Cullerin Range Wind Farm 30 August 2006

Response to Public Submissions – Cullerin Range Wind Farm

Below is a summary of relevant issues raised in submissions, together with the proponent’s response. Please note, “SoC” refers to the Statements of Commitment outlined in Chapter 9 of the Environmental Assessment (EA).

Bicentennial National Trail

A number of general issues were raised in public submissions in relation to the Bicentennial National Trail, summarised as follows:

1. The Environmental Assessment has failed to identify Lerida Road North as part of the Bicentennial National Trail and as such, the impacts of the proposal, particularly the high noise levels and visual dominance of the turbines, have not been properly evaluated. Could the Proponent provide further information on how the potential impacts of the wind farm on the Trail would be managed, particularly during the construction period in light of the use of this road by many bushwalkers and horse riders.

2. The Trail is used by horse riders, cyclists and walkers. Will these users be unable to use the trail due to safety reasons (such as from shadow flicker and noise) arising from the wind farm? There is general concern that children in particular, will not be able to use these sections of the roads as the proposal will frighten and endanger both the riders and their horses.

3. Submissions note that the Cullerin Range provides an ideal environment for the training of racehorses due to the gradient of the slopes. Will the wind farm be detrimental to the horses, particularly as they are sensitive to low frequency sound waves?

4. Many submissions consider that an important piece of history will be lost forever and that the wind farm will destroy the physical characteristics, historical concept and ambience of the Bicentennial National Trail. How does the Proponent propose to address this?

5. Will trees be removed along Lerida Road North? A number of people are concerned, particularly as many of the trees are very old and have heritage significance to the locals.

6. The Traffic Assessment report states “The location of trees and other roadside objects have the potential of obstructing the passage of long wide loads” p 17 section 5.2.4. Whilst there is no apparent reference to the removal of trees on Lerida Road, there is equally no discussion on how the loads will be managed to negotiate the road if trees are not to be removed. What does the proponent propose in this circumstance?

7. Concern has also been raised at the construction of a cement batching plant next to the Trail which will detract from the heritage values of the Trail. How does the Proponent propose to address this?

8. Will any part of Lerida Road North be diverted in order to establish and maintain access to the turbine site?

The Visual Assessment acknowledged that the Bicentennial National Trail occurs in the area and that horse riders were likely to use it within close proximity of the site. Lerida Road North forms 4.36 km of the Bicentennial National Trail. The trail is 5330 km in total, traversing bush, wilderness and mountain areas from Victoria to North Queensland, following historic coach and stock routes, old pack horse trails, and country roads and providing where possible a "living history" of the county. It is used by horse riders, walkers and mountain bike riders. The Lerida Road North section of the trail is not remote like much of the Trail and can be accessed from the Hume highway and public roads, in the vicinity of the proposed wind farm site.

Potential impacts of the proposal on the Lerida Road North section of the trail and the experience of users of the trail include:

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­ track upgrades to allow access during the construction phase as outlined in the EA and Traffic Impact Assessment (outlined below)

­ possible loss of heritage appeal through visual impact; and

­ possible safety impacts (including noise, shadow flicker and the unexpected start up of turbines).

The impact of these works at Lerid Road North is evaluated in Attachment 3.7, Appendix G to the EA. The proposal would involve minor alterations to discrete sections of the road, including grading, repair of damaged culverts, the lopping of branches at narrow sections, possible modification or replacement of gates, and possible road widening where the road is less than 6m. In some cases, it may be easier and result in less soil disturbance to lop encroaching branches rather than increase the road width, this is the preferred approach in these circumstances. It is estimated that one apple box, 10 yellow box, 4 red gum and 1 brittle gum would require some lopping. Lerida Road North would be used to access a temporary concrete batching plant at the southern end of the road.

Lerida Road North will not be diverted at any time during construction or operation of the project.

The proponent does not anticipate any removal of trees along Lerida Road North.

At the site, the trail crosses largely cleared agricultural lands with heritage values, as discussed in the EA in Sections 7.7.2 and 8.4. It was considered that:

“the development is not incongruous with the production­based economy of the area and is not situated near formalised nature­based recreation activities. The close proximity of the site to existing infrastructure, including the Hume Highway and electricity easements, suggests that its placement is not inconsistent with visitors’ experiences of the character of the area.” (p.8 EA).

The visual impact of the proposal was assessed as a key issue in Section 7.2 of the EA. A specialist report categorised the landscape into character types and uses. Based on the nature of the modified rural landscape in the area, and the many significant built elements visible in the landscape, it was determined that there were no landscape character types in the area where the contrast between the wind farm and the landscape would be unacceptable. This assessment took into account the recreational use of the area by horse riders.

Noise impacts are not expected to cause nuisance or safety issues for passing traffic.

Mitigation measures to address the above impacts during the construction and operational phase of the proposal are discussed in the EA and are considered adequate to address the impacts on this part of the Bicentennial National Trail. Relevant mitigation measures from the EA include:

­ Preparation of a Traffic Management Plan (SoC 21).

­ Preparation of a Construction Environmental Management Plan (SoC 36).

­ Heritage impact mitigation as per (SoC 40).

­ Locating and designing infrastructure for minimum contrast to the existing landscape (SoC 3 and 4).

­ Signage to warn horse riders of potential sudden start­up of turbines and shadow flicker (SoC 19).

Horse riders, cyclists and walkers will be able to use the trail at all times.

If shadow flicker is found to be a nuisance to residents or motorists, conditions will be pre­ programmed into the control system and individual wind turbines automatically shut down whenever these conditions are present (SoC 39).

The potential for impact to horses and livestock was considered with reference to the British Horse Society wind farm advisory statement guidelines (Section 7.7.1 of the EA). In general, the development would pose a low risk, however measures to further reduce risk on neighbouring roads and properties are recommended (SoC 19).

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It has been stated categorically by the British Wind Energy Association in 2005 that there is no significant infrasound emitted from current designs of wind turbines. This has been confirmed in the SA EPA Noise Guidelines, which state that recent turbine designs do not appear to generate significant levels of infrasound, as the earlier turbine models did. Therefore this issue is not expected to affect horses near the site.

Although some loss of amenity will be experienced during the construction phase for users of the trail, this would not preclude the use of the trail at any time and is over a short section of the trail (less than 5km of the 5330km trail). In the medium to long term the change in character of the trail is not expected to be unacceptable.

The batching plant is to be located at an area previously used as a batching plant where an existing concrete slab is currently located. Although some loss of amenity may be experienced during the construction phase for users of the trail, this would not preclude the use of the trail at any time and is over a short (less than 1km) section of the trail adjacent to the Hume Highway. This will be a temporary impact for the construction phase only, the plant will be removed following construction.

Noise

A number of general and specific issues were raised in relation to potential noise impacts for the projects, the response to these has been summarised under the following key issues:

9. A submission notes that in addition to the “swish” sound identified in the SA Guidelines, there is also an additional modulation or “pulsing” sound which is caused by: changes in flow conditions around the blade aerofoil as it passes the tower; and wind shear, producing different airflow regimes around the blade at high and low points of blade rotation (known as the Van den Berg effect). The submission argues that the use of the term “swish” in the SA Guidelines is not the same as the modulating sound as inferred in the noise assessment (See section 1.2.2 and 2.2). The submission goes on to further state that such modulating characteristics will be heard by observers at locations distant from the turbines where the turbine noise is audible above background noise and as such, a penalty of 5 dB(A) should be added when assessing turbine noise levels at receivers.

Please provide further justification to demonstrate that either the annoying modulation is submerged in background noise (and therefore, not an issue) or that compliance is possible with a 5 dB(A) penalty added.

“Swish”, also commonly called “swooshing”, is simply an onomatopoeic description of the character of the sound. Given the cyclical nature of rotating turbine blades and variations in the wind profile with altitude, it is not uncommon for the noise being emitted from each blade to be cyclical and therefore have a modulating character. The degree of modulation is dependant upon numerous environmental variables and is not generally measured or assessed during detailed IEC 61400­11 testing.

The SA EPA Guidelines have “been developed with the fundamental characteristics of noise from a wind farms taken into account”. The Guideline only prescribes penalties (of 5 dBA) be applied to tonal emissions. It should be noted that the minimum limit under the SA EPA Guideline of 35 dBA is 5 dBA lower than that of the New Zealand Standard NZS 6808:1998 of 40 dBA, from which the methodology of the assessment was generally based. The New Zealand standard provides for a penalty if special audible characteristics (tones, impulsiveness or modulation) are present. The SA EPA guidelines were developed with a lower minimum limit with the inference that certain characteristics (including ‘swishing, modulation etc.) are inherent in all wind farms.

It should also be noted that the NSW Industrial Noise Policy does not explicitly identify modulation as an audible characteristic requiring a ‘modifying factor’ adjustment.

10. The WHO Guidelines state that where noise is continuous, the equivalent sound pressure level should not exceed 30 dB(A) indoors. Outside bedrooms with a window open at night, the equivalent sound pressure level is 45 dB(A). The submission contends that these guidelines imply a façade attenuation of 15 dB(A), whilst in Australia, the attenuation capacity of rural dwellings is likely to be 10 dB(A) or less. Please discuss.

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The exact sound transmission loss of a dwelling bedroom is dependant upon variables such as;

­ The exact construction details and materials used for walls, roof/ceilings, eaves etc. ­ The size (volume) of the bedroom ­ The amount of acoustic absorption in the bedroom (soft furnishings etc.) ­ The total area of glazing and thickness of glass ­ The total area of open window ­ The incident angle of impinging noise

It is therefore to be expected that quite some variation in transmission loss will occur from one dwelling to another. Generally 10­15 dBA can be expected from an ‘open window’ scenario.

