Figure 1, Scenery looking North over Springdale (Valley) Site from my property. Note the drop in elevation.

I object to The Springdale Solar Farm proposal going ahead for numerous reasons as demonstrated in my submission below. This Proposal is not in a good position and Renew’s goal of windfall profits to be received from Government subsidies before they finish in 2020 appears to be their only driving force.

I have highlighted all the quotes from Renew Estate’s Springdale Solar Farm’s, Environmental Impact Statement (EIS). The EIS that is presented does not give credit to a proposal supposedly valued at $138,000,000. If a building was to be built for this amount then detailed plans, surveys, quantity surveys and construction deadlines would be done. Instead the EIS is filled with inaccuracies, hidden or disguised information and statements such as ‘The tracking structures would be mounted on piles, which would be screw or pile driven depending on final geotechnical analysis.’

Screw driven or pile driven would make quite a difference to the noise level in the valley (6db for immediate neighbours), noise carries in the country we do not have the background noise as in a city. I object to the potential noise not only from the construction period which would be horrific. I also object to the ongoing noise this industrial proposal would generate, with cars, machinery operating and washing of panels.

No geotechnical analysis done? Why not?

Security fencing would be up to 2200 mm in height, subject to final design. and

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Total land use available for agricultural activity during the operation of the project would be subject to the final detailed project design. and

Preparation and implementation of an OEMP to reduce the impact of the proposed project on:

and

NV1 Prepare a Noise Management Plan that specifies and

NV2 Consider using bored piling for construction works where practicable. and

T1 Preparation of a Traffic Management Plan in consultation with the YVC, RMS and other authorities prior to construction that covers

And

Opportunity for relevant skills training, up-skilling and scholarships: The details of this are yet to be determined.

And

Potential sealing of part of Tallagandra Lane.

And

Finalise the draft Landscape Plan and

Prepare and Erosion and Sediment Control Plan (ESCP) and

W2 Prepare a CEMP that ensures and

W3 Prepare an O&M Plan for the operational phase that covers: and

L1 Preparation of a CEMP that incorporate the following measures: and

BF1 A Bushfire Management Plan would be developed

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So many ifs, when does final design occur after they have received approval? So they can then do what they like.

Non-Aboriginal heritage

There are no historic heritage values within the Site listed on UNESCO, Commonwealth, State or Local Government Lists, Registers or Schedules. The closest listed historic heritage item is Bywong Homestead, outbuildings and landscape, listed in the Yass Valley Local Environmental Plan, located 2.6 km east of the Site. In addition, no historic heritage items were identified during a field survey.

As no historic heritage values were identified within the Site or directly adjacent to it, no impacts to historic heritage items, places or values are anticipated, including views and vistas from the historic villages of Gundaroo and Sutton

I object on the grounds of destruction of Heritage.

The land is part of the Reid/Read family properties, Tintinhull house (built in 1890’s is neighbour to the site and being restored) and Tintinhull Road (lane) are named after Tintinhull in the UK from where my relatives two Read/Reid brothers moved.

George in 1849, and Hugh 7 years later, ‘both purchased land at a land sale in Queanbeyan on 31 October 1859’. George is believed to have settled on land near Spring Flat the name of the property where both my brother and myself live. ‘George’s property was known as Perm Hill. All that remains of the house today is a heap of stone which indicates the position of the fireplace. However some trees mark the spot and the old sheepyards and dip remain.’

And

‘The Gundaroo Correspondent of the “Queanbeyan Age” reported in 1875 that: “there is a place in Gundaroo called the Back Creek, and, until lately, both its people and itself have been in the back, but within the last six months or so, a provisional school under the management of Mr Devlin has sprung into existence and given itself both ‘a local habitation and a name’. it is called Spring Flat and has made everybody and everything spring into fresh notice and activity…’ From A Pictorial History of the Read/Reid family in Australia 1849-1979 by Lyall R Gillespie (ISBN 0 9595542 0 3).

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Figure 2, Book; A Pictorial History of The Read/Reid family in Australia 1849- 1979, by Lyall R Gillespie.

This book was published in relation to the Read/Reid family reunion in March 1979. At that time there were over 700 descendants from these two brothers. There must be thousands now. George was my Great Great Grandfather, his house is located on the Springdale site. .

Renew Estate’s EIS states there is no historic value! This is part of the history of this nation, immigrant Fathers who raised sheep and families at a time when Australia rode on the sheep’s back.

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The remains of my Great Grandfather and Grandfather’s house a brick chimney of the 1920‘s overlooks the site on Spring Flat. Another cursory survey by Renew Estate with no depth.

1.6 1.6 Purpose of environmental impact assessment

The purpose of this EIS is to assess, and propose mitigation measures for, the environmental and social implications of proceeding with the development.

And 2.2.8 Social and economic justification

On a social level, the project has received broad support from the local and regional community and Yass Valley Council. This has included broad support for Renew Estate’s proposes community contributions scheme, which would be offered to support of local community initiatives (refer section 5.0)

The proposed Springdale development has been met with strong opposition to the proposal, not broad support, 102 people attended our first public meeting of The Sutton Solar Action Group, with nearly seventy people at the meeting signing our petition to stop the Springdale development going ahead. Nearly 40 people attended our last public meeting at short notice (with many apologies), as concerned residents were not given adequate notice before the Exhibition period begins. The meeting included two Yass Valley Councillors who were opposed to the proposed Springdale development.

We also attended the Renew Estate’s Springdale Solar Farm information sessions during the exhibition period which was attended by mostly Renew estate workers with less than a dozen residents who were not part of the Sutton Solar Action Group. Of the residents that did attend few were in favour of the Development, despite Renew Estate’s attempt to bribe the community with offers of $100,000 for the community, roads upgraded and tree plantings.

This has caused deep social divisions in neighbours and many within the Sutton community, with organizations such as Sutton & District Community Association and Landcare.

Most of the adjoining properties owners joined together as part of the Sutton Solar Action Group with regular meetings of the executive, local landowners, even those not directly affected allowed protest signs to be exhibited on their properties,

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Figure 3, Protest sign at entrance to Sutton with flyers distributed, email updates and our Facebook page (https://www.facebook.com/Suttonsolaractiongroup/?fb_dtsg_ag=AdwMkYTFlZcS9s4MoXx854vl0iG 3ymRtOTH2DQAwuftxBQ%3AAdzl-SuSZCagVRS6oX2ZC2eId3DwuEjLUw-R9esaUT19Bw) . Residents have been very generous financially in supporting the fight against the Springdale Development. There has been a community ground swell growing in opposition as residents and the local community realize the potentially devastating affect this development would have on the Community and its future if the Springdale Development was to go ahead.

There have been 2 articles in The Canberra Times (https://www.smh.com.au/environment/sustainability/on-our-doorstep-a-village-hall-becomes-a- war-room-20180806-p4zvuy.html, including a front page story (https://www.smh.com.au/national/act/corbell-back-on-solar-game-with-100mw-solar-farm- planned-for-sutton-20180718-p4zs65.html, and articles in The Yass Tribune and Sutton Chatter. This has resulted in strong support from Sutton and Gundaroo residents to stop The Springdale development.

We have met with local Yass Valley Council, Politicians Pru Goward and Mike Kelly.

There are 34 residents within 2 kilometres from the proposed development, most are not in favour and strongly oppose the proposed development. It would be interesting to find out how many houses there are within 5kms of the proposed site? As they also would be affected.

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Sutton area remains the wrong location for this type of industrial development. The Springdale solar farm development cannot be mitigated.

Entrepreneur Dick Smith who has a property in the Gundaroo area has also voiced his opposition to the proposed Springdale development.

The Yass Valley Council opposes the Development, see the minutes below this is not broad support as Renew Estate’s EIS states, but broad opposition.

Yass Valley Council; Minutes of the Ordinary Meeting of Council held on 22 August 2018

6.1 PROPOSED SPRINGDALE SOLAR FARM

SUMMARY

Presenting a report on the proposed Springdale Solar Farm. The proposal is State Significant Development and the Planning Assessment Commission is the Consent Authority. Key issues for Yass Valley relate to road infrastructure, the community enhancement fund and ensuring issues raised by local residents are properly assessed as part of the process.

RESOLVED that a submission be made to the Department of Planning & Environment on the proposed Springdale Solar Farm on the following grounds:

1. The location is inconsistent with the Yass Valley Settlement Strategy and likely to negatively impact on the visual amenity of the area.

2. Locating the development within the proposed RU6 transition zone undermines the intended objectives to protect the open rural landscape and environmental values of the area.

