that environmental monitoring required by more intrusive project (mines, quarries, roads, etc.) will not be required. In addition to the electrical and mechanical systems monitoring required to efficiently operate the facility, the following monitoring is proposed:

 Subject to finalisation of the final Noise Management Plan, noise monitoring at potential affected residences if complaints are received;  Visual monitoring of dust during construction; and  Dilapidation surveys of unsealed roads.

Appropriate environmental management and monitoring measures will be implemented following a positive determination for the Project in accordance with the following environmental objectives:

 Implement a standard of environmental management that reflects proactive planning and recognition of environmental impact;  Comply with Commonwealth and NSW legislative requirements;  Comply with all applicable environmental standards and approvals throughout all phases of the Project; and  Commit to undertake all environmental management practices in accordance with best- practice.

Monitoring and management procedures may be adjusted in the event of an environmental incident or the receipt of complaints.

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11 ECOLOGICALLY SUSTAINABLE DEVELOPMENT

The objectives of the EP&A Act are listed in section 5 of the Act, including encouragement of the principles of Ecologically Sustainable Development (ESD). A comprehensive assessment of a proposal in accordance with the principles of ESD should result in a clear justification of the preferred project. Accordingly, the complete integration of ESD principles within the environmental assessment process has remained a paramount consideration for the Project, from inception and concept phases, through to the design and assessment stage.

Supplementary to the EP&A Act objectives, section 7 (1(f)) of Schedule 2 of the EP&A Regulation requires a proponent to include in an EIS the reasons justifying the development, including the principles of ESD. Section 7(4) of Schedule 2 of the EP&A Regulation defines the principles of ESD as follows:

(a) the precautionary principle, namely, that if there are threats of serious or irreversible environmental damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation. In the application of the precautionary principle, public and private decisions should be guided by: (i) careful evaluation to avoid, wherever practicable, serious or irreversible damage to the environment, and (ii) an assessment of the risk-weighted consequences of various options, (b) inter-generational equity, namely, that the present generation should ensure that the health, diversity and productivity of the environment are maintained or enhanced for the benefit of future generations, (c) conservation of biological diversity and ecological integrity, namely, that conservation of biological diversity and ecological integrity should be a fundamental consideration, (d) improved valuation, pricing and incentive mechanisms, namely, that environmental factors should be included in the valuation of assets and services, such as: (i) polluter pays, that is, those who generate pollution and waste should bear the cost of containment, avoidance or abatement, (ii) the users of goods and services should pay prices based on the full life cycle of costs of providing goods and services, including the use of natural resources and assets and the ultimate disposal of any waste, (iii) environmental goals, having been established, should be pursued in the most cost effective way, by establishing incentive structures, including market mechanisms, that enable those best placed to maximise benefits or minimise costs to develop their own solutions and responses to environmental problems.

The following sections provide the evaluation of the Project with regard to ESD.

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11.1 Precautionary Principle

As defined above, the precautionary principle requires careful evaluation of potential environmental damage and risk‐weighted consequences of such damage to avoid serious or irreversible harm. In this sense the precautionary principle promotes proactive environmental protection as opposed to reactive measures following environmental damage. In order to satisfy the precautionary principle, the potential for serious or irreversible environmental damage must be anticipated, measured and prevented from the outset to ensure a level of scientific certainty has been achieved in relation to the proposed development.

Accordingly, this EIS has undertaken an evaluation of all key environmental components, as well as secondary components with the potential to influence environmental damage including social and economic considerations. Detailed assessment of all key issues and proposed mitigation and management procedures have been conducted as documented in the previous sections of the EIS. Through the adoption of an anticipatory approach, each potential issue arising from the Project has been identified, evaluated and mitigated through a series of design, monitoring or management solutions.

The assessment process has involved a detailed study of the existing environment and the use of scientific modelling and study to assess and determine potential impacts as a result of the Project. The process also relied on the experience and expertise of the specialists engaged throughout the assessment phase. To this end, there has been careful consideration to avoid, where possible, irreversible damage to the environment, including the following measures:

• The best available scientific information for the Project area has been relied upon during the assessment process. Where necessary, site investigations and monitoring have been undertaken to ensure a level of scientific certainty consistent with the precautionary principle. Where uncertainty in data has been identified, modelling and assessment have been based on an objectively ‘worst‐case scenario’ case analysis with appropriate contingency measures proposed to manage such uncertainty; • Modelling of worst case scenario visual impact, land use impact (agriculture), biodiversity impacts, noise emissions, traffic impacts, and air quality impacts have provided greater scientific certainty about the potentially adverse impacts of the Project. This has subsequently resulted in conservative mitigation measures to manage and monitor anticipated environmental impacts; and • Cumulative impacts created as a result of the Project being carried out adjacent to a similar solar project, proposed by Neoen Australia, have also been assessed to provide certainty surrounding the expected environmental impacts.

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The EIS has anticipated, assessed and managed the potential impacts and uncertainties arising from the Project. The Project contains no environmental or cumulative environmental issues with large-scale uncertainties capable of posing a risk of serious or irreversible damage to the environment. Therefore the Project is consistent with, and meets the precautionary principle.

11.2 Inter-generational Equity

The concept of inter‐generational equity requires that the present generation preserves or enhances the health, diversity and productivity of the environment for the benefit of future generations. Essentially it refers to equality between generations. The concept includes both intra‐generational equity, i.e. within generations, and inter‐generational equity, i.e. between generations. This means that the principle extends beyond the requirement of environmental protection and enhancement for inter‐generations, but also requires that the economic and social benefits of the proposal are equally distributed among members of a community intragenerationally.