The predicted noise level at each dwelling has been calculated as a worst case exposed façade. In reality the dwelling will likely provide full or partial shielding from some WTG noise sources on some or all facades, resulting in lower external noise levels on those facades. The predicted external noise levels in front of bedroom windows therefore imply a degree of conservatism in most cases.

Those dwellings being assessed under the WHO Guidelines are “project involved”. If actual WTG noise levels in bedrooms are determined to exceed WHO limits then any impact can be mitigated through providing suitable acoustic upgrade of windows or providing alternative ventilation.

11. The NSW Industrial Noise Policy requires that temperature inversions be considered in any assessment of noise impacts. The proponent has not provided any data predicting the frequency of temperature inversions and no proper analysis of their consequent effect on noise, although a few submissions provide anecdotal evidence to suggest that night time surface temperature inversions are a feature of the locality (and the wider Southern Tablelands region generally). One submission expressed particular concern with the statement made in the consultant’s report that “there is insufficient data to accurately determine the prevalence of temperature inversions” as justification for not addressing this effect.

Further information is required from the proponent in this regard, that is, the proponent must either obtain the relevant meteorological data to demonstrate whether temperature inversions are a feature of the area, or provide solid justification why the worst–case scenario of a temperature inversion being present should not be modelled. If inversion conditions are found to be a feature of the area, further modelling taking this effect into consideration must be undertaken.

Noise propagation enhancement during temperature inversion conditions occurs where the noise source is located below the inversion level. Furthermore, significant noise enhancement gains generally occur to ground based sources which are shielded.

If the wind turbine is located lower than the inversion level, the turbine would be experiencing similar wind conditions to those conditions at ground level, and would therefore be accurately modelled using the existing analysis.

Furthermore, temperature inversion conditions generally form only when little wind is blowing. Under such conditions it is unlikely that wind turbines will be operating.

Wind turbines are therefore not typical of other ground based sources and low level temperature inversions (in the lower 100 metres of the atmosphere or so) are unlikely to affect wind turbine noise propagation.

Insufficient historical meteorological data exists to assess the prevalence of temperature inversions at this site. Notwithstanding, the report concludes that the height of wind turbines on Cullerin Range above the surrounding region is significant (160 ­ 200 metres). Accordingly, the presence or otherwise of temperature inversions is unlikely to have any additional impact on noise propogation at the site.

12. High wind velocities at turbine hub height can occur without high wind velocities at ground level and as such, wind turbine noise at the receiver may not be masked by higher background noise. How does the model take this into consideration?

The noise model simply predicts what the wind turbine noise level at each receiver location for each integer wind speed. The assessment methodology prescribes the technique of characterising the

Taurus Energy Response to Public Submissions Page 4 Cullerin Range Wind Farm 30 August 2006 background noise level at surrounding receivers for a variety of wind speeds. The regression analysis method determines the ‘best fit’ average of background noise level for the period of monitoring. This determines the allowable wind turbine noise level criteria.

13. Could you provide further information on what compensation/ mitigation measures are proposed/ will be available for residences which are predicted to/ will experience noise in excess of the criteria?

The proponent’s intent is to mitigate noise impacts to ensure compliance with guidelines rather than offer compensation after the fact.

In the event that Layout B is the preferred solution, further detailed noise monitoring will be carried out at Location C37 and Location C04 (see Noise Study for references) to confirm baseline conditions and the extent of any predicted non­compliance at these locations for Layout B. Any predicted non­ compliance would be mitigated through options including removal or relocation of turbines; adaptive management of turbines to switch off offending turbines during conditions which cause noise levels to be exceeded; or (with the approval of landowners) improvements to the building façade (e.g. double glazing of windows and other building treatments). Modelling has indicated that at the current assumed baseline condition at these two locations, switching off of wind turbines S1, S2, and S3 would be sufficient to ensure compliance under Layout B. (SoC 6, 7 and 8)

Compliance monitoring may be required to confirm wind turbine noise levels at surrounding residences where compliance with noise guidelines is predicted to be marginal. An adaptive management approach could be adopted if undue noise impact is identified.

Project involved residences which are identified as receiving WTG noise levels in excess of WHO limits may have suitable alternative upgraded glazing and ventilation. (SoC 6)

14. Will you be implementing an ongoing monitoring system at potentially affected properties to ensure that once the wind farm is operational, the noise levels at these properties can be checked to ensure they do not exceed the criteria?

Post commissioning operational compliance noise monitoring will be conducted to confirm wind turbine noise emission levels are in compliance with manufacturers specifications as used in the analysis.

15. What was the basis for deciding which residences to take background noise measurements at?

The basis for choosing residences for background monitoring was generally; ­ proximity to the proposed wind farm ­ representative exposure of other nearby properties ­ permission from landowners to conduct monitoring

Permission was not granted for all properties requested, however alternate properties were then selected which offered representative background noise level analysis.

16. Is it fair to only consider noise at the residences when activities on the properties often take place out­of­doors and along boundary fences?

The SA EPA Guideline states that “the property boundary of the receiving premises is not necessarily a valid measuring position (particularly for large rural properties) unless it is likely that someone would regularly be there or the development plan clearly envisages noise sensitive development at such a location”. Furthermore, typical farming activities taking place out­of doors and along boundary fences often include the use of mobile equipment (tractors, 4wd’s, motorbikes etc.) which are likely to produce far greater noise levels locally than that of wind turbines.

Similarly the NSW Industrial Noise Policy is only applied to particular noise sensitive receivers.

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Flora and Fauna

A number of general issues were raised in relation to both the process and results of the Biodiversity Assessment, summarised as follows. Further specific questions are also outlined below:

17. How will construction traffic be managed to ensure that animals such as swamp wallabies are not adversely affected by the proposal?

18. Will the lighting of the turbines at night be detrimental to many bat species as well as other nocturnal birds and animals?

19. How can the EA class the impact of collision by bats as a moderate risk when there has been no research into the size of the bat population in the area? This issue is particularly in relation to the Large Footed Myotis (incorrectly cited as the Long footed myotis in the EA).

20. Given the Large footed myotis has been found on the site, why didn’t the biodiversity assessment undertake further work to estimate the number of individuals or whether the population is a viable breeding population in order to determine the level of risk to the species posed by the development?

21. How will the bat population/ collision rates be monitored? For example, how will the survey times be decided? This issue also applies to other species that may be affected.

22. Will the development reduce the natural heritage value and further fragment small areas of remnant degraded Yellow Box Grassy Woodland EEC?

23. How has the biodiversity assessment come to the conclusion that wedge tail eagles are a “species at low density in the landscape” when there are at least two breeding pairs seen regularly in the area, with at least one nest located on a nearby property?

24. Given there are at least two breeding pairs of wedge tail eagles that live in the area, could you please provide further information on what impact the proposal will have on the local population of the wedge tail eagle?

25. How can the flora and fauna survey be considered to be a good indicator of the species known to occur in the area, particularly as the survey was done outside the migration period for many species? For example, it was noted that black swans do not migrate in November and hence were not counted in any survey.

26. One particular submission highlighted the Federal Government report relating to avian collisions which states that “..if a wind farm is situated in an area where a naturally high density of a bird species occurs, such as key breeding or feeding sties, then it is possible that mortalities due to collisions could create a location population ‘sink’ which could have widespread impacts on the species.” Wet Lagoon is a key breeding site for black swans and as such, the implications of the proposal on these birds should be further investigated

Construction traffic has the potential to impact fauna, and will be managed by way of a Traffic Management Plan and Construction Environmental Management Plan (SoCs 21 and 36). The aim of the former plan is to address safety as well as environmental emissions such as dust and noise. It is considered that education of involved personnel, use of designated tracks, and strict adherence to reduced speed limits will be sufficient to mitigate against the risk of collision with native fauna or stock. In addition, signage to warn other motorists of the works will assist by reducing last minute avoidance actions which may otherwise occur. Onsite, stock will be fenced out of construction areas (excluding roads). Vehicle collision with native fauna cannot be entirely prevented however, it is considered that the level of activity on the site during construction will also act to deter fauna such as wallabies from areas of collision risk, reducing the risk to an acceptable level.

As a safety precaution, wind turbines require obstacle marker beacons, as prescribed by the Civil Aviation Safety Authority (CASA), to reduce the risk of collision with aircraft. CASA draft guidelines for aviation warning lighting for a group of wind turbines require that sufficient wind turbines should have

Taurus Energy Response to Public Submissions Page 6 Cullerin Range Wind Farm 30 August 2006 red obstacle beacons to indicate the extent of the group. It is expected that 4 to 5 turbines in the proposed project would require aircraft warning.

The Biodiversity Assessment notes that:

“Lights on turbines may increase the probability of bat collisions, as insect abundance is higher under lights (Erickson et al. 2002). In the US, some warning lights on towers have been shown to attract migrating birds at night (Cochran and Graber 1958, cited in Canada Bird Studies 2001), possibly because they are used as references for navigation or because they attract insect prey. Kerlinger and Kerns (2003) found that red flashing lights did not attract night migrating birds and that turbines could have lower collision rates than other telecommunications and power infrastructure due to the absence of guy wires…” (p. 40).

Therefore, this risk is considered manageable by using low wattage, red, intermittent lighting and using the least number of lights required, as discussed in the Biodiversity Assessment, Attachment 3.4 of the EA.

The impact of collision by bats has generally been classified as a moderate risk. The level of impact predicted for species at risk was determined based on consideration of local records, habitat evaluation onsite and in the region, species ecology and the impact types generated by the proposal. For example, the Large­footed Myotis was considered to have a moderate degree of potential impact because it is known to occur in a drainage line east of the site and it may forage and migrate in groups.