3. The visual assessment is be revised to include all affected dwellings within 2 km of the site.

4. Project is to demonstrate how it positively contributes to the habitat connectivity outcomes of the Greater Gooroyaroo project.

5. The Department of Planning & Environment be requested to hold a public hearing locally as part of the assessment process.

6. If approved, all road work and upgrades are required to be consistent with Council’s Roads Standards Policy.

7. If approved, a fund is to be established in accordance with Council’s Community Enhancement Fund Policy based on 1% of the capital cost for the project.

8. If approved, the proposed 2.2 metre high security fence is to be located inside the 20 metre wide landscape strip rather than on the boundary to Tallagandra Lane and Tintinhull Road.

9. If approved, the project is to be commenced within 5 years of a Consent being issued and completed within 5 years of commencement.

10. If approved, any landscaping plan is to incorporate species which are endemic to the local area.

11. If approved, alternative waste disposal arrangements are to be made for construction waste.

(Jones/Frost) 162

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FOR: Councillors R Abbey, C Burgess, G Frost, A Harker, J Jones, M Reid and K Turner

AGAINST: Councillors N Furry and M McManus https://yass.infocouncil.biz/Open/2018/08/CO_22082018_MIN_478.PDF

Take note that the community and the Yass Valley Council are opposing this development from progressing. It has done enough damage in the community to this point, stop it now.

15.1.2 Impact assessment

The proposed Site does not lie on an area designated as bushfire prone land under the Yass Valley Council LGA Bush Fire Prone Land Map (6 June 2014). Therefore, a Bush Fire Assessment is not required under the assessment methodology specified in Planning for Bushfire Protection (PBP) (RFS 2006). Notwithstanding, a qualitative assessment has been undertaken to determine controls to mitigate residual risk that may be present.

Construction

Bushfire risks associated with the proposed development occur during both construction and operation. During construction the activities that could increase the risk of bushfire include:

ks.

Considering the mildly undulating terrain and low degree of vegetation present the risk of bushfire within the Site and surrounds is considered to be low. The risk outlined above would be manageable during construction through measures in the CEMP.

Figure 4, Bush Fire 18/01/2017 on Mulligans Flat Road, Deliberately lit.

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Figure 5, Started at Mulligans Flat, less than 3kms away from the Springdale site.

Figure 6, Burning toward Sutton/Gundaroo Road. Burnt sheds, grassland, scrub and other infustructure.

The development would be a Fire hazard, there have been a number of fires located within 1-5 km’s of proposed development within the last five years and fire entered the Springdale site during the devastating fires of 1979, when my whole property was burnt out.

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With the whole site being fenced off with 2.2m chain wire fencing and trees planted, there is a greater risk of fires growing in intensity before fire brigades are able to enter and control the fire. Fire risk from Lightning, torching of stolen cars (several have occurred in the last few years) Check with Sutton Brigade the number of fires within 5 km of the site in the last five years. The proximity to Canberra increasing the risk of roadside fires, whether accidently or deliberately being lit. in 2017 two fires within 2kms of the Springdale site were deliberately lit, causing grassland and infrastructure damage, see below. The electrical and human activity within the site increases the risk of fires to the immediate area and to Sutton or with a Northerly wind to the Suburbs of Canberra and the sensitive Environmental areas of Mulligans Flat, surrounding Canberra (Within 5 kms).

If the development is successful and I hope reason prevails and it isn’t, Fire retardant trees should be planted instead of the proposed trees and shrubs that could exacerbate a fire. Once a fire gets established it is so much harder to extinguish. We are currently in drought and recent fires on the news in August.

See Fire photo’s figure 15 to 17 of one of the fires that commenced in 2017, being deliberately lit. ACT police block road as Sutton fire spreads http://www.abc.net.au/news/2017-01-18/sutton-fire-police/8192036

4:54pm Wednesday 18 Jan 2017 Fire near ACT / NSW border at Sutton

https://esa.act.gov.au/2017/01/18/fire-near-act-nsw-border-at-sutton/

Tarago, Sutton grassfires both contained by firefighters Updated 20 Jan 2017, 6:55am

523-hectare blaze on Mulligans Flat Road http://www.abc.net.au/news/2017-01-19/tarago-sutton-fires-contained-with-help-of-milder- weather/8193164

The Sutton Chatter April 2017

Sutton Volunteer Rural Fire Brigade

March report;

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27/2/2017 Late at night a ute was deliberately torched on Mulligans Flat Road and this in turn started a grass fire in the neighbouring paddocks. Sutton 1 with a crew of four, Sutton 7 with a crew of two, Sutton 2 with a crew of three and the Captain in Sutton 17 all responded. The fire burnt an area of approximately six acres. Units from the ACT Rural and the Fire and Rescue Services also attended.

9/03/2017 A fire occurred on a property off Duke Road, started by a resident using a slasher, which burnt an area of about 21 hectares. Sutton 2 with a crew of three, Sutton 7 with a crew of two, the Captain in Sutton 17, Sutton 1 with a crew of five and Sutton PC and Fast Fill Trailer with a crew one all responded to this fire. We also had invaluable support from many crews from other local RFS Brigades, from the ACT Rural and Parks and urban Fire Services and a helicopter. There were many rocks in the paddock and the blades striking a rock would have caused a spark that ignited the dry grass. Luckily the wind was fairly light or a much larger area would have been burnt. Slashing should be carried out in the early morning when there is some dew on the grass, or late in the evening, rather than during the warmest and driest part of the day in the afternoon.

The fire on 27/2/2017 was lit at night, if this was a car dumped outside of the proposed solar farm and torched, with a wind blowing it could cause massive damage to the farm and neighbours as entry to the site would be difficult to extinguish the blaze. A few years ago my brother also had a car burnt on the edge of his land. The fire burnt inside the fence however extinguished itself as there was no wind and little grass to burn in the area, also within 3km’s of the site.

Has consideration been given to the likelihood of the proposed Springdale Solar Farm being a Terrorist target, the site being so close to Canberra suburbs?

2.2.7 Supporting regional development, employment and industry

The project is expected to provide a strong contribution to regional development and employment, and ongoing economic benefits to the local region. The Yass Valley Council Economic Development Strategy (YVC, 2014) outlines the Council’s plan to improve the economic wellbeing of the region through attracting employment-generating investment.

According to Google Maps the distance from the centre of the development on Tallagandra lane to Yass by road is 49.0 kilometres and to the Canberra Suburb of Bonner is 7.1 kilometres and to Canberra City Centre 25.8 kilometres. How will Yass prosper from this development? Yass will not nor will the rest of NSW nor will the local Sutton area as most of the employment in the region originates from Canberra and that is why the Barton Highway needs to be duplicated due to the large number of Yass residents working in Canberra.

Canberra’s Unemployment level is the lowest in Australia according to the Australian Department of Jobs and Small Business. http://lmip.gov.au/default.aspx?LMIP/LFR_SAFOUR/LFR_UnemploymentRate Unemployment Rates (15+) by State and Territory, June 2018 (%)

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Unemployment Rates (15+) by State and Territory, June 2018 (%)

State/Territory Unemployment Rate (%) Australian Capital Territory 3.5 Northern Territory 4.1 New South Wales 4.7

It also has the second highest participation rate next to the Northern Territory.

From Renew Estate’s EIS; Labour force within the Yass Valley LGA was 8,318 people and unemployment was recorded as 2.9%, well below the national average of 6.9% (ABS 2016).

Minimal effect on employment in the local area. In which case will Wirsol bring in 457 visa employees as in other developments?

One of Renew’s partners is Beast Solutions which is a Canberra based Company.

‘Ground Floor 34 Thynne St Bruce ACT 2617.

The Canberra Region may prosper slightly, not necessarily NSW. Another reason why this Springdale proposal should be totally rejected.

2.3 Project options and alternatives

2.3.1 Site selection -level of solar resource and ideal climatic conditions for a commercial-scale solar farm. solar resources in the world.

The solar farm lies in a fog prone valley. Fog has been minimized this year because of the severe drought that we have been experiencing. The fog has not been as thick as normal and not remained in the valley as long as would be in a normal year. However I have been able to photograph 44 days that started with fog. This valley, is worse than Canberra Airport area, what research has been done in this area, (not Canberra as this area is worse than Canberra) to the number of hours of sunlight lost because of fog.

See attachment Fog Photos 1- 44.

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Figure 7, Overlooking the Proposed Springdale Site 26/8/18

The project is located under TransGrid’s 132 kV feeder 977, approximately 3.5 km north of the ACT and between the Canberra and Queanbeyan substations. The Site is uniquely located to contribute to the additional electrical demand in Canberra over the coming decades.

‘Located to contribute to the additional electrical demand in Canberra’.