Throughout the assessment process, the type and extent of potential impacts caused by the Project have been analysed and mitigated. The assessment methodologies have adopted a risk- based and worst case scenario approach to ensure improved environmental, social and economic protection for current and future generations. The environmental management and mitigation measures have been developed to minimise the impact of the Project on the environment for future generations.

The Project promotes inter-generational equity in Australia through the use of renewable energy. Renewable energy is needed to replace non-renewable sources in order to prevent adverse climate change impacts on future generations. Solar PV facilities, such as those to be used in this Project, can produce between 10 and 42 times lower GHG emissions per kWh of electricity produced when compared to traditional coal-fired thermal power stations. Significantly, the Project is anticipated to produce seven times more energy than it consumes over its lifetime, and will save approximately 1.8 MtC02e compared to traditional coal-fired power generation. Solar farming promotes intergenerational equity by ensuring that the needs of the present generation are met without compromising the ability of future generations to meet their own needs.

The Project has no long term impacts which will prevent inter-generational equity. The solar panels are expected to operate for a lifespan of 30 years. After this time the project is expected to be decommissioned. Once all the infrastructure is removed from the site, the land would likely be returned back to its previous condition. Solar farming has little if any impact on the quality of the land so the land is cable of being used for other purposes, including agriculture, in the future.

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The Project also has the potential to improve inter-generational equity through the creation of mutualism. Solar panels typically have minor disturbance footprints and solar farming does not preclude land from other forms of traditional farming. For example, sheep grazing is likely to occur on the land simultaneously with solar farming. Diversification provides farmers with increased financial stability where their ventures are not co-dependent.

11.3 Conservation of Biological Diversity

The conservation of biological diversity refers to the maintenance of species richness, ecosystem diversity and health, and the links and processes between them. In accordance with the principle of conservation of biological diversity and ecological integrity, a number of investigations have been undertaken by specialists to assess the extent and nature of ecological values on the site and the surrounding locality. All environmental components, ecosystems and habitat values potentially affected by the Project are described in the EIS.

The Project will not significantly impact on biological diversity. The site has been extensively used for agricultural purposes for a number of years. Desktop analysis has been undertaken on a number of resources including existing threatened species listings under the Threatened Species Conservation Act 1995 (NSW) and the EPBC Act (Cth). Based on the primary analysis, it is unlikely that any threatened species, population or endangered ecological community occur onsite, and therefore would not be impacted by the project.

11.4 Improved Valuation, Pricing and Incentive Mechanisms

The principle of improved valuation and pricing mechanisms refers to the need to determine proper values of services provided by the natural environment. The objective is to apply economic terms and values to the elements of the natural environment. This is a difficult task largely due to the intangible comparisons that need to be drawn in order to apply the values.

This Project optimises the valuation and pricing of natural resources by generating electricity and a financial income from solar power; a natural and sustainable energy source. As the sun is a renewable resource, there are minimal, if any environmental costs generated from solar farming. This project simultaneously promotes sustainable economic development by promoting growth and economic stimulus in the region with a low environmental cost. Finally, the proponent accepts that polluter pays principle and will be responsible for the removal and appropriate disposal and/or recycling of all products used throughout the construction, operation and decommissioning phases of the solar project.

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12 CONCLUSION

This EIS has been prepared for the proposed Riverina Solar Farm at Yoogali, near Griffith, NSW. The expected environmental issues related to the proposed development have been outlined and assessed. These assessments are made in accordance with the relevant Commonwealth, State and local planning requirements. It is considered that the proposed project will not result in any significant impacts with regards social, economic or environmental matters.

The assessment of key environmental impacts concluded:

• Air quality – The low level of dust expected to be generated during construction will be mitigated by regular watering; • Traffic – Effective planning and ongoing liaison with Griffith City Council will ensure that traffic disruptions are largely unnoticeable; • Noise – It is expected that predicted construction noise will not cause community concern given the pre-existing noise levels associated with the agricultural area; • Greenhouse gas – the project could offset a significant amount of GHG; and • Visual Amenity – Vegetation screening will be used to mitigate any perceived loss of visual amenity from Irrigation Way.

The Riverina Solar Farm offers a number of economic and environmental benefits which outweigh any minor negative environmental impacts. The proposal is strategically important for renewable energy in Australia and is reflective of the principles of ecologically sustainable development. In light of the low level of environmental impact, it is considered that the proposed development meets all regulatory and environmental assessment criteria and is suitable for a positive development determination.

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13 REFERENCES

Cook, L. and McCuen, R 2013, ‘Hydrologic Response of Solar Farms’. Journal of Hydrologic Engineering, vol 18 iss. 5, viewed January 2016 pp. 536-541.

Department of Environment and Climate Change 2009, Interim Construction Noise Guideline, DECC, NSW.

Department of Environment and Climate Change and Water 2011, NSW Road Noise Policy, DECCW NSW.

Lenzen, M 2008, ‘Life cycle energy and greenhouse gas emissions of nuclear energy: A review’, Energy Conversion and Management 49, pp. 2178-2199.

MacKay DJC 2009 Sustainable Energy – Without the Hot Air. UIT, Cambridge, viewed January 2016, http://www.withouthotair.com

Singh, R.P., Mullen, J.D., and Jayasuriya, R.T., 2005, Farming Systems in the Murrumbidgee Irrigation Area in NSW, Economic Research Report No. 10, NSW Department of Primary Industries, Yanco, viewed January 2016, http://www.agric.nsw.gov.au/reader/10550.

Vitucci, M 2013, Heavy Vehicle Strategy, Griffith City Council NSW.

Wright, M. and Hearps, P 2010, Australian Sustainable Energy Zero Carbon Australia Stationary Energy Plan, University of Melbourne Energy Research Institute, Beyond Zero Emissions.

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Appendix 1 Secretary’s Environmental Assessment Requirements