For species considered to have a high or moderate level of potential impact, an Assessment of Significance in accordance with the NSW Threatened Species Conservation Act was completed to characterise the impacts in more detail in order to assist the Department of Environment and Conservation (DEC) to determine whether a significant impact may occur for these species. This Assessment of Significance is also known as the Seven­part Test and focuses on the potential to affect the viability of local populations.

For the Large­footed Myotis, an Assessment of Significance in accordance with the NSW Threatened Species Conservation Act was completed to characterise the impacts in more detail in order to assist the Department of Environment and Conservation (DEC) to determine whether a significant impact may occur for the species. This assessment found that the proposal was unlikely to generate a lifecycle impact and unlikely to generate a population level impact however, due to the lack of certainty a precautionary measure was suggested:

“Evidence from existing wind farms and species ecology suggests that the levels of collisions would not generate a population level impact however, uncertainty exists. Although this assessment does not anticipate a population level impact it recognises it as a risk that must be addressed. Rigorous and properly timed monitoring of collision impacts should be undertaken and protocols developed so that action can be taken if unacceptable levels of mortalities occur onsite.” Attachment 3.4 Biodiversity Assessment, Appendix D, p.30.

Because the risk was considered manageable, no further survey work was undertaken.

The details of the monitoring program in relation to bird and bat collision rates would be developed pending project approval. They would be developed with the explicit aim of quantifying collisions and avoiding a significant impact (refer to SoC 18). Development of the monitoring program is expected to be an extensive undertaking in consultation the DEC. Using standardised methods and making the results available upon request is considered advantageous in assisting other developments minimise their collision risks.

In relation the Endangered Ecological Community Yellow Box, Blakely’s Red Gum Woodland, a TCS Act Assessment of Significance concluded that unacceptable impact can be avoided through careful positioning of infrastructure and access routes and the adoption of standard weed and sediment erosion controls. In relation to fragmentation, it was noted in the Biodiversity Assessment that the proposal would not have this effect:

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“…since the vegetation will remain much as before the development over most of the site. The better quality examples of this EEC (although of only low­moderate conservation significance) can be avoided.” Attachment 3.4 Biodiversity Assessment, Appendix D, p.28.

In general, impacts on the Yellow Box, Blakely’s Red Gum Woodland EEC will be minimal on the ridge top and substation site, due to the degraded state of remnants in these areas. Better quality remnants occur onsite and access routes can be developed in consideration of this limitation.

In response to questions regarding the Wedge­tailed Eagles, these are a high order predator and therefore they occur at low density in the landscape, when compared for example to their prey species or species which congregate. This affects the type of impact the proposal is likely to have on them.

The ecology of local Wedge­tailed Eagles and the behaviour of populations in areas with wind farms were used to assess the potential impact to the local population. As the species occurs onsite and forages at the height of turbines, a moderate impact rating was determined. Evidence from other wind farms suggests this species can avoid turbines although a number of mortalities have occurred; these appear to be related to taking prey near turbines.

The assessment concluded:

“For raptors, the risk was related primarily to foraging activity. There is potential to reduce this risk by managing the availability of prey on the site. However, a risk remains that mortalities will occur and monitoring is required to ensure that mortality levels do not reach unacceptable levels without action being taken.” Attachment 3.4 Biodiversity Assessment, Appendix E, p.44.

Further information about the impacts of wind farms on this species is provided below. It is sourced from the Biodiversity Assessment of the Conroy’s Gap Wind farm, prepared by nghenvironmental in 2006:

Ecology Wedge­tailed Eagles are sedentary and widely distributed in a range of habitats. They are monogamous and apparently mate for life. If one bird of a pair is killed, the survivor will find a new mate. Established pairs defend breeding territories around their nest sites from other Wedge­tailed Eagles. Nest density varies with food supply but nests are usually 2.5­4 kilometres apart (Australian Museum 2003a). Home ranges around the breeding territories may be shared by two or more breeding pairs and by non­breeding birds (Australian Museum 2003a).

Wedge­tailed Eagles have a relatively slow reproductive rate, mating at an advanced age, raising few chicks and having long incubation (42­45 days) and chick dependency periods (12 weeks­1 year). Eagles begin breeding at 5 years, have a usual lifespan is 20­25 years and a reproductive lifetime of 15­20 years. A clutch usually consists of two eggs. A breeding pair usually rears only one young per clutch, although in a good year, two chicks may fledge (Australian Museum 2003a). During drought periods, eagles may not breed at all for several years. Monitoring of breeding pairs at Lake Burrendong (Central West NSW) in a post­ calicivirus environment showed an annual productivity of 1 chick per territory, with fledging success at 76% (Davey and Pech 2001).

Wedge­tailed Eagles feed on a range of small to medium sized fauna. In many areas, native prey, particularly kangaroo pouch young, have declined and eagles have become reliant on rabbits and carrion. They have been observed feeding after dark on a roadkill carcasse (Wren 2002).

Conservation status

Birds Australia surveys indicate that, Australia­wide, the Wedge­tailed Eagle has declined by 28% since the 1980s (Davey 2003). Some regions may produce

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regular eagle population surpluses (‘population sources’) which disperse to less productive regions (‘population sinks’) (Davey 2003). … The significance of (a) site to regional eagle populations hinges on whether the site forms part of a breeding territory, and hence contributes to the population source.

Bladestrike risks

Raptors appear to have no difficulty avoiding turbines when simply flying or soaring (Canada Bird Studies 2001), but when hunting may focus intensely on prey beyond the turbine without perceiving the rotor blades (Thelander et al. 2003). Raptor eyes do however have two foveal regions allowing focusing on the horizon as well as downwards (Hodos et al. 2001 in Canada Bird Studies 2001).

Available data from existing wind farms in south­eastern Australia show that large raptors have the capacity to avoid wind turbines, and have a relatively low frequency of collision. However, two Wedge­tailed Eagle mortalities at the Starfish Hill wind farm in South Australia and one at Woolnorth (Tasmania) indicate that collision is possible. Risks may be higher during the period immediately following the installation of the turbines, before local birds have habituated. Risks may also be higher for inexperienced, juvenile birds, and during periods of heavy rain, fog or low cloud.

Experiences at other wind farms suggest that local Wedge­tailed Eagles would become habituated to (a) wind farm over time. Resident Wedge­tailed Eagles have been observed to fly among turbines at wind farms at Codrington (Biosis Research Pty Ltd 2002, Wonthaggi EES Panel 2003) and Toora (Brett Lane and Associates 2005). A range of raptors continue to be present within one kilometre of the Crookwell I turbines (URS 2004). Wedge­tailed Eagles are also resident near the Woolnorth wind farm (Hydro Tasmania 2003).

At Codrington, Wedge­tailed Eagles were observed to avoid turbines by flying horizontally around them and turning and not entering the turbine area (Biosis Research 2002). Directly observed collision avoidance rates at this site have been documented as 100% (Meredith et al. 2002). The collision avoidance rate for the Tasmanian Wedge­tailed Eagle has been estimated to be 99% or higher (Biosis Research 2006).

Assuming breeding productivity of 1 chick/year and a conservative fledging success of 50% (accounting for drought years), a breeding pair of eagles (in the region) would produce an average of one additional bird every two years. Based on the low frequency of collision at these existing wind farm sites, it is considered unlikely that the … wind farm would result in bladestrike impacts that would significantly affect the local or regional eagle population, or reduce the value of the region as an eagle population source.

Questions were also raised regarding the appropriateness of the survey approach applied the flora and fauna assessment.

Because practicality dictates that some species will be missed during site assessment, no matter how rigorous, the methodology employed in the Biodiversity Assessment was to undertake a preliminary assessment of fauna habitat values and the likelihood of the presence of threatened fauna to be in the area based on species distribution records and known habitat requirements, prior to field work onsite. The results of previous fauna survey work in the region were also reviewed for threatened fauna records. Habitat requirements were drawn from a range of sources, including reference books, scientific papers and local research (including talking to locals during and after community consultation). Important regional habitats were also considered in a regional review (Biodiversity Assessment, Section 3).

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Survey work was then undertaken with a focus on threatened species; both state and federally listed species are considered. Survey effort was distributed among habitat types (open woodland, grassland, dams) and landscape positions (ridges, flats, gullies), being most intensive on the ridges that would be most impacted by the proposed works. A precautionary approach was adopted. If the ecology of a species suggests that it may occur onsite, even if it was not recorded nearby, it was considered further.

The Biodiversity Assessment is explicit about its limitations:

“The late spring timing of the fauna survey, and warm weather during the fieldwork, was favourable for recording frogs, reptiles and microchiropteran bats, as well as birds and mammals. Tall grass however, reduced the visibility of basking reptiles and ground birds. The limited duration and intensity of the survey may have resulted in the omission of some sparsely distributed, ephemeral or seasonal species. However, considering the quality and diversity of habitats at the site, the selected survey methods and intensity are considered appropriate to the assessment of the wind farm proposal. A precautionary approach has been adopted when evaluating the potential for species to utilise the site or where impact is uncertain.” Attachment 3.4 Biodiversity Assessment, p.21.

The possibility of local population sinks having a wider impact on a species is acknowledged. The extent of the impact hinges on the ability of individuals to avoid collision with turbines; this involves the morphology and behaviour of the species as well as the distribution of local and regional resources for the species and the arrangement of the turbines (most collisions occur with the end turbines demonstrating that a group or cluster are more easily recognised and avoided).

While the report focussed on threatened species, a general assessment of waterbirds (including migratory birds) was also included in the Biodiversity Assessment. Regional and local resources for waterbirds were considered, as was the arrangement of turbines, in assessing the impact of the proposal on bird life.

The key mitigation strategy for bird life centres on an adaptive monitoring program. While it is not anticipated from our investigations that unacceptable impact would result, such a monitoring program would safeguard against this risk.