The Proposed Springdale Solar Farm is for the benefit of Canberra ACT not NSW.

From Transgrid website; https://www.transgrid.com.au/what-we-do/our- network/our-assets/Pages/default.aspx

‘Our substations operate at 132 kV, 220 kV, 330 kV or 500 kV.

Electricity is transmitted at high voltages when required to travel over large distances as this reduces electrical losses. At substations, high voltage transmission can be reduced in voltage for local needs or for further transmission.’

132kv power lines are therefore more suited to short distances and therefore not to linking long distances users on the grid. Canberra is the main short distance user.

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Why is this site being considered when Transgrid recommends that future developments use higher voltage power lines than the 132kv proposed by Renew Estate to allow more efficient energy transfer on the grid.

2.3.4 The ‘Do Nothing’ option

The ‘do-nothing’ approach would not provide additional generating capacity in region.

According to the Clean Energy Council; https://www.cleanenergycouncil.org.au/technologies/solar-pv.html

‘Solar PV in Australia: 2017 in focus

In 2017, small-scale solar was responsible for 20.3 per cent of Australia's clean energy generation and produced 3.4 per cent of the country's total electricity.

More than 1.1 GW of new solar capacity was installed in 2017, which was an Australian record for a calendar year. More than 1.8 million small-scale solar power systems had been installed across the country by the end of 2017.’

2018: Australia’s Second Solar Boom Is Here - IAIN ADKINS | Contributing Economics Editor 8:32AM Wednesday, 23 March 2018 ‘Currently over 10,000 solar panels are being installed in Australia every day - this smashes the previous records set in 2012. One-third of Aussie homes now have solar - that’s 1.8 million homes! Homeowners are now installing more solar than ever and the trend shows no signs of slowing down.’

The Guardian: https://www.theguardian.com/australia-news/2018/mar/06/australias-solar- future-bright-as-households-install-record-35m-panels.

‘The future of Australia’s solar industry is looking bright after a record 3.5m panels were installed on rooftops last year, giving the equivalent output of a medium-sized coal-fired power station.’

‘In 2017, there was a 41% increase in installed capacity across all states and territories compared to 2016. Queensland led the way with installed capacity at 295MW, with the Australian Capital Territory taking top place for biggest annual increase, up 57%.’

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The Australian Capital Territory, increased roof top solar by 57%! Do Nothing! The growth in roof top solar and not greenfield industrial solar continues even if the opportunistic Renew Estate’s proposal fails. I believe there are a large number of other solar projects seeking approval in NSW that would benefit NSW and not the ACT in areas that would be welcomed and benefit the community where they are placed, the Springfield proposal will not.

NSW Government/News and Events / News / More large-scale solar farms coming to NSW https://www.nsw.gov.au/news-and-events/news/more-large-scale-solar-farms-coming-to-nsw/ Solar projects across NSW Operational

Solar farms that are up and running:

1. Nyngan Solar Farm 2. Moree Solar Farm 3. Broken Hill Solar Farm Approved

Solar farms approved by the NSW Government since 2011:

1. Bogan River Solar Farm in Nyngan 2. Capital Solar Farm in Bungendore 3. Manildra Solar Farm 4. Riverina Solar Farm in Yoogali 5. Griffith Solar Farm in Yoogali 6. White Rock Solar Farm in Matheson 7. Parkes Solar Farm 8. Goonumbla Solar Farm in Parkes Proposed

Solar farms proposed by the NSW Government in 2017:

1. (Balranald Council) 2. Gilgandra Solar Farm (Gilgandra Council) 3. Narrabri Solar Farm (Narrabri Council) 4. Metz Solar Farm (Armidale Dumaresq Council) 5. Hillston Solar Farm (Carrathool Council) 6. (Balranald Council) 7. Nevertire Solar Farm (Warren Council) 8. Walgett Solar Farm (Walgett Council) 9. Hay Solar Farm (Hay Council) 10. (Murrumbidgee Council) 11. Jemalong Solar Farm (Forbes Shire Council) 12. Beryl Solar Farm (Mid-Western Regional Council)

Gunning Solar Farm is proposed to be 316 MW and would be positioned over a site of 500 ha approximately 27 km to the north of the Site.

Renew Estate is not the only Solar Farm seeking approval in NSW with a lot more in the pipeline trying to join the rush before subsidies run out.

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In our rush to meet The Paris Agreement let us make intelligent long term planning decisions that are based on good policy and community good, not just short term profits for companies seeking subsidies.

The project would create business opportunities and provide a socio-economic boost to the local construction sector.

Given the lack of large scale development proposals in the vicinity of the project, and the general abundance of suppliers, accommodation and workers nearby in the ACT, it is not expected that the project would result in significant adverse socio- economic impacts

See above information on unemployment rates. Much of the ACT is already fully employed with major projects such as the Light Rail Project. I know at least one of the local construction companies is fully employed on the project.

From Transport Canberra, Light Rail Network. https://www.transport.act.gov.au/light-rail-network ‘Construction of stage one of the Light Rail Network is now underway, with work progressing on the 12 kilometre City to Gungahlin corridor. The ACT Government has also endorsed a City to Woden corridor as the preferred next stage in the development of the network’

Would overseas workers be used? If local residents are not used, what benefit is it to NSW.

The solar farm should be moved out west where it is more efficient and it would truly benefit drought ravaged communities. It would not benefit Sutton community, only cause increase in traffic, noise and long term damage to the rural nature of the Sutton community.

Supply and Demand, if you increase the demand without any increase in supply then this causes inflation. The area does not need the Springdale development, Stop it progressing.

3.0 Project description

3.1 Site description

The Site is greenfield comprising large paddocks used exclusively for grazing sheep and cattle. With the exception of a seven-hectare patch of woodland in the western portion of the Site (lots 189 and 190), the Site is largely cleared, with some scattered trees and rows of trees along fence lines. The topography is gently undulating with a few knolls and ridges. The Site contains a few dams and various tributaries that drain into Back Creek which flow towards the northeast and eventually discharges into the Yass River.

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Figure 8, Looking over Springdale site with Tallagandra Lane in foreground, the dividing line between my property and The Springdale Site (Beautiful grazing land), from the Eastern part of my property.

From Wikipedia; Brownfield land is a term used in urban planning to describe any previously developed land that is not currently in use, whether contaminated or not or, in North America, more specifically to describe land previously used for industrial or commercial purposes with known or suspected pollution including soil contamination due to hazardous waste.[1][2]

Many states in the USA discourage solar farms being built on greenfield sites instead specifying wherever possible they are built on Brownfield Land, as large areas of productive land for crops and grazing was being converted to be used for solar farms. From brownfield to solar field: A case study

By John David Baldwin on January 28, 2017

Massachusetts has been among the leaders in repurposing brownfields for solar. The Massachusetts state legislature passed the Brownfields Act in 1998. This law concerns the transformation of brownfields for any purpose, not just solar …In April 2014, legislation was passed expanding the scope of the original brownfields law. It combined the state’s campaign to reclaim brownfields with the adoption of renewable energy. This new program provided specific incentives to develop solar on brownfield sites. New jersey Solar Act of 2012,

‘Ideal sites include brownfield and degraded land – creating so-called ‘brightfields’ (Hernandez et al.,’

European Commission FUTURE BRIEF: Wind & solar energy and nature conservation Environment Science for Environment Policy

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December 2014 Issue 9

Springdale is a greenfield site and should be excluded on this alone, much of the USA and Europe are recommending and legislating the use of brownfield sites and not Greenfield sites. This would be a loss of primary production and a loss of a beautiful grazing land, bordered by hills and mountains, which would be spoilt if an industrial site of this magnitude was to be approved. The total site being larger than the nearest ACT suburb of Bonner 3.5 kilometres away.

A buried gas pipeline also runs through the Site in a southwest-northeast direction.

Would you trust these people to build a $338,000,000 development, they did not mention the two important national fibre optic cables running through different areas of the site?? Their cursory survey is evident. Despite the large number of words in their EIS. Perhaps they will now have to do some redesigning of their incomplete plans.

Figure 9 Figure 10

Figure 11, Fibre Optic cable running through my property and the Springdale sites. Figure 12

3.1.1 Yass Valley

The Site is located with the YVC LGA and is zoned Primary Production (RU1) under the LEP.

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The YVC LGA occupies around 4,000 km2 of land in south-eastern NSW with Yass as its main town centre. Yass is approximately 40 km northwest of the Site, with Canberra being the Site’s nearest major settlement approximately 22 km to the southwest. Sutton is the nearest village, approximately 7 km to the southeast.