27. Why wasn’t Wet Lagoon included in the biodiversity assessment for the proposal given it is a sanctuary of importance for water birds and without this assessment, the true impact of the wind farm on the local bird population could not be fully considered? (It has been suggested that Wet Lagoon is a permanent water body and not ephemeral as quoted in the EA.).

Because Wet Lagoon occurs near the site and is known to have high numbers of wetland species at times, it was visited during site assessments, considered in terms of the potential movement corridors of birds in the area and included in the regional review in the Biodiversity Assessment.

28. How did the biodiversity assessment determine the “possible flight paths for migratory birds” shown on page 38?

Possible bird movement corridors (Biodiversity Assessment Figure 5.2) occurring in the area were considered based on the distribution of resources for birds; riparian vegetation, wetlands (ephemeral or permanent), reasonably connected woodlands and the presence of larger resources (such as Lake George and Lake Bathurst).

29. On what basis was the statement “…it is not known to be a migration corridor for waterbirds or woodland species” in the biodiversity assessment, made?

In clarification of the statement, the author states that at the time of writing no information could be found by the author to indicate the site was a migration corridor. The beginning to the sentence acknowledges the paucity of available information.. ‘While little information is available pertaining to the seasonal and diurnal migration routes for bird species at the site…“. To address the lack of information, which is a recurring problem when assessing the impact of developments on rare species or in areas that have not been comprehensively surveyed in the past, a precautionary approach is adopted and other factors, such as other resident species, are considered.

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30. Black swans flock to the wet Lagoon each year from inland Australia (exactly where the proposed wind farm is located) travelling from west to east which is not shown in the Biodiversity Assessment. Why was this path excluded and what is the anticipated effect from the wind farm on bird movements between these area, that is, is there a collision risk between the birds and the turbines?

While considered, Black swans were not the focus of the assessment as it is not considered threatened. It is noted that it is a night migrating bird that would therefore be at higher risk of collision than birds that migrate by day. If this species migrates across the site, collision impacts may be present. It has been found however, that red flashing lights, as would be used on the site, do not attract night migrating birds and that turbines could have lower collision rates than other telecommunications and power infrastructure due to the absence of guy wires (Kerlinger and Kerns (2003) (refer to Attachment 3.4 Biodiversity Assessment, p. 40).

31. There are many straw­necked ibis’ flying in large flocks in the area which are good at eating insect pests. What impact would the turbines have on this population?

Straw­necked Ibis were not the focus of the assessment as it is not considered threatened. Ibis migrations have been noted in the assessment and no substantial impact is anticipated on ibis or insect numbers as a consequence of the development.

Visual Amenity

Some general and a number of specific issues were raised in respect to the visual Impact Assessment as follows:

32. How did the authors of the visual assessment report come to their conclusions about the way in which rural landowners perceive the landscape? Many submittors disagree strongly with the conclusions of the visual assessment report and note that many landholders have carried out extensive tree plantings on their properties to try and improve the landscape values of the area.

33. Why did the authors of the visual assessment report only consider the views from the house when looking at the impact of the proposal on these properties, especially as the owners utilise their entire farm for work and recreation, from which many of the turbines will always be visible?

Public perception of the landscape is an important component but only one element of the visual assessment methodology used in this report. The basis of the approach is outlined in Section 4 of the Visual Impact Assessment.

The assumptions of views of the landholder views of the landscape were developed from a number of sources including public consultation days, feed back forms, personal conversations and outcomes of previous visual assessments.

It is understandable that some landholders do not agree with the necessary generalisations about landscape values. Public perception takes in a whole range of views and any assumptions made about perception will not fit all those potentially affected. This is acknowledged in the Visual Impact Assessment on pages 21 and 22.

However, the conclusion was reached that, on the whole, landholders that earn an income from the land tend to have a pragmatic approach to the landscape and tend to value the landscape as a means of production mainly and any other values are secondary.

The landscape that can be seen today in the area has evolved through the activity of primary production, where landscape visual quality is a secondary consideration. Even current activities such as tree planting serves as much to improve the productivity of the land by way of providing shelter for stock and reducing wind impacts as much as it has a visual effect.

It should be noted that the report acknowledges (on page 22) that regardless of user type unscreened or unfiltered views from a house tend to be valued highly.

Taurus Energy Response to Public Submissions Page 11 Cullerin Range Wind Farm 30 August 2006

The Visual Impact Assessment did not only consider views from houses but rated views from houses as being more highly sensitive. In general, it is from the home that a person spends more time than other locations, is often relaxing, and has a stationary view the surrounding landscape.

Views to the turbines from other locations on properties are considered of a less sensitive nature and are generally experienced while conducting other activities, such as working, driving etc. For example, views of the turbines from the living room of a house have much greater impact than transient views from a road while travelling at speed.

34. Photo 18 is described as being a photomontage depicting the road between Collector and Breadalbane, however, it bears no resemblance to any part of that road.

(Department note: Upon further inspection, it is evident that this photo has been mislabelled when compared with the larger set of photomontages. Furthermore, the photo provided appears to be taken from the same location as Photo 20, although there appears to be more fenceline shown in the latter. Figure 7.9 of the Environmental Assessment also seems to have been mislabelled as view PM02. Given this apparent inaccuracy, the visual assessment must be re­evaluated to ensure that the appropriate viewshed was taken into consideration in the assessment. The location of each of the photomontages should be confirmed).

It is acknowledged that the incorrect photo was included in the Visual Impact Assessment (Photo 18) and EA (Figure 7.9). This photo has not been taken from the location stated, it is a cropped copy of photo 20 (Figure 7.11). Photomontage PM02 was taken from the road between Collector and Breadalbane, and should have been included in the Visual Impact Report as Photo 20, and the EA as Figure 7.9. Photomontage PM02 has been made available at public exhibition locations and on the Taurus Energy website (http://www.taurusenergy.com.au/CUL%20PM02%20Layout%20B.pdf), and is displayed here for completeness.

Photomontage PM02

The location of all photomontages taken are correct as indicated in Figure 7.2 of the EA..

The Visual Impact Assessment has been re­evaluated and is not affected in any way by this editing error, which occurred in final production of the reports. Appropriate viewsheds have been taken into account in the assessment.

35. The visual assessment states that some homesteads will have a screening of large exotic trees to reduce the impact of the wind farm. The visual assessment, however, fails to consider that many of the trees are deciduous and will offer little or no screening for several months of the year. The contrast to the existing landscape will be great. How will this be managed?

In many cases existing screening is provided by large pines and conifer trees which are evergreen. Even deciduous trees will disrupt the view to the wind towers making them less conspicuous, however it is acknowledged that this does not offer a complete screen.

It has been noted in the Visual Impact Assessment that where the wind towers dominate the view either all year round or part of the year (page 50):

‘Localised landscape treatment can assist greatly in reducing the visual impact of the wind farms from specific view points, particularly around houses. Placing vegetation carefully can allow key views out from a home while screening other less desirable views.’

Taurus Energy Response to Public Submissions Page 12 Cullerin Range Wind Farm 30 August 2006

The Visual Impact Assessment recommended that Taurus Energy make provision for landscaping material to landholders to screen views of the wind farm from houses or outdoor entertaining areas around the site (page 50).

Taurus Energy has committed to offer a screening program to highly affected residences (SoC2), this will include consideration of the level of existing screening available from deciduous or evergreen trees.

36. Several submissions raised concern about the impact of flicker vertigo and blade glint on motorists travelling on the Hume Highway and the distraction that these turbines will cause, particularly in the late summer months. The effect of shadow flicker on motorists has only been assessed to 1 kilometre, despite the DGRs requiring an assessment to 2 kilometres. Consequently, the impact of the proposal on road safety as a result of shadow flicker should be reassessed to at least 2 kilometres.

Shadow flicker has been assessed qualitatively to find that flicker is only an issue within 1km of turbines due to natural diffraction. Therefore, specific quantitative analysis was carried out within this impact zone to determine the number of hours of potential shadow flicker within 1km from a turbine. Shadow flicker would not extend to 2km from the site.

37. How were the photomontages put together? That is, please identify what camera and lenses were used and whether more that one photograph was stitched together to create the montage?

The photomontage process utilises digital representation of the wind farm and background photographs. The background photos were taken on a 35 mm digital SLR camera using a 50 mm lens. The 50 mm lens is generally held as being the "normal lens" on a 35 mm format camera as the combination delivers a natural perspective, that is a perspective that most represent that seen by the human eye.

For the photomontages at Cullerin, a series of background photos were taken in a panoramic fashion at each location. The photos were taken so that there was overlap on each photo to enable compiling of each component photo into a composite “stitched” panorama. These panorama photos were then used as the basis of the photomontage exercise. This method increases the resolution / clarity of the base photograph to allow it to be printed clearly at large sizes (e.g. the 2 metre wide images presented at the second open house).

38. What field of horizontal and vertical view do these montages represent, that is, do they truly approximate what the human eye can see?

The photomontages fairly represent what the human eye will see. The photomontages should be held at a distance from the eyes so that the actual horizontal angle of view to the photomontage matches the field of view noted in the table below. At this point the horizontal and vertical scale will approximate what the human eye can see.

The vertical view angle is truncated due to the landscape format of the image, this does not distort the image. In fact, if anything this effect is likely to increase the apparent size of the turbines.