Canberra Suburbs are approximately 4kms away or 6.6 km by road, another misleading statement, Canberra City is 24.1kms away by road. Sutton is 9 kms away by road.

Figure 13, Looking North toward Springdale site

From Renew Estate’s EIS; Figure 5 A typical example of solar farm panel arrays

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This shows a typical flat site not in a valley on undulating land, surrounded by homes and properties. The local community do not want this development, place this out west on one of the three solar zones that the NSW Department of Energy has recommended.

The region is dominated by cool climate wineries east of the Murrumbidgee River and sheep and wool production in the north and west (YVC, 2017)

Tourism

Tallagandra lane is a roadway between the winegrowing areas of Murrumbateman and The ACT area of Gungahlin with a growing population heading toward 100,000. Near the Northern end of Tallagandra lane are located two wineries. There is also a winery between Canberra and the proposed development off Mulligans Flat road Di Bartolo Wines (http://www.dibartolowines.com.au/). Tallagandra Hill Winery (https://tallagandrahill.com.au/), has regular visitors and special events see advertisement in Sutton Chatter (https://www.scribd.com/document/377954448/Sutton-Chatter-May-2018), p10. See Figure Future development of wineries may be stifled by proximity and or overlooking a solar industrial estate. Other enterprise may also be affected, that is a wedding centre and an indoor horse arena. Tourists from Canberra often drive out into the country to see the natural beauty, we don’t want tourists to come out to see the equivalent of a Nineteenth Century Psychiatric ‘Funny farm’. See Figures 7 to 13 for screen shots and photos of some of the Wineries in the local area of the proposed Springdale site.

Vineyards in the local area include; https://www.gundogestate.com.au/2017/vineyards

Figure 14, Located on Murrumbateman Road close to the Northern end of Tallagandra Lane, 6kms away.

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Figure 15, http://www.dibartolowines.com.au/ (less than 3 kms away from the Springdale site)

Figure 16

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Figure 17 Google maps of the Di Bartolo Wines site.

Figure 18 From The Sutton Chatter May 2018 P10. https://tallagandrahill.com.au/

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Figure 19

Figure 20 , More events advertised on Tallagandra Hill Winery’s website, for Father’s Day.

Visitors to a country vineyard should not have put up with driving through an ocean of 330,000 solar panels, and numerous other buildings, sub station, and amenities block together with a ten space parking lot, it would not add to the experience of a Sunday drive in the country.

Don’t let it become like Joni Mitchell’s song– Big Yellow Taxi Lyrics Don't it always seem to go That you don't know what you've got Till it's gone They paved paradise And put up a parking lot.

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Figure 21, Photo 27/08/2018 at 09:52AM, Regular International Flight coming into Canberra, has just flown over Springdale site, From north to south toward Canberra Airport.

The Development is under the flight path for International flights such as Singapore Airlines, they fly low over this area at apparent low speed, not a good sight for international tourists, flying over an industrial development of this size. Their first look at the approach to The Nation’s Capital seeing 330,000 solar panels glaring at them and many other buildings, an industrial area on the edge of Canberra. See Figure 34, taken at 9:52 am, International flight flying North to South towards Canberra Airport. They would have 330,000 panels aimed at them (if it is approved) as the panels are turned to the East to catch the morning sun. Reflection off water does not turn from east to west during the day.

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Visual considerations

Figure 22, Outlook from near my house looking North over Springdale Site, note position of my shed, directly overlooking the proposed Sub Station, Amenities block and Parking area.

22 Power Conversion stations

The power conversion stations have an indicative height of 3.5 m, and would have a total elevation of no more than four metres above the natural ground level, including foundations.

Another eyesore for the locals, the community and Tourists.

The switchyard and substation are being designed with TransGrid, with an indicative footprint of 50 x 90 metres.

Nearly the size of a football field at the bottom of a valley, not hidden by trees in how many years?

3.2.7 Control building

‘A control building with a footprint of approximately 450 m2 would be constructed to contain both the site office and warehouse/workshop facilities. The control building would consist of a steel structure erected on a concrete base.’

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Plus a ten space parking area. How long do they expect the screening trees to grow to screen their site, 30 years? Even planting extra large trees, which they are not proposing. I have been growing trees in the area on my property, for forty years, as my property adjoins the site, I know the difficulty, on most of my tree fences I have used drippers on each tree, for trees to grow and prosper, check out my tree fences.

Figure 23, Springdale site in distance, with 132kv Power lines.

In a drought such as we are currently experiencing even with weekly watering few would survive the first summer. If you have large gaps in the screening, then it is not screened. Anyway it cannot be screened from elevation.

Internal roads, probably at least 3 kms of internal roads, at least 4 metres wide plus temporary roads. The road would also cross a flood plain so would require either huge pipes with the road built up or large areas of concrete culverts. In either case this would cause a build up of flood waters banking up behind this structure into the proposed solar panels. If it is going to be underwater why not put it with the wind turbines on Lake George.

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Figure 24 Springdale Site in flood in the distance.

Figure 25, Flooding on Spring Flat 21/09/2016.

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Figure 26, Flooding on Spring Flat, flowing into Springdale site 21/09/2016

The only potential impacts to groundwater would be contamination due to spillages of chemicals used for construction or maintenance activities.

3.2.12 Tintinhull Road re-alignment

Subject to the execution of a Voluntary Planning Agreement with YVC (including agreement on the relevant works), a new section of public road is proposed to be constructed between Tallagandra Lane and Tintinhull Road, across the southeast corner of the Site. This would provide an alternative access to Tintinhull Road from Tallagandra Lane which does not traverse Lot 7001 DP96227 (Figure 10)

This has already commenced by a subdivision developer, and it appears that it has not been anything to do with Renew Estate???

See attached documents, Figures 27 and 28.

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Figure 27, Copy of document from YVC

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Figure 28, Copy of document sent by Yass Valley Council

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3.2.13 Subdivision

Subdivision for proposed substation

The proposed substation lot will be owned by TransGrid. In order to facilitate access for TransGrid to the substation, a 10 metre right of way will be granted in favour of the new substation lot over the proposed residue lot of 20.5 ha. The right of way will run south from Tallagandra Lane to the proposed substation lot as shown in the Plan of Proposed Subdivision in Figure 12.

As the substation is owned by Transgrid, it would not be removed as part of the decommissioning?

The subdivision of small lots would change the future of any development in the future after decommissioning.

3.3.3 Construction works; Site Establishment

Site clearing

Some existing exotic vegetation on-site planted by the existing landowner as wind breaks may be removed to reduce shading and aid in site design. Some roadside vegetation may also be removed or trimmed along Tallagandra Lane to improve line of sight at the main access route on this road.

Figure 29, Blue arrow indicated Pine tree windbreak that Renew Estate wishes to remove.

The removal of a large number of established pine trees as a wind break would affect other landholders down wind, despite the increase in CO2 as a result of the trees removed. See figure 32 with Blue arrow. As the trees are located on a hill there will be soil erosion from the removal of the trees as there is no vegetation growing under them. Another example of their low impact, not really. This is another part of the project that will not be rehabilitated at the end of the 30 year lease.

A huge number of large (fifty plus year old) pine trees have already been removed as part of the Tintinhull Lane realignment.

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Grading or earthworks may be required for levelling some areas of land

The site is undulating and will require large scale earthworks during construction for access during construction plus levelling to accommodate the long PV solar modules. All stormwater including any chemical residues from construction or operation will eventually flow into the Yass River, Yass’s water supply.

3.3 Construction Activities

3.3.1 Pre-construction and site establishment activities

Preliminary works that would be undertaken prior to the commencement of full construction would include:

 Detailed civil and electrical design

Another example of the lack of planning and design in this project, no final design before wanting approval! Would this occur for a $338,000,000 building NO!

Renew Estate has offered to enter into a Voluntary Planning Agreement with YVC to provide an additional public benefit of contributing funds to the upgrade some current unsealed sections of Tallagandra Lane. Renew Estate understands that YVC has no immediate plans to upgrade Tallagandra Lane due to other priority projects within the LGA, however feedback provided to Renew Estate from the community during its community consultation activities has identified that the state of Tallagandra Lane is an important issue for local residents. Renew Estate is continuing to work with YVC towards agreeing the terms of a Voluntary Planning Agreement that would allow for the provision of this public benefit (amongst other benefits). YVC has confirmed that, if such an agreement is able to be reached, that they would be the consent authority for these upgrade works. Accordingly, consent is not sought in this application for this component.

What is to stop Renew Estate from reneging on any deal reached if the Development was approved by the State Government? This is a Voluntary agreement! Renew Estate should enter into a binding contract to provide 1% of the capital cost for the project to Yass Valley Council’s Community Enhancement Fund as is their Policy. This money could then be used to upgrade Tallagandra Lane, a contract should be signed before any approval be granted to the project.