The horizontal view angles of the photomontages are as follows:

Direction at Direction at Photomontage Field of View Direction of photo Left Hand Side Right Hand Side number of photo of photo PM01 75 deg 345 deg 308 deg 021 deg PM02 75 deg 297 deg 259 deg 334 deg PM03 75 deg 273 deg 235 deg 310 deg PM04 75 deg 274 deg 237 deg 312 deg PM05 75 deg 241 deg 204 deg 279 deg PM06 75 deg 128 deg 090 deg 165 deg PM07 75 deg 117 deg 080 deg 155 deg

Taurus Energy Response to Public Submissions Page 13 Cullerin Range Wind Farm 30 August 2006

PM08 68 deg 090 deg 056 deg 124 deg PM09 75 deg 069 deg 031 deg 106 deg PM10 64 deg 057 deg 025 deg 089 deg PM11 90 deg 230 deg 185 deg 275 deg

Note, all directions are to true north: North = 000 deg South = 180 deg East = 090 deg West = 270 deg

In viewing the photomontages the natural human response is to search for the wind turbines within the photomontage and then focus on these rather than taking in the whole image. However, this is not how the turbines would normally be viewed in the countryside, where the viewer appreciates the overall scene in front of them. Accordingly, the temptation to search for turbines in the photomontages should be avoided to truly approximate what the human eye sees.

39. What was the basis for selecting the photomontage locations? Do they provide a representative view from all sensitive locations noted in the visual assessment report (that is those with medium to high visual sensitivity)? If not, why hasn’t the visual assessment addressed this?

The photomontages provide representative coverage from key viewing areas, focussing on those areas likely to have a higher impact (e.g. directly East or West of the site where the majority of turbines would be visible).

The sites were carefully chosen by the authors as being views that represent a local area and have clear views of the wind farm. While photomontages have not been prepared at all locations with medium­high sensitivity, representative photographs are available to provide an indication of what the wind farm could look like from many different locations under various weather conditions.

For this reason, a number of different locations were selected which offered: ­ different viewing angles and distances ­ different levels of cloud cover ­ different provision of foreground / background focal objects (e.g. trees)

Input from the community as to which locations should be included was requested at the first Open House, where the community was invited to mark key locations on topographic maps of the area. Final locations for photomontages were based on this feedback.

40. Are any mitigation/ compensation measures proposed for those residences where the visual impact is predicted to be medium to high?

The EA recognises that, while the perception of the look of a wind farm is a subjective experience and therefore varies from person to person, distance from the wind farm and the exposure of the house to a view of the wind farm can be used to classify the impact level. The sensitivity of areas with a view of the wind farm was also considered in the Visual Assessment. The Visual Assessment identified that properties within Areas 8, 9, 10 and 17 (refer to Figure 7.1 of the EA) may be exposed to moderate to high visual impact. Houses in these areas with a direct view of the site (from the house or outdoor entertaining area) could be highly impacted.

The proponent has committed to offering screening by way of tree planting to all residences within 2km of a wind turbine and to other residences in areas 8, 9, 10 and 17 at their request (SoC 2). This process would be carried out by the proponent individually with each land owner in order that the screening is appropriate to the impact and to the property. It would be carried out within 3 months of the construction phase completion. The proponent would keep a record of the liaison and would aim to achieve agreement with the majority of these landholders.

As the proponent intends to mitigate these impacts compensation is not appropriate.

Taurus Energy Response to Public Submissions Page 14 Cullerin Range Wind Farm 30 August 2006

Heritage

41. A number of properties in the area are listed on the Register of the National Estate, however, the EA did not recognise this. The visual assessment should be updated to adequately take into consideration the heritage values of these properties when determining the degree of impact from the proposal.

The EA identified that heritage registers relevant to the proposal exist at the Commonwealth, state and local level. A summary of heritage listings is presented in Table 8.8 of the EA. This includes 18 items on the Register of the National Estate.

Within 30km of the Cullerin site proposed for the wind farm, five sites occur that have been registered on the Commonwealth National Estate Register as historic items (EPBC Act Protected Matters Report generated 3 January 2006):

1. Collingwood Homestead, 5km north­east of Gunning (~12km north­west of site);

2. Frankfield Homestead Group, 6km east­south­east of Gunning (~6km west of site);

3. St James Chapel on Kippilaw, 12km west of Goulburn (~19km east of site);

4. Tirranna Garden Farm Complex and Cemetery, 7km south­south­west of Goulburn (~27km east of site); and

5. Wollogorang Garden, 7km south­east of Breadalbane (~15km east of site).

(Source: Matters of National Environmental Significance search tool).

The impact of the wind farm on these items was assessed in accordance with the NSW Heritage Council’s eight points outlining the potential impacts of wind farms on heritage items. Several mitigation measures were considered necessary to properly address the impact on heritage features, including the visual component. The following commitments were given by the proponent, pending the approval of the wind farm (SoC 40):

1. Inform the Upper Lachlan Shire Council and NSW Heritage Council regarding the proximity of final access routes to listed heritage items.

2. Implementation of a Traffic Management Plan to define appropriate access routes and measures needed to ensure that the additional traffic load required during construction and decommissioning does not adversely affect buildings nearby as well as road infrastructure.

3. Visual impact mitigation, as stated in Section 7.2 of the EA.

42. How will the heritage value of “Frankfield” be protected as the wind farm will be visible from some or possibly all the heritage listed buildings on the property, including the homestead, coach house and stables, stone shearers hut, old slab and shingle kitchen and bath house?

With particular reference to “Frankfield”, one of the listed properties, it is located in Area 12 (determined by the Visual Assessment) and is more than 5km from the wind farm. As such, it is considered by the Visual Assessment to have a low to moderate visual impact. The Assessment notes that: “The landscape is a modified farming landscape and is not overly sensitive to change” (EA p.108). Photomontage 9 from the Visual Assessment gives an indication of the likely view of the proposal near this location; all turbines are visible but are relatively small.

43. How will the heritage significance of the Lerida Ranges landscape be affected by the proposal?

The impact of the proposal on the general heritage appeal of the area (including the Lerida Ranges) was considered in Section 7.7.2 of the EA. It was considered that “the development is not incongruous with the production­based economy of the area and is not situated near formalised nature­based recreation activities. The close proximity of the site to existing infrastructure, including the Hume

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Highway and electricity easements, suggests that its placement is not inconsistent with visitors’ experiences of the character of the area.” (EA p.8).

Financial/ Land Values

A number of issues were raised in relation to the process and results of the Land Value Impact Assessment, summarised as follows:

44. How can the land impact report be considered a useful assessment of the likely impact of this wind farm on the Cullerin area when the report provided in the assessment looked at a wind farm that was of a different size and scale and also looked at the property prices of large working farms rather than lifestyle blocks (of which there are a number in the Cullerin area)?

45. Can the proponent instead provide a report which compares the property prices of hobby farms located with a direct line of sight to similar sized wind farms to that proposed, or provide estimates made by professionals?

46. The land value assessment was not considered to be a quantitative study but rather a collection of thoughts. Why were relative increases in rural land not compared with the whole Sydney 3­hour catchment area and why weren’t other driving factors behind land value increases considered in the assessment such as the “lifestyle factor”?

One submission stated that the value of land is no longer primarily based on grazing or farming value but now includes a substantial “lifestyle” factor. For example, property prices under the power lines built for the Snowy­Hydro is considerably less than land further away and suggests that prices at Collector are greatly in excess of their farming value. So whilst some landholders will benefit from rent, the people around will suffer the detriment with no benefit.

There have been limited case studies on the financial impact of wind farms. Therefore, all examples will have features which differ from the proposal at Cullerin or other limitations (for example largely qualitative studies are open to intense scrutiny). The land value study conducted at Crookwell as a part of the EA is considered useful because it looks at an existing wind farm in the region. This means land use practices and cultural factors will be similar and, as it has been operating for several years, perceptions and experiences of the wind farm are a clearer reflection of impacts than speculative impact assessment. The drawbacks of this example are the smaller scale of the existing wind farm.

The EA noted that: ‘Land values are influenced by prevailing and permitted land uses, economic conditions, access and proximity to markets and workplaces, demand for lifestyle as well as a range of other factors”. Land uses including demand for lifestyle blocks were discussed in the EA (Section 7.4.3).

Both the existing Crookwell wind farm and the proposed wind farm at Cullerin have the issue of hobby farms becoming more popular than extensive agricultural practices. The Crookwell land value report was commissioned by a professional in the local valuation industry. The report combines perceptions with hard data on prices, which was considered appropriate for the task.

The Crookwell land value report was prepared by a professional in the NSW valuation industry. The report combines perceptions of an expert with hard data on prices over a 15 year period, which was considered appropriate for the task.

Properties investigated were those that surround the development and have some direct impact from a valuation perspective; principally aesthetic influences including, visual, noise and shadow effects. These sales are deemed ‘effected’ sales, the hypotheses being these sales had been influenced by the development of the wind farm. A control group of sales in the same location with little or no physical and visual link to the Wind Farm formed the ‘not effected’ sales. The ‘effected’ and ‘non effected’ sales were compared over time to determine whether a correlation existed between the Wind farm development and land value movements.

Market evidence suggested that having a view of the wind turbines did not have an effect on land value.

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47. How will the proposal affect the ability of nearby properties such as “Waiontha” to train horses, particularly as the turbines will be noisy and will cause shadow flicker, which will affect the horses and therefore, the financial viability of the property?

Impacts to horses were discussed in Section 7.7.1 of the EA. The proposal is not considered to impact on the practice of training horses or the viability of the property for this purpose, based on this assessment. Accordingly, there is no impact on the financial viability of the property in relation to training of horses.

48. How will adjoining landowner’s rights to subdivide their land and build close to the boundary be affected by the wind farm proposal?

The rights of land owners adjoining the proposal will not be affected by the proposal. These land owners are still entitled to construct and subdivide their land subject to local planning instruments. Future residences close to the wind farm may be impacted by noise, however this can be addressed with materials and design that reduce acoustic impacts from wind farms and the adjacent highway, together with appropriate location and orientation of the house.

Energy Offsets/ Output

49. A number of submissions stated that they could not see the point of wind farms as they will contribute only a minor amount to the grid and will not result in the closing down of any other power stations. Can you further substantiate the benefits of wind farms?