4.0 Statutory context

4.1 Permissibility

The proposed development is located on land zoned RU1 Primary Production under the Yass Valley Local Environment Plan 2013. Electrical generation is not listed as permissible with consent in this zone, however the proposed development is permissible with consent on any land under clause 34(7) of the State Environmental Planning Policy (Infrastructure) 2007 (ISEPP).

Under normal planning this would not be allowed in the Yass Shire RU1 zone, Yass Shire are trying to convert a 5km zone from the ACT Border to RU6. This would be a massive industrial development within a rural area. It should be Renew Estate’s job to prove why it should be in this area and not vice versa. This is totally against current planning in this area and sets a very unhealthy precedent if it was to be approved.

Why is this development still being considered because it is located outside of the NSW Governments three designated renewable energy zones.

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Visual as the development is located in a valley and despite Renew Estate’s photographs being taken to try and minimise impact of the Development it cannot be hidden by trees even if they do grow for the thirty years of the development. This is because of the location in a valley on undulating land, with surrounding houses and properties overlooking the Development. Certain areas cannot be hidden as trees and shrubs cannot be planted because of the Golden Sun Moth habitat. Other areas such as the huge substation cannot be hidden because of the location near power lines. Tallagandra lane travels from the hills down through the valley with development on both sides of the road and then up the hill out of the development, as a result the huge development cannot be adequately screened therefore should not be allowed to be built in this area.

See my photos in Figures 1 and 8

The DRAFT Large-Scale Solar Energy Guideline | For State Significant Development November 2017 under Key considerations for site selection states

 ‘unobtrusive sites with flat, low-lying topography, and sites with potential to be screened, such as those that can be readily vegetated along boundaries, to reduce visual impacts,’ Springdale site does not fit the guidelines.

4.2.4 Other NSW Legislation

State Environmental Planning Policy (Rural Lands) 2008 c. recognition of the significance of rural land uses to the State and rural communities, including the social and economic benefits of rural land use and development

Future of Land in this area. This land would be locked up for thirty years with Renew Estate or to whoever they sell it. This land is within 5 kms of Canberra suburbs and the future growth of Canberra will continue as NSW or as part of Canberra.

A 14 million dollar house and buildings has recently been built near the border of the ACT on Mulligans flat road, within 5 km of the development. The land in this area, will progressively become more valuable in the future.

Growth of Canberra. This area was originally planned to be part of the Y development of Canberra following both the Federal and Barton highways.

‘Based on our research Australian Capital Territory population will reach 407,692 by the end of June of 2018. By then, it will be the first time ACT’s population goes beyond 400,000. We use end of June each year due to Australia Bureau of Statistic (ABS) always follow Australia financial year when they publish the data. The calculation is based on the average growth rate of 1.48% over last 7 years since 2011. We believe using the recent years’ figures (see the table in next section) will make the estimation more accurate.’according to Population Australia (http://www.population.net.au/population-of-australian-capital-territory/)

This would mean the ACT population in thirty years time would be 633,499 a 55% increase in population. Gungahlin is within 5kms of the proposed Springdale Solar Development. Where

33 | P a g e will these people be living? The population growth will have to progress north of the border eventually. From The Canberra Times, By Finbar O'Mallon, Tom McIlroy Updated27 June 2017 — 3:06pmfirst published at 8:33am ‘Census 2016: ACT has nation's largest population growth, Gungahlin the driver’, ‘Census 2016 data shows while the ACT's population has grown by 11.2 per cent in five years, Gungahlin is Australia's second-fastest growing region, with 71,000 residents, up from 47,000 in 2011.

d. in planning for rural lands, to balance the social, economic and environmental interests of the community

I have worked in Mental Health for over twenty years as a clinician and manager and I see the effect that this proposed development has caused to the mental health of myself and surrounding landholders and the concern of the general community, who are worried that this development might go ahead.

Local Families have had to endure meetings with Renew Estate, meetings to try and fight this proposal weekly to fortnightly, time spent on emails, meeting with Newspaper reporters, radio announcers and politicians, research into solar policy, research into government decision making for appropriate sites for solar farms, potential for harm from solar farm developments and contributing to The Draft Guidelines for Solar Development in NSW. This has led to exhaustion and the unfairness of a system that allows a developer to have as much resources as they wish to push their case (in this case millions of dollars), (Renew Estate how much was spent on your EIS?), while the community that it affects are scrambling to organize themselves, find finances and people to try and combat their well oiled machine. Renew Estate’s proposal in unjust and inappropriate for this area, however because they are able to employ solicitors, engineers, specialists in various fields it makes the fight to stop the proposal feel unwinnable. Some of the local residents are older and not computer literate so the two printed copies of the 220 page EIS that were made available at The Sutton Post Office and 50 kilometres away in Yass meant that they were unable to read it let alone comment and object to it.

This has caused an increase in stress within the Sutton Community, with residents feeling overwhelmed by the prospect, even the EIS has been so daunting to many residents feeling that they are only little pawns, fighting a mighty industrial conglomerate, with their hands tied behind their backs, in the process of decision making. When people feel there is no way out, they feel disempowered, which can lead to depression and possible suicide. At present they have rallied to try and win the fight. If this Springdale development is approved the situation would change dramatically. I hope that Renew Estate does not end up with blood on their hands as for many residents their finances and their dreams are tied to a country/rural lifestyle.

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Figure 30 Protest Signs

Figure 31 Advertising first meeting of Sutton Solar Action Group in which over 100 people attended.

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Figure 32 Mobile Protest sign.

f. the provision of opportunities for rural lifestyle, settlement and housing that contribute to the social and economic welfare of rural communities

Industrial Area. The land is currently rural and the area rural or rural residential. An industrial development of the size proposed, sets a precedent for further Industrial development which would change the nature of the whole of the Sutton region and determine its future. What State long term planning has been done in respect to a development in this area. Most of the residents in this area have moved into the area for a rural lifestyle and it is wrong to ruin that lifestyle. Devalue their properties and spoil the environment.

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The closest NSW nature reserve is more than 6 km south of the Site (Goorooyarroo Nature Reserve).

Mulligans Flat nature Reserve was not mentioned in Renew Estate’s EIS, it is within 5 km of the proposed site. https://mulligansflat.org.au/, and Goorooyaroo Nature Reserve.

From the ACT Government, Environment, Planning and sustainable development Directorate;

‘Goorooyarroo Nature Reserve, part of Canberra Nature Park, is a 703 hectare reserve located in north- east Canberra and includes the prominent hill, known as 'Old Joe' on the ACT/NSW border.

The reserve borders Mulligans Flat Nature Reserve in the north-west and is separated from the Mount

Majura Nature Reserve by Horse Park Drive in the south.

Goorooyarroo, together with Mulligans Flat Nature Reserve, protects 1384 hectares of endangered Yellow

Box-Red Gum Grassy Woodland which is the largest remaining area of box-gum woodland in the ACT. It is a regional stronghold for several threatened or uncommon woodland plant, grasshopper, lizard, bird and mammal species. It provides habitat for the critically endangered Golden Sun Moth (Synemon plana) and vulnerable Superb Parrot (Polytelis swainsonii).’ http://www.environment.act.gov.au/__data/assets/pdf_file/0007/390580/cnpmapgoorooyaroo. pdf

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Figure 33 Note Mulligans Flat Road represented by blue arrow.

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Figure 34, Frogs of the local area

Figure 35 Frogs of the Local area.

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Figure 36, Wedged Tail Eagle flying near the Springdale Site.

Solar Farms Threaten Birds, By John Upton, Climate Central on August 27, 2014. Scientific American https://www.scientificamerican.com/article/solar-farms-threaten-birds/ Much of the problem appears to lie in the “lake effect,” in which birds and their insect prey can mistake a reflective solar facility for a water body, or spot water ponds at the site, then hone in on it. Because of the power of the lake effect, the federal investigators described such solar farms as “mega-traps” in their report.

The site appears to be part of a flight path for migratory birds, what effect would this have on some of our endangered species, another plan to try and mitigate? Too many mitigations, just stop the project and protect the species.

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4.4 Local government

4.4.1 Yass Valley Local Environmental Plan 2013

The project is located on land zoned ‘RU1 - Primary Production’ under the LEP

The Yass Valley Council: RESOLVED that a submission be made to the Department of Planning & Environment on the proposed Springdale Solar Farm on the following grounds:

1. The location is inconsistent with the Yass Valley Settlement Strategy and likely to negatively impact on the visual amenity of the area.

2. Locating the development within the proposed RU6 transition zone undermines the intended objectives to protect the open rural landscape and environmental values of the area.

4.5.2 Native Title Act 1993

Searches of the Schedule of Applications (unregistered claimant applications), Register of Native Title Claims, National Native Title Register, Register of Indigenous Land Use Agreements and Notified Indigenous Land Use Agreements were undertaken in November 2017, with no relevant listings identified for the Site.

Has there been a native title claim with 2 km of the site?

5.0 Consultation

5.1 Overview

5.1.1 Renew Estate’s engagement strategy

Deliver an honest, innovative, flexible and transparent engagement process with all landowners,

No Meaningful Consultation. Renew Estate has not been in any meaningful consultation only providing information. Not acting on concerns of the Springdale neighbours. Only ticking the boxes by having meetings with residents and offering them paltry compensation, who face a year of disruption, noise, traffic, dust and visual pollution and glare for thirty years. They have ticked the boxes with other Community groups, giving a very one sided and Rosy account of the benefits without showing any of the drawbacks.

This is not an appropriate site and Renew Estate is only interested in the windfall profits from applying for subsidies from government. As most of the company would be funded by an overseas company Wircon, would Australian Subsidies paid be going to an overseas? What percentage of the profits from the company would be going overseas? How does this relate to the balance of trade for the loss of exports from the production of beef cattle and loan payments and/ or profits going overseas? What is the opportunity cost. Would this development still go ahead after 2020 without subsidies? Who does Renew Estate have contracts for feed in tariffs at what price and for how long?

Transparency - Being transparent at all times across all aspects of the project, processes and decisions

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At a meeting at Tom Hardwicke’s home a Renew Estate Director stated that there would be no glare from the solar panels that statement was corrected by one of her engineers at the meeting, who stated that there would be glare equivalent to the reflection off water.

At the Renew Estate’s first information session Simon Corbell stated to me that all funding would come from Renew Estate for the total building costs and there would be no subsidies from the Government. At the same meeting one of their engineers stated that they would be approaching the government for subsidies.

At the first information session a large number of photos were portrayed of small sized solar farms in the UK, Wirsol), when confronted Renew staff admitted that they were much smaller than the proposed Springdale Development. No photos of similar sized developments displayed. All Photos displayed showed solar farms on flat land with trees surrounding them, easy to achieve on small farms in the UK, not on 850 acres of undulating land in a valley in the Sutton area.

Renew Estate providing misleading information. At a meeting of residents and Renew Estate, a Solicitor of Renew Estate informed a group of residents that the compensation package being offered was in plain English and there was no need to get legal advice. This was from a solicitor who should have known better.

Renew Estate offered residents $20,000 worth of solar equipment for home solar system or $5000 of investment in their project, the income fixed for the first year however variable after that depending on income from panels. Mr Simon Corbell is reported in the Canberra Times as saying that residents would be getting $10,000 per year, $200,000 over twenty years. At a later meeting with Renew Estate it was confirmed that Mr Corbell’s comments were incorrectly reported. This is from the spokesperson for Renew Estate.

See front page of Canberra Times and following article (https://www.smh.com.au/national/act/corbell-back-on-solar-game-with-100mw-solar-farm- planned-for-sutton-20180718-p4zs65.html.

Engage in a manner that ensures approval and broad social acceptance of its projects by the local community and all other stakeholders (a social licence).

There has been strong opposition to Renew Estate and their industrial solar proposal. This has been evident in the strong support the Sutton Solar Action Group has received in confronting Renew Estate’s plans. Attendance at our public meetings and support to our Facebook page and regular email updates. This is also reinforced by The Yass Valley Council finally deciding to support the community over Renew Estate. The proposed development has caused tension and division within the community. Sutton has always been a close community with neighbours banding together in various areas such as the School, the local church, the local Sutton Volunteer Rural Fire Brigade, Landcare and various other organizations. This has caused division and some irreparable damage to the unity of the community. Renew Estate with their secret meetings and causing neighbourhood disputes.

- Proposing projects that are appropriate for the local context.

This project is a massive solar farm bigger than others in the area, (ACT), sticking a massive industrial complex in a pristine agricultural valley within 3.5km of the ACT border.

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Figure 37, Rainbow looking toward Springdale Site

properties.

Land devalued because of the development, prices of land thought to depreciate by up to 30% in areas overlooking the industrial development. What is the effect on rural/rural residential land prices of building other industrial developments (not just Solar) within 5km of a major city, not just rural land. The effect of farm values on remote land for wind farms is irrelevant to an industrial development next to rural /residential land. A recent auction of land near the proposed development apparently did not meet its reserve and failed to start bidding at the price paid for the land and home twelve months previously.

Farming Land, The Development if approved will be on some of the best farming land in the district, an area that has been pasture improved and fertilized over sixty or seventy years. Although the developer is planning to run sheep on some of the land. There would be a great loss of productivity from the current use. The long term damage to soil under solar panels for thirty years is yet to be determined. Erosion caused by earthworks, removal of a large number of trees on the side of a hill and Solar panels sitting at up to 2 metres above the ground dropping water ( from a storm) in this area is yet to be determined.

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Photos taken by Renew Estate from many neighbours properties, when viewed, were rejected by the neighbours and permission rescinded for Renew Estate to use the photos, to stop them from showing photos that did not show true landscapes, Photos that did not show changes in elevation and the impact of visual pollution from the 330,000 panels, 22 Container sized buildings and other buildings.

Attached are a number of photos from my land, house yard and home. (including the many fog photos that clearly show the site located in a fog prone Valley. Figures 1 and 8 clearly shows it is in a valley, my home sits at 650 Metres and most of the valley ranges from 650 on one hill to 600 metres. A 50 metre difference in altitude, screening trees such as Yellow Box would take 150 years to reach 10 metres tall. The site cannot be adequately screened so it should be rejected. The trees would take years to screen and even at the end of Thirty years they would generally not have achieved its’ purpose.

Magnitude of change: Low

The magnitude may be low if you are sitting in your Renew office in Manly or Beast Solutions in Canberra, however drastic if you are an affected resident or a part of the Sutton Community.

Size/scale: The scale of change in the landscape would be low within the context of the adjoining LCZ edges, and noting that a substantial area of the project is expected to be reinstated with screening vegetation which will reflect the character of this LCZ.

How condescending to be told that your lifestyle does not matter because the land will be restored in thirty years time. This may be meaningful if the site was located on a large property in the west of the state. The Sutton area is a fast moving area, with development applications being processed at present by YVC for the village to have two new housing subdivisions.

The site is 3,439,828 square metres the size of 420 football fields and the change in the landscape would be low, tell them they are dreaming.

9.3.2 Visual impact assessment

A total of fifteen visual receptor locations were identified to represent viewpoints for the assessment of potential impacts on views as a result of the project, as shown in Figure 19. A controversial project to build a solar farm next to the rural village of Uriarra has been dumped by the ACT Government after fierce opposition from local residents. http://www.topsolar.com.au/index.php?m=content&c=index&a=show&catid=14&id =37

Plans by Elementus Energy to build a 26,000-panel solar farm. 26,000 panels, Renew Estate are planning on 330,000 panels, the Uriarra proposal was only 8% the size of Springdale’s proposal. Our local residents are equally determined to stop Renew Estate’s huge proposal.

See attached Photos and not the Photoshop montages that make the site appear flat with no view of the solar panels as were presented to adjoining residents, of their properties from a Renew Estate employed photographer. This is the reason that local residents after viewing photographs taken for Renew Estate, refused to allow Renew Estate to use the photographs from their properties.

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c flow)

Traffic is already heavy on many of the roads proposed due to its proximity to Canberra.

This is a quiet valley and noise carries a long distance, people have moved to this area because it is a peaceful country area, NOT an industrial area. What effect would all the noise and construction have on wildlife?

.

Nil. Only negative to the character of the area, changing it from Rural and Rural Residential to industrial, with the closeness of Canberra the effect will be irreversible. The construction would be twelve months of interruption for the whole community with noise and traffic. Having additional people in the area would increase crime, antisocial behaviour, driving offences (speeding, drink driving, negligent driving) People from the City who are not used to driving on Country roads, accidents with kangaroos and other drivers).

See Figure 38, showing damage to one of my sheds after being rammed by a 4WD vehicle, the Shed is located within 50 metres of the Springdale site. This has occurred twice in the last few years.

Why should this proposed development rob the local residents and the Sutton Community of their current rural way of life.

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Change to the current grassland will allow weeds to grow see photo in Figure 26 showing current weeds, serrated tussock on the Springdale Site.