The benefits of wind farms are discussed in Section 4 of the EA.

The proposed wind farm would represent a renewable, non­greenhouse gas producing method of electricity generation to meet increasing electricity demand. Every Megawatt­hour of electricity generated by the wind farm will prevent one Megawatt­hour of electricity being generated at a coal fired power station, and prevent additional energy losses within the electricity transmission system.

Each wind farm will result in less fuel being burnt in coal­fired power stations, and therefore will result in lower greenhouse gas emissions; lower water use; and lower levels of other pollutants being released to the atmosphere.

A single wind farm will not result in the closing down of any existing power stations. However, NSW needs more power generation to meet growing demand. A combination of wind farms, low emission power generators, and energy efficient technologies to reduce demand growth could help defer the construction of new coal­fired or nuclear power generators.

Wind farms are currently the cheapest form of zero emission power generation. Accordingly, as we try to reduce the significant environmental impact of existing power stations, wind farms are an essential part of the electricity generation mix going forward.

The energy production of the proposed Cullerin Range Wind Farm is estimated to be 85,000 to 95,000 Megawatt­hours. This is a significant output, providing sufficient energy in a typical year to power approximately 10,900 to 12,200 average NSW homes.

50. How has the stated capacity of 35% efficiency been calculated for this site? For example, it has been shown in other localities that the efficiency of wind farms is only 11­13%? Is the proponent able to provide real data for wind farms located in a similar environment to Cullerin?

The calculation of energy output and capacity factor has been discussed in Section 4.5.1 of the EA.

The energy production calculations for the Cullerin Range Wind Farm have been based on wind speeds measured at the site; on turbines likely to be used at the site’ and on operating conditions likely to occur at the site. Good energy calculations are essential for the developers in being able to provide a commercial return for the project, if energy production is less than expected then revenues will also be less than expected which is not in the developer’s interest. Therefore the energy calculations are carried out in a way which maximises their reliability and builds in a level of conservatism to ensure that the estimates are likely to be exceeded.

Taurus Energy Response to Public Submissions Page 17 Cullerin Range Wind Farm 30 August 2006

The wind turbines at the Cullerin Range site are expected to have a capacity factor (or utilisation factor) of around 35%, calculated from the estimated energy production of 85,000 to 95,000 Megawatt­hours per annum.

It is not reasonable to compare the likely energy output of Cullerin Range Wind Farm with energy outputs of wind farms at other locations. These locations will have different wind regimes, different topographic features; different wind turbines, different transmission constraints and different operating conditions; and different market conditions. To suggest each wind farm will have the same output is like suggesting that each car on the road will drive the same number of kilometres or use the same amount of fuel each year.

As an example, in Germany wind turbines have been installed in very low wind speed locations because the wind farms are paid more for their output in less windy areas to ensure that they are commercially viable even with this lower energy production level.

Taurus Energy does not have real operating data available for existing wind farms such as Blayney Wind Farm or Crookwell Wind Farm as this data is confidential to the owners of those wind farms.

51. Many submissions contend that despite best efforts, they have been unable to find evidence to prove that wind energy is a reliable and efficient form of electricity production. Could the proponent provide such information?

The “efficiency” of a wind turbine can be calculated by dividing the instantaneous power output at a set wind speed by the power available in the wind at that wind speed. The power available in the wind is determined by the wind speed, air density, and cross­sectional area of the wind turbine. Modern wind turbines under consideration for the Cullerin Range Wind Farm have maximum power efficiencies of 42 ­ 46% which generally occur when the wind speeds are in the mid range (7 to 10 metres per second). This means that under these wind conditions 42­46% of the power available in the wind is converted into electrical power output from the wind turbine.

The average wind speed at most wind farms in Australia is around 7.0 to 8.5 metres per second, around the point of maximum efficiency for modern wind turbines.

This is compared with NSW coal fired power stations which have average fuel efficiencies of around 35%. This figure excludes the coal lost and energy used in mining, which means a significantly lower overall efficiency for a coal fired power station.

The “reliability” of wind turbines (and other types of electricity generators) is accurately described by their availability factor. The availability is the proportion of the time that the wind turbine is available to operate. Modern wind turbines are sold with availability guarantees of around 95­98% (depending on manufacturer), this means that the manufacturers warrant that the turbines are able to operate for at least 95 – 97% of the time, including their scheduled maintenance. This is a very high level of reliability for industrial plant of this type. Confidentiality provisions prevent Taurus Energy from releasing the specific supply terms offered by any particular wind turbine manufacturer.

Wind farms now supply around 60,000 Megawatts of electricity around the world, this more than the combined capacity of all installed power generation in Australia.

The UK Government Department of Trade and Industry (DTI) has published a useful summary of the terms used to describe the performance of wind turbines (“Efficiency and Performance, Wind Energy Fact Sheet 14”, 31 March 2005, available free of charge at http://www.dti.gov.uk/files/file17821.pdf?pubpdfdload=05%2F995). This short paper also summarises average capacity factors in the UK based on measured data from a large number of wind turbines over the four years 1997­2000. The data indicates average capacity factors in the range 28% ­ 38%. The DTI also indicates that “most new wind farms have availabilities of 97 ­ 99%”.

Health Impacts

52. A few submissions noted that a number of studies have demonstrated that the reverberating “throb­throb” noise of wind turbines has health impacts on neighbours up to 2 kilometres from the wind farm, particularly under temperature inversion conditions (van den Berg effect). As several

Taurus Energy Response to Public Submissions Page 18 Cullerin Range Wind Farm 30 August 2006

homes are located within 2 kilometres of the turbines, they could therefore be subject to such negative impacts. How does the proponent plan to address this issue?

It should be noted that the measurements and anecdotal studies conducted by G.P. van den Berg relate to wind farms in northern Europe which are located in ostensibly flat regions, where wind turbines operate closer to the ground boundary layer and are therefore at subject to greater variations in wind gradient etc. due to atmospheric stability. The wind turbines proposed for Cullerin Range are elevated with respect to surrounding land and one would speculate that wind gradient effects would therefore not be as pronounced

The noise emissions from the project have been assessed using the SA EPA Guideline which has a core objective of ensuring that the amenity of a surrounding community is protected from adverse noise impacts. The conditions applied for all residences are based around amenity, any compliance with these amenity conditions are well within any necessary health limits.

Furthermore, all residences are predicted to be within World Health Organisation (WHO) limits.

Earthquake Zone/ Ground Stability

A number of responses raised issues in relation to geotechnical issues, including the fact that the Cullerin area is an earthquake zone which includes a number of old mine shafts:

53. A number of submissions noted that the Cullerin area is earthquake prone. The Environmental Assessment should be updated to address this serious issue. For example, can the turbines/ foundations be designed to ensure that they won’t collapse in an earthquake?

54. Several submissions also noted that the area is riddled with old gold mine shafts which, coupled with earthquake potential, could create highly unstable ground and potential for significant impacts. A few submissions also contend that the RTA originally proposed for the Hume Highway to cross the Cullerin Range, however, owing to the location of old mines, altered the route. What effect will the presence of gold mines have on the siting of the turbines? How will the proponent be sure that they are not constructing a turbine over an abandoned shaft?

55. How will the proponent manage potential mercury and cyanide leakage or other unknown hazards resulting from the mining practices in the 1800s during construction of the wind farm?

Engineering design of the wind turbine and turbine footings ensure that they can be built in earthquake zones. The key elements in the design of turbines are in the foundations (both the foundation design and the geotechnical assessment of the surrounding ground) and the tower. The flexibility of blades, together with the dampening of any effect by the tower, tends to mitigate against impacts on blades.

Both the turbine tower and the turbine footings will be designed by a suitably qualified engineering firm, taking into consideration the potential for earthquakes on site.

A geotechnical investigation will be carried out prior to construction to confirm that the ground is sufficiently stable to allow safe construction of the wind farm. The turbine foundations will be designed in accordance with all Australian standards, and certified by a practising Australian structural engineer, taking into account the risk of earthquake.

There are no known mine shafts affecting the ridgeline where the wind turbines or substation will be located. While it has been suggested that the RTA relocated the Hume Highway route to avoid mine shafts, it is likely that this route (and the mine shafts referred to) was proposed in the valleys off the main ridge, no turbines are located in this area.

The proponent will continue to liaise with the landowners involved, the local community and RTA to determine whether any known mineshafts exist.

To further ensure the structural integrity of the wind turbines, a geotechnical investigation will be carried out prior to construction to confirm that the ground is sufficiently stable to allow safe construction of the wind farm. This investigation will be required to detect any shafts likely to impact turbine foundations.

Taurus Energy Response to Public Submissions Page 19 Cullerin Range Wind Farm 30 August 2006

There are no known mine shafts affecting the ridgeline where the wind turbines or substation will be located, and there are no known mercury or cyanide hazards on this site. . The proponent will continue to liaise with the landowners involved and the local community to identify any such hazards. Any hazards identified during final design, construction, or operation of this site would be managed in accordance with industry best practice and all relevant government guidelines and legislation.

Bushfire Potential

56. How is the rural fire service supposed to deal with potential wind turbine fires when they have not been trained, nor do they have the equipment to deal with this type of fire? For example, the turbines are too high for any hoses to reach. There is considerable concern that the fire which occurred at Lake Bonney, SA in January 2006 could happen at Cullerin.

57. How would fires occurring at night be managed?

Bushfire potential was considered a key issue in the assessment process. Representatives from the RFS (Peter Dyce & Tim Street, RFS Southern Tablelands Zone, Yass) were invited to the Planning Focus Meeting, to ensure that this issue was properly considered.

The key issues identified by these representatives were:

­ access to the site in the event of a fire

­ potential for containment lines

­ potential for the substation to start a fire, and

­ activities such as hot welding in fire danger periods.