Figure 39 An example of Serrated Tussock currently on the Springdale Site.

Photo of an infestation of Serrated Tussock on the site, how are these to be dealt with between the panels.

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t on wildlife

I have a photo of a Kangaroo under the power lines, it will have no access to the site because of a 2.2 metre security fence. This will also stop the movement of other wildlife and potentially cause damage to vehicles as they will be caught on Tallagandra Lane and Tintinhull road, between two impenetrable 2.2 metre fences.

Figure 40, Blue arrow points to a large grey kangaroo, near the 132 kv power poles on the Proposed Springdale Solar Farm Site.

See photo of kangaroo under the power lines, Figure 42

.

Your computer modelling is totally inadequate, what is the surface area of 330,000 solar panels that are moved from east to west each day, what about people on distant hills, this area is surrounded by mountains and hills for twenty plus kilometres. Glare response to planes is also inadequate. Where are your field studies?

Law of nuisance may give relief to neighbours annoyed by solar farm, Posted on September 8, 2013 by Peter Mericka https://www.reic.com.au/2013/09/08/law-of-nuisance-may-give-relief-to-neighbours- annoyed-by-solar-farm/

Queensland lawyer Tim O’Dwyer” the Nine News reporter said, “sue for damages. Tim was then shown (in our board-room) sagely advising: “If they (the panels) impact upon

47 | P a g e your enjoyment of your property – with something like this such as a (serious) glare – that could be an actionable nuisance.” In his interview Tim had explained further (but unreported) that a court nuisance action for damages might also include a claim for an injunction to remove the panels, but this would be a possible remedy only for those neighbours “significantly” affected by glare from the array of panels.

This has already been covered. By enclosing an area adding, electrical operation and just human activity increases the risk of fire, using tractors machinery, grinding or welding. If a fire started then fighting it becomes very difficult, trying to fight it between panel arrays where there are no vehicle access and could be devastating if it quickly spreads to neighbouring properties, then Sutton or Canberra.

Site Specific Assessment – Magnetic Fields

The solar farm 132 kV switchgear is assumed to be an outdoor busbar arrangement as a worst case from an electric field perspective. The 33/132 kV Substation is estimated to have a minimum ~50 m separation to the property boundary and the electric field level at this separation would be designed to be <5 kV/m, which would therefore be compliant in regards to general public exposure.

Long term health impacts are unknown.

The long term effects of Magnetic fields may well be like safe smoking levels. As a Health Professional the long term effects are not always evident, such as asbestos and mesothelioma. I will be working close to the switch station and substation at times with farmwork and do not appreciate extra risk to my health, even from low level exposure to magnetic fields. The site should be located away from people and houses to an appropriate energy zone.

Rainfall runoff from solar panels is unlikely to cause soil erosion during operation. Each solar panel would have a length of up to four metres, and the maximum fall height from the panel to the ground would be about 1.22 metres to 2.0 metres

The current drought would mean that sheep would eat the pasture to ground level (dirt), if there was a storm during this time, water flowing off the panels from 2 metres would cause extensive soil erosion off the hills where the solar panels are located. From the topographic map provided in the EIS, The Site varies in elevation from 650 metres to 600 metres, quite a difference, this is not a flat site.

See Photos of flooding in the area in 2016 floods. Figures 24, 25, 26 & 41.

Potential impacts to surface waters during the operational phase include: has the potential to minimally increase runoff volumes and flow rates which may result in increased land and watercourse erosion.

Groundwater

There is a minor risk of contamination of groundwater due to accidental spillages of fuel, lubricants, herbicides, sewage and other chemicals

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The contamination risk would also be to the residents of Yass who have to drink the water that flows from the site with a minor risk of contamination!

Figure 41, Photo of Flooding on Spring Flat, this water flows on into Springdale Site 21/09/2016

the solar farm or build a second phase in the future

At my first initial meeting with Renew Estate, I talked with one of their representatives about whether they were considering using batteries, they said that it was not part of the initial construction but they would be considering it in the future.

A large area would be required for batteries and this would be the only way that Renew could future proof dropping feed in tariffs when increases in solar resources become available. Unfortunately once a solar farm of this size is established it would be difficult to stop further expansion, it might just require a modification to its approved plan. This would certainly then increase the danger to the community.

Shared benefits for the community

How nice of Renew Estate to try and raise funds for their enterprise through shared benefits and spread the risks. Also to offer neighbours part of their income for the first year and potential risks of drop in income if feed in Tariffs drop dramatically.

Increased demand for local services: There will be an increased demand locally for services such as accommodation, catering, dining and drinking, automotive and electrical during the construction and operational stages of the solar farm.

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The only viable accommodation available is in Canberra with a few beds available in Gundaroo,

Figure 42 Screen Shot of Google map of available accommodation in the area.

Very little catering and dining available for two hundred workers, outside of Canberra.

Automotive would be Canberra. Little benefit to NSW. If a large number of workers are brought in from other areas this brings with it some social problems for the Sutton Community. If 457 visa holders are used, as have been in other Wirsol projects, this can also lead to problems with workers not having family and social connection to the area.

Funding for the Springdale Solar farm?

Government incentive programs are still the main driver behind the development of large-scale and utility-scale solar projects in Australia. The federal government’s Solar Flagships Program is the most high-profile effort in the country to usher in an era of renewable energy generation, doing so by subsidising the construction of multi-megawatt solar power plan.

Renewable Energy Certificates (RECs) are a tradeable commodity attached to eligible installations of solar power systems. It’s an umbrella term referring to Small-scale Technology Certificates (STCs) and Large-scale Generation Certificates (LGCs).

In a commercial scale array, their value can be many thousands of dollars.

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The Federal Government has decided to close the Renewable Energy Target (RET) program under which the current certificates schemes operate. The RET ends in 2020. LGC Market Prices

10 November 2017

Large buyers and sellers of Large-scale Generation Certificates (LGCs) trade through the wholesale market with minimum parcel sizes of 5,000 certificates. The price for a parcel of certificates is called the 'spot price'. Like any other commodity, the price for certificates is determined largely by supply and demand. Wholesale prices can fluctuate considerably. The graph below shows the fluctuation in certificate prices over the past 6 months.

For detailed price history, please contact us at Green Markets for a quote. http://greenmarkets.com.au/resources/lgc-market-prices

Where and how much of the funding (amount and %) for the Springdale Solar Farm comes from;

1. Overseas (Wircon) and

2. From Government subsidies such as LGC’s and or other feed in tariffs (where are they coming from)?

Why are we not following the lead of other major developed countries in tendering for ground mounted photovoltaic systems?

Germany’s Federal Network Agency (Bundesnetzagentur) has announced its first-ever tender process for ground-mounted photovoltaic systems. The pilot tenders, which were approved late last month through an executive order by Angela Merkel’s cabinet, are designed to act as a test for auctions for other renewable energy technologies until 2017.

The tenders mark the beginning of a new chapter for German clean energy, which has historically flourished with the help of government-sponsored incentives. The tender process will largely eliminate government subsidies in favour of market-driven incentives, meaning newly built solar farms will no longer receive fixed subsidy support under the country’s feed- in tariff. https://www.solarchoice.net.au/blog/news/germany-introduces-incentive-program-for- ground-mounted-solar-farms-020315

Other countries are now tendering for energy from PV systems instead of providing subsidies, this would mean that only the best economic projects would be approved. This process has resulted in drastic reductions in the price of electricity provided from Solar PV’s.

Visual

Figure 20 of the EIS.

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This gives a real estate view of the proposed sight from the bottom of the valley, what about driving into and out of the valley, quite a different perspective.

EIS Figure 22 reveals the topographic view of the area and the impossibility of adequately screening the site.

See my Figure 1 and 8

9.3.4 Glint and glare

The results of the desktop glare hazard analysis identified that for the project, there is no glare hazard predicted to be generated as a result of the operation of the project. Computer modelling of the glare is not sufficient, There needs to be actual testing of glare from various sights with a reflective surfaces equal to the reflectivity of the panels to be used.

10.24 Ramsar wetlands

Although there may not be Ramsar wetlands in the district there are still important wetlands, such as Jerrabomberra Wetlands. Wetland Projects

Since 2006, the ACT Government has developed a number of constructed wetlands to improve Canberra's

urban waterways.

 The Valley Ponds, The Valley Avenue, Gungahlin, Ginninderra Creek Catchment and a number of others

in the ACT-

We have migratory birds flying over the area, including just recently pelicans.

12.2 Existing environment

Figure 24 shows noise sensitive receivers which could potentially be affected by the SSF. A total of 34 residential dwellings were identified as sensitive receivers with the closest receiver being approximately 50 m to the west.

12.2.1 Estimated rating background levels

Minimum rating background levels (RBL) have been assumed for residential receivers in the area based on Table 2.1 of the Noise Policy for Industry.

The relevant RBLs are presented below in Table 33.

Table 33 Rating background levels Time of day Minimum assumed rating background noise level, dB(A)

Day 0700-1800

35

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Evening 1800 – 2200

30

Night 2200 – 0700

30

The noise effect will be partly dependent on the winds on a still day everyone will be affected by the noise of construction, noise of operation and eventually the noise of decommissioning. When we have light winds from the South we hear the traffic noises from Canberra and the explosions of the military at Majura. Otherwise this valley is quiet.

Noise levels should not be taken as to whether they meet a city standard for noise pollution they should be taken as the difference between a baseline from receivers in the 34 neighbours areas and then work out the increase in noise generated by the site that will carry to these neighbours. Renew Estate’s EIS is totally inadequate in determining the change in noise as they have not determined baseline readings in the affected areas.

If Renew Estate were able to get approval based on this uninformed EIS, and used a pile driver for their supports this would definitely affect the whole valley, to the detriment of all their neighbours. Therefore they should move the site to a NSW recommended Renewable Energy Zone where it is not going to affect neighbours.

12.3.2 Operation noise criteria

The NSW Industrial Noise Policy (INP) provides guidance and recommendations on the assessment of noise impacts from industrial and commercial facilities.

The assessment procedure for industrial noise sources has two components that must be satisfied:

and

Please note the statement of noise from industrial and commercial facilities, an industrial facility is inconsistent with a rural area.

Exceedances of 11 dB(A) have been predicted during the site establishment stage at receivers R1, R2, R3 and R5. During the piling/foundations stage exceedances of up to 10 dB(A) have been predicted at R1 and R2. Exceedances of up to 4 dB(A) are predicted at R1 and R2 during the assembly stage.

This is totally unacceptable, I personally work around the farm close to the Springdale site checking, feeding animals and repairing fences and managing weeds, some of the construction is within 20 metres of my boundary fence.

14.1 Existing Environment

Traffic Movement

The Traffic figures quoted in EIS Table 49, are 2008 Bywong Street, 2009 for Tallagandra Lane, 2015 for East Tallagandra Lane and the latest other road figures were 2016.

Population for Gungahlin in 2009 was reported to be 40,900 and 71,000 in 2016 and expected to grow by 19% (ACT Population Projections 2017 to 2020) and Renew Estate are using 2008 and

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2009 figures in their EIS. The population in Sutton area has also increased dramatically as evidenced by the increase in the Sutton School population. Do not allow this project to proceed on road use figures that are obviously so outdated they do not carry any weight.

Before this project proceeds (approved) let there be fresh road statistics, how can a road management plan be formulated based on 2008 figures.

The Sutton Culvert should be re-examined to determine whether it can carry the additional traffic of heavy vehicles in a safe manner. Other routes should be examined that they are not passing Sutton school and Country Bumpkins (Daycare) plus the three ninety degree turns, (See EIS Figure 27) going through Sutton.

Safety, due to increased conflicts with other vehicles, cyclists, pedestrians, stock, wildlife and increased levels of dust. It is noted that many of the local roads have generally low traffic volumes and congestion, and/or high signposted speeds (80 km/h or greater). As such there is the potential for crashes to occur for a variety of reasons (fatigue, speed etc).

Most of the Roads in the area are 100 km/h roads, Sutton Road, East Tallagandra lane, Mulligans Flat Road and Tallagandra Lane. It is used by a high volume of traffic that has increased of late. New figures need to be obtained. Mulligans Flat and East Tallagandra Lane has become a commonly used route for cyclists from Gungahlin to the bakery at Sutton, sometimes in groups of twenty or more, a hazard for trucks traversing the site. Another reason to stop the industrial development.

14.2.3 Decommissioning

The restoration of the land in thirty years time. What guarantees are there, that if the technology of Solar develops or a glut of solar power, (as occurred when ‘Chile literally gave power away, with prices hitting zero in the afternoon, (when production was highest)on a majority of days in 2015 and 2016.’ If this causes the proposed Solar farm to become redundant within 10 years causing the company to go bankrupt, then no restoration of the land would occur. Varun Sivaram, who is described as a solar expert in his book Taming the Sun writes ’Fundamentally , rising solar penetrations degrade the value that solar offers to the electricity grid, regardless of the revenue that a particular solar paradigm guarantees solar owners.’

What state laws have been progressed to counter the potential disaster of premature decommissioning? What guarantees are there that the solar panels would not be recycled and end up in landfill? A future fund should be a part of any approval process so that Decommissioning is inbuilt as part of the establishment cost.

Likely negative impacts include:

13.2)

ity of the area

rounding area

missions

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Potential negative impacts due to the operation of the proposed solar development would include:

y of the Site.

Solar PV plants with a large footprint have the potential to create heat islands producing rising convection currents that could potentially affect the operation of aircraft overflying the area. PV solar panels reduce albedo by making the surface darker and less reflective, leading to increased heat absorption. PV panels although having a low heat capacity can be up to 20°C warmer than the ambient temperature during the day causing the surrounding air mass to heat and rise.

The risk of a rising thermal plume affecting aviation approaching or departing Canberra Airport is considered low given the relatively small temperature differentials producing the thermal plume and the height of aircraft overflying the Site which are typically at least 900 m in altitude. Furthermore the widespread practice of siting large solar plants at airports suggests convection from solar panels is unlikely to be a significant safety issue for aviation activities.

The rising thermal plume may well affect neighbours causing a mini greenhouse effect on the microclimate of the area, with hot air being blown to neighbours on a higher elevation. We know that a rise of a few degrees can affect the world climate, a temperature rise of a few degrees can also affect the fire danger and land productivity in an area.

Air Quality

The project is located in a rural agricultural setting within the Yass Valley where the nearest receptors are the residential dwellings. A total of 34 residential receptors have been identified within a 2 km radius of the Site (refer to Figure 31). The nearest residential dwelling is located approximately 150 m to the north of the Site.

Tintinhull, the 1890’s home, is 150 metres from the site, this is totally unacceptable, move the Solar Farm out west where it will have negligible impact on its neighbours.

19.2.3 Landscape and visual impacts

Noting that there are no other solar or wind farms or large scale developments visible from the Site, there are no cumulative visual impacts.

No other visual impacts from the site, I also see the windfarms from my house yard in the distance, particularly in the late afternoon when the sun is sinking.

21.1 Ecologically sustainable development inter-generational equity, namely, that the present generation should ensure that the health, diversity and productivity of the environment are maintained or enhanced for the benefit of future generations,

My family has been on the land since the 1850’s and the Springdale site was once owned by my Read family relatives. I have three separate blocks that adjoin the Springdale site and it was my hope and their desire that my 3 children would each have a block. If approved each of these blocks would have views of 330,000 Solar panels, associated infrastructure including a substation and amenities block. Two of my Sons have approached Yass Valley Council in preliminary discussions re

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This is not Intergenerational Equity.

i. polluter pays, that is, those who generate pollution and waste should bear the cost of containment, avoidance or abatement,

Yes the polluter should pay, pay for the devaluation of property, Visual pollution of 330, 000 solar panels and other infrastructure, noise pollution in a pristine valley, dust from the earthworks, heavy vehicle traffic on country roads, destruction of trees and habitat. Disruption and breakdown in the local community. They should have to pay so much, to the point that it is not economic for them to build an industrial solar farm in this location.

CONCLUSION

The Springdale Solar Farm proposal should be rejected, based on poor site selection and all the other reasons documented. Please reject this application for The Springdale Solar Farm outright, do not entertain reducing the size or other modifications or mitigations, as an industrial site does not fit into a pristine farming valley 3.5 kilometres from Canberra. This is a rural area that has become home to many people from the city, with the vast majority working in Canberra. Before my retirement I worked at Canberra Hospital and in the ACT Department of Health while also maintaining a working sheep and cattle property with my brother. I am a fifth generation farmer on this land and although Canberra’s encroach is inevitable, an industrial sized solar farm the size of 420 football fields is not. This project would be devastating to the Community and to the future of this area, from agricultural to industrial, stopping the promising agricultural, cottage, art and tourism industries from developing. The site is laughable as an ideal site because it is to be situated in a fog prone valley that cannot be screened. Please consider carefully the opportunity cost of developing a solar farm in a less than ideal position, subsidised by public funds by denying this venture and allowing another venture to use these funds to develop a Solar Farm in an appreciative Community in a Renewable Energy Zone that can fully utilize the Sun’s energy.

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