The proponent contacted turbine manufacturers to discuss fire suppression. Automatic fire suppression systems are not proposed within the wind turbines due to the low likelihood of occurrence, and the hazard to maintenance staff from automatic systems if a fire did occur. Manual fire extinguishers are available both in the nacelle and in the base of each wind turbine, as well as at the substation location.

In the case of a grass fire at the Cullerin site, one or more local units of the RFS would be deployed. The closest local units are at Parkesbourne, Cullerin and Gunning.

In the case of a fire related to the substation or a wind turbine (due to electricity and oil hazards respectively), the Fire Brigade would be deployed with the RFS acting in a support capacity. The Fire Brigade unit or units to respond depend on a decision made in Wollongong. They decide on the most appropriate vehicle / unit for the situation. The closest Fire Brigade units are Goulburn, Yass and Crookwell. It is possible that up to 5 units would be deployed. They respond on a '000' basis, which has a 5­7 minute response time. From Goulburn, this amounts to 15­20 minute response time to site. The RFS would also be deployed in a support capacity, closest units indicated above. (pers.comm. P. Dyce RFS Yass, 28 August 2006).

It was also noted early in the assessment process that fire fighting would rely on local RFS volunteers, who have no experience in fighting fires in the vicinity of wind farms. These volunteers would be acting in a support capacity to the NSW Fire Brigade in the event of a wind turbine or substation fire (due to the presence of potentially hazardous materials).

The RFS representatives commented that the development was not substantially different to other infrastructure risks in the area and therefore they held no large concerns over the issue from a bushfire risk perspective. The representatives also stated that the chances of a turbine catching on fire were very very small. (pers.comm. P. Dyce RFS Yass, 28 August 2006).

Overseas experience suggests that the turbine itself would in most cases be allowed to burn out due to the potential hazard to fire crews in attempting to extinguish a blaze within the turbine. Accordingly, management is likely to involve containment of grass fires triggered by a turbine blaze.

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The EA details measures to deal with the unique bushfire hazards presented by the proposal, including the inexperience of fire fighters in fighting fires near wind farms (Section 7.9). Mitigation measures to address identified risks have been included in the EA Draft Statement of Commitments (SoC 29). In particular, a set of protocols will be developed in consultation with the Rural Fire Service in regard to bushfire prevention measures to be implemented onsite during construction, operation and decommissioning phases. These measures will cover response protocols as well as hot­work procedures, asset protection zones, safety, communication and site access.

To ensure that these measures are satisfactory, they would be developed in consultation with the RFS, before the construction phase. Written endorsement of these procedures would be sought from the RFS and submitted to DoP, before the commencement of the construction phase. Auditing would occur as part of the Project Environmental Management Plan.

The set of response protocols developed in consultation with the Rural Fire Service will include protocols related to fires at night. Any fires occurring at night will be managed in accordance with these protocols.

The lack of detail in the specifics of these protocols is a feature of the stage of the planning process. Only upon project approval would these issues be decided with the RFS. To do so earlier would potentially be a waste of the RFS’s and the proponent’s time . The safeguard to this initial lack of detail is the commitment of the proponent to consult with the RFS and obtain written endorsement of the measures from the RFS and DoP.

It should be noted that while turbine fires can occur, they are a relatively rare occurrence. Only a small number of turbine fires have occurred in the more than 40,000 wind turbines currently installed world wide.

Impact on Aircraft

58. Several submissions noted that there is an airstrip on the Waiontha property that is used mainly by light aircraft for surveying stock and property and for recreation. These submissions raised concern that the presence of the turbines, particularly during adverse weather conditions, would be hazardous and pose a greater risk of collision. Concern was also expressed about the ability of aircraft to take off to the west as the proximity of the turbines would reduce the aircraft’s clearance over the Range. How does the proponent plan addressing this issue?

Wind turbines are highly visible to pilots during day time flying, and visibility of the turbines will be enhanced at night and during adverse flying conditions by incorporating obstacle marker beacons to the requirements of the Civil Aviation Safety Authority (CASA). All requirements of AirServices Australia and CASA will be met by the proponent. The proponent will provide final turbine location details to these organisations and the Royal Australian Air Force prior to construction to allow the turbines to be marked on aeronautical maps.

A local resident has indicated the airstrip is located in an area to the north­east of the “Waiontha” homestead between the homestead and the road. Taurus Energy has endeavoured to identify the airstrip on the Waiontha property and contacted the landowners of this property in this regard. To date the location or landing frequency of the airstrip has not been confirmed by the landowners.

The likely airstrip location is elevated at approx 714m asl. The nearest (northern most) turbine will be located at an elevation of approximately 828m asl and at a distance of approximately 600m to the south and 2360m to the west of the airstrip. The turbine height of up to 126m would place the turbine tip at a height of 954m asl or 240m above the elevation of the airstrip at a distance (direct line of sight) of approximately 2435m. The wind farm would occupy a field of view of approximately 45 degrees from South­South­West to West­South­West of the assumed runway location.

The turbines are located well to the south of the airstrip, with no obstacles to the north of the northern­ most turbine other than the existing range. In fact, there is a break in the range to the north of this turbine which would provide good clearance for take­off to the west. Only a limited potential flight path area would be affected by takeoffs and landings, at a significant distance from the airstrip. The proponent has mitigated the potential hazard to aircraft through the commitment to install obstacle marker beacons to the requirements of CASA.

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The small aircraft that could use the airstrip rely on visual rather than instrument based landings and therefore as the turbines are clearly visible structures there is not expected to be any safety risk due to their presence.

Accordingly, the presence of the wind farm is unlikely to have any effect on the use of the “Waiontha” airstrip.

Film and Television

59. Several submissions note that the many historic towns and villages of the Cullerin region are drawcards for film and television production. These submissions raise concern that this will no longer continue in the Cullerin area as the wind farms will restrict the ability to film in any given direction and will spoil the view. The wind farm will destroy the filming and tourism opportunities for the area.

The site proposed for development and the general area have an agricultural look and historic appeal that attracts tourism. It is noted that several public submissions to the Department of Planning have highlighted these features also act as drawcard for film and television production. The impact of the development on the film industry was investigated in consultation with the Film and Television Office (FTO) and Screen ACT. The FTO is the NSW agency that has prime responsibility for facilitating film production in NSW and helps producers identify suitable locations within the State for filming. Robert Pickles is the Screen ACT Regional Production Liaison Officer, promoting the Capital Region, from the southern tablelands to the south coast, for film opportunities.

Impact types are considered to include visual and noise issues for any film crews in the locality during the construction phase and be purely visual during the operational phase. Construction impacts would be temporary and the likelihood of them coinciding with filming nearby is anticipated to be low. The impact of the proposal on the visual aspects of the area have been considered within the EA, Section 7.2. To understand the visual impact of the proposed wind farm on the visual catchment, a zone of visual impact model was constructed and photomontages were constructed for different view of the site. This gives an idea of the areas that would be impacted and the type of visual impact that would occur. Based on this modelling, it is considered that areas greater than 10 km from the site would not perceive the wind farm while areas within 5 km and 2 km could have moderate to high visibility of the wind farm, depending on the location, topography and existing screens, such as vegetation.

The Crookwell wind farm site is promoted by Screen ACT, as would the Cullerin wind farm if developed, to film suitable pieces. Contemporary films or films featuring wind farms would be appropriate.

Gunning was used recently to film a movie, its main street and buildings and close proximity to Sydney were the drawcards (pers. comm. R. Pickles, Screen ACT, August 18 2006). These would be unaffected by the proposed wind farm which could not generally be seen from the main street.

For period pieces, many towns in the region provide filming opportunities and the presence of a wind farm on the horizon may influence the decision to film there, should they be visible. The wind farms could be removed in post production for less expense than powerline removal (which is required for all period pieces set in modern towns), however, this additional expense may affect the decision to film in the area (pers. comm. R. Pickles, Screen ACT, August 18 2006).

Wind turbines will occupy a constrained area of the horizon, and it is likely that film directors will be able to avoid filming the turbines if this is their desire. It should be noted that the presence of the turbines may also add an additional feature for film directors, and it is therefore equally likely that film and tourism opportunities in the area will be increased.

Crown Roads

60. A submission received noted that there are a number of Crown roads which bisect the subject site, however, the EA does not recognise these or the possible implications that the proposed wind farm will have on these, particularly public safety. According to the figures provided in the EA, at least two turbines and part of the access roads appear to be sited over Crown roads (see

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particularly Figure 3.12 of the EA). This issue requires further consideration and where relevant, consultation with the Department of Lands.

Crown roads are present in areas that would be impacted by the proposal. This includes a paper road with existing farm track, approximately 700m long on the ridge top. Proposed impacts here include two turbines near the easement under both layout options A or B, upgrade of the access road and installation of underground cabling. No turbines are proposed within the Crown road easement area.

A section of Lerida Road North is also a crown road, west of lots 65, 66, 67 in DP 750031. Proposal impacts in this area would include discrete areas of road upgrade and potential tree lopping.

John Daunt (Principal Lands Officer, Dept. Lands, Goulburn office) was consulted to ensure issues affecting the crown roads have been properly considered. He notes that:

“Generally the construction of carriageways on Crown roads is not encouraged because of maintenance issues and the possibility of erosion. The Department is a roads authority in terms of the Roads Act 1993 but is not a road construction authority... Therefore the Department has no plans to develop any of these Crown roads however in certain circumstances such as the Cullerin Wind Farm project, or when Crown roads are required for access and there is no alternative, construction can be authorised provided that there is DA approval. Crown roads are public roads and public access along them in their natural state cannot be denied.” (pers. comm. J. Daunt, Dept. Lands 11 Aug 2006).

If the proposal is approved, a license would then be sought through the Department of Lands under the Roads Act, to upgrade the tracks and Lerida Road, where required, and to place underground cabling across the easement, as described in the EA (Section 3.2). All underground works including cabling would be left insitu at the completion of the project to reduce erosion hazards.

For clarification, it is noted that the temporary concrete batch plant would be located off the southern end of Lerida Road North and that this road was dedicated as a public road in 1998. A Traffic Management Plan and Construction Environmental Management Plan would address safety risks during the operation of the plant. This site would be restored at the end of the construction phase.

It is further noted that the upgrade of tracks would not increase the accessibility of crown roads to the public; the upgrades to the ridge are linked to Lerida Road via a private track not a crown road. This is an advantage to the Department of Lands, as issues of crown road track maintenance and erosion become less important with decreased public accessibility (pers. comm. J. Daunt, Dept. Lands 10 Aug 2006).

Upper Lachlan DCP

61. The proponent should provide further justification as to why the development is not in accordance with the Upper Lachlan DCP on wind farms, particularly the issue of proximity of turbines to residences. A number of submissions highlight there are 4 non­involved houses within 2 kilometres of the wind farm.

The Upper Lachlan Shire Council Wind Power Generation Development Control Plan (DCP) was adopted on 22nd September 2005. Although the scale of the development (in excess of $30 million capital investment) has determined that the proposal would be assessed by the Minister for Planning, during the consultation process, Upper Lachlan Shire Council expressed interest in seeing how the proposal fits within the recommendations of the DCP. Table 5.1 of the EA refers the reader to relevant sections of the EA that deal with issues in the DCP.

The proposal does not meet several items suggested in the DCP. The most significant is considered to be the proposed location of turbines within 2km of premises (specifically, Illawambra and Faybri, refer to Table 5.2 of the EA for distances). The visual and noise assessments have provided mitigation measures that aim to reduce the level of impact at these premises to an acceptable level however, additionally, the proponent would commit to working with the owners of these premises to ensure that the mitigation of impacts is acceptable to them.

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The remaining items and reasons for non compliance are provided below. Items related to roads would be addressed further into the planning process. If approved, additional investigations would occur as required by RTA and DoP.

DCP requirement Proponent’s commitment Locate the development more than 15 times the Four non­involved premises are located within 2km of a blade tip height (1.89km for this proposal) or 2km turbine, two of these are residences. As discussed above, (whichever is greater) from any lot that has been the proponent would commit to working with the owners of created for the purpose of a dwelling (or greater Illawambra and Faybri, to ensure that the mitigation of where the turbines will be significantly higher than impacts is acceptable to them. Sections 7.2 and 7.3 of the such properties and will dominate the view). EA assessed visual and noise impact from nearby properties. Refer to SoC 7 for commitments. Substantial investigations into the roads chosen A preliminary investigation has been completed (Section should be undertaken (ARRB and gypsy camera). 7.8.1). Additional investigations would occur as required by RTA and DoP (refer to Section 9.1). Bonds required for any potential damage to roads A preliminary investigation has been completed (Section during the construction phase, road works required 7.8.1). Additional investigations would occur as required for the development will be at the developers cost. by RTA and DoP. Council prefers to have a viewing area where safe A viewing platform may not be acceptable to the local vehicle and pedestrian movements can view the community. It is therefore not part of the proposal at this wind farm in a safe manner; the developer should stage. Further investigation could occur, if approved, to liaise with council and RTA. gauge the appropriateness of this option. Within six months of the wind turbine generators Within 12 months of wind turbines becoming redundant, becoming redundant, they are to be fully they would be removed and the site restored, Section dismantled and removed from the site by the 7.11. The scale of the removal process dictates this is a developer. more feasible time period.

Strategic Approach/ Cumulative Impacts

62. How does the proposal fit within the Sydney to Canberra Corridor in so far as the “rural residential (lifestyle) opportunities” promoted by the Strategy are concerned?

The NSW Government Metropolitan Strategy has been developed to plan for growth in the Greater Metropolitan Region (GMR). Concerning areas outside the GMR, promotional material for the strategy states that:

“The Sydney to Canberra corridor is strongly influenced by growth and change in the Sydney region and Illawarra. The growth of Sydney and the economic connections between Sydney and Canberra are being felt by communities along the Sydney­Canberra corridor, in particular in the Southern Highlands which is growing strongly with many people commuting to Sydney.”

A draft Sydney to Canberra Corridor Regional Strategy is still being prepared. Release of the draft is pending the findings of an inquiry into Queanbeyan residential land development. Community consultation has been conducted but no printed material has yet been made public. The document at this stage is said to be in favour of green energy and recognises wind farms as a legitimate land use activity within the corridor (pers. comm. N. Sargent, Manager Planning, Murray Murrumbidgee Region).

Properties Not Assessed

A number of questions were raised in respect of specific properties which were considered to be inadequately addressed or not addressed at all, as follows:

63. A number of occupied residences appear to have been overlooked in the assessment of the proposal. These include: “Colletts” which is situated on the Breadalbane/ Collector Road between the Wet Lagoon and “Bohara”; “Cullerin” which is situated by the railway near the junction of Old Sydney Road and the Old Hume Highway, approximately 2 kilometres west of the Cullerin Range. Further assessment is required to address the potential impacts of the proposal on these properties, particularly noise and visual impacts.

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64. “Dairy Flat” on Collector Road was not addressed in the noise assessment, despite it being located approximately 5 kilometres from the proposed site with a direct line of site to the turbines. The noise predictions at this property should be provided or justification as to why it was not done.

65. The visual impact of the proposal on the cottage at “Bohara” does not appear to have been taken into consideration. Further assessment of the potential impact is required.

Both noise and visual impacts have been assessed for all known properties in the vicinity, identified from site visits and topographic maps of the area. In addition to the receiver­specific analysis, botb the visual assessment noise assessments provide results for broad areas around the proposed wind farm to allow additional properties (whether existing or proposed new properties) to be considered.

After receiving the Department’s summary of submissions made during the exhibition period, Taurus Energy has made every effort to identify the “Colletts” and “Cullerin” properties. These properties are not identified on any maps available to Taurus Energy, and therefore Taurus carried out a specific site visit to attempt to identify these properties based on the information provided. In addition, Taurus Energy contacted Council, the local Post Office, the local mail delivery contractor, and a number of local residents in an attempt to find further details of the properties. This effort was largely unsuccessful.

The “Colletts” property could be the 2nd property marked as “Greendale” and identified in the Noise Assessment as property G15. This was suggested by one local resident, and while this suggestion could not be independently confirmed, it would seem likely based on the description of the property location. Whether this is correct or not, the location described for the “Colletts” property is believed to be in the vicinity of this property and would therefore have similar visual and noise impacts. [Visual Impact: Area 10, moderate– high impact if views to site, low – moderate impact otherwise; Noise Level: 29.4­30.3dBA at 8m/s; complies].

The “Cullerin” property could not be identified either from an extensive on­site search or from aerial photographs of the area. The two owners of the land immediately surrounding this intersection were contacted and could not provide any further advice. It is possible that this is a previous name of the “Rosehill” or “Lochleigh” properties. In any case, from the description this property would seem to lie between the “Rosehill” property (C52) and the “Lochleigh” property (C9) and would therefore have similar visual and noise impacts. [Visual Impact: Area 12, moderate – high impact if views to site, low – moderate impact otherwise; Noise Level: 17.1 – 22dBA at 8m/s; complies].

Further details on these properties can be found in the Noise Assessment and Visual Impact Assessment attached to the EA.

The “Dairy Flat” property is approximately 5.44km from the nearest turbine and therefore outside of the 5km radius from a turbine determined necessary for the noise assessment to ensure compliance with the noise criteria. Figures 3 and 4 of the Noise Impact Assessment predicts noise impacts at 8m/s of less than 30 dBA, well within the 35dBA criteria.

From the road, there appeared to be 2 houses on the ‘Bohara’ property. What is believed to be the main homestead “Bohara” was specifically addressed in the visual assessment.

It is assumed that “Bohara” cottage is the small building on the property next to the road (it should be noted that it was not always possible to locate and determine the use of every building on any given property). This cottage is mostly surrounded by vegetation, and any views to the wind farm would be mostly or totally screened. The visual impact is likely to be less than from the main homestead on the property.

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Response to DNR Submission – Cullerin Range Wind Farm

Taurus Energy acknowledges the importance of soil and landscape management, watercourse management, and vegetation management in relation to the proposal.

We have included a number of mitigation actions in our Statement of Commitments to minimise impacts in these areas.

With reference to watercourse management, as part of our efforts in mitigating impacts, we have been careful in our planning to ensure that no site disturbance activities or project infrastructure are located within 40m of the bed or banks of a watercourse. In the event that site conditions identified during the final design phase mean that a minor layout modification is required which could place works within 40m of a watercourse, Taurus Energy would liaise with the Department of Planning and provide mitigation in accordance with the minimum standards provided by DNR.

With reference to vegetation, we note that DNR identifies a number of issues including:

­ degradation of existing remnants and loss of habitat components

­ sediment and erosion control

­ disposal of cleared vegetation

These issues have generally been addressed in the Biodiversity Assessment and in the EA. Where possible, we have avoided impacts to sensitive areas, and made efforts to minimise and mitigate impacts where they are unavoidable. We agree with the principles outlined by DNR, and would be happy to meet their suggested conditions of consent in relation to:

­ retaining felled timber for habitat value and for reducing erosion

­ aligning this felled timber with the contour on steep land

­ where felled timber could not be retained (e.g. where it could become a bush fire hazard), chipping of the felled timber, or use of local firewood contractor)

­ keeping drainage lines clear of felled timber

No burning of felled timber is anticipated on site.

Again, a number of mitigation actions have been included in the Statement of Commitments to minimise impacts in these areas.

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