MORTLAKE PERMIT AMENDMENT APPLICATION

EXPERT WITNESS STATEMENT OF BRETT LANE

ACCIONA Energy Australia Global Pty Ltd

Suite 5, 61-63 Camberwell Road, Hawthorn East, Vic. 3123 P O Box 337, Camberwell, Vic. 3124 Ph. (03) 9815 2111 Fax. (03) 9815 2685 November 2016 Report No. 12020 (6.2) Mortlake Wind Farm – Amendment Application –Witness Statement of Brett Lane Report No.12020 (6.2) CONTENTS 1. WITNESS INFORMATION ...... 1 1.1. Expert witness information ...... 1 1.1.1. Name and address ...... 1 1.1.2. Area of expertise ...... 1 1.2. Information of other significant contributors ...... 1 1.3. Role of Brett Lane ...... 1 2. WORK UNDERTAKEN ...... 3 2.1. Amendment biodiversity assessment...... 3 2.2. Further bird and bat impact assessment ...... 4 2.3. Sources of information ...... 5 3. FINDINGS ...... 6 3.1. Native Vegetation ...... 6 3.2. Birds ...... 9 3.3. Bats ...... 10 3.4. Conclusion ...... 11 3.5. Collision risk ...... 11 4. REVIEW OF SUBMISSIONS ...... 12 5. DECLARATION ...... 18 6. REFERENCES ...... 19

TABLES Table 1: Details of other significant contributors ...... 2 Table 2: Response to submissions ...... 13

APPENDICES Appendix 1: Qualifications and experience of Brett Lane ...... 20 Appendix 2: Qualifications and experience of Elinor Ebsworth, Khalid Al-Dabbagh and Bernard O’Callaghan ...... 23 Appendix 3: Analysis of additional potential bird flights at risk for the largest possible turbine designs...... 30

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1. WITNESS INFORMATION

1.1. Expert witness information

1.1.1. Name and address Brett Alexander Lane Brett Lane & Associates Pty Ltd Suite 5, 61-63 Camberwell Road Hawthorn East, Vic. 3123

1.1.2. Area of expertise Brett Lane has extensive expertise in terrestrial ecology and related legislation and policies. He has particular expertise in the impacts of wind farms on wildlife, having advised on such impacts for over 80 projects throughout Australia, from pre-feasibility assessments to post-operational monitoring and reporting programs. His qualifications and experience are summarised in Appendix 1.

1.2. Information of other significant contributors The names, addresses and areas of expertise of other significant contributors to this report, and associated background reports, are presented in Table 1.

1.3. Role of Brett Lane I confirm that my role in the assessment of the Mortlake Wind Farm has been: . Project Director and internal peer reviewer for the original ecological assessments of the proposed wind farm (2007 onwards); . Project Director and internal peer reviewer for the 2015 and 2016 re- assessment of bird and bat impacts of the revised turbine design that is the subject of the exhibited amendment application; and . Preparation of this witness statement.

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Table 1: Details of other significant contributors

Location of summary of Name of contributor Address Area of Relevant Expertise qualifications and expertise Brett Lane & Associates Pty Ltd Ecological assessment, including native Elinor Ebsworth Suite 5, 61-63 Camberwell Road, Appendix 2 vegetation and flora. Hawthorn East, Vic. 3123 Brett Lane & Associates Pty Ltd Bird and bat utilisation surveys and data Khalid Al-Dabbagh Suite 5, 61-63 Camberwell Road, Appendix 2 analysis Hawthorn East, Vic. 3123 Brett Lane & Associates Pty Ltd Project Manager, Wind farm ecological Bernard O’Callaghan Suite 5, 61-63 Camberwell Road, Appendix 2 impact assessments Hawthorn East, Vic. 3123

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2. WORK UNDERTAKEN Brett Lane & Associates Pty Ltd (BL&A) completed an assessment of the impacts of modifications to the turbine specifications and layout of the Mortlake Wind Farm on biodiversity in 2015 and 2016, the results of which have been compiled in the flora and fauna report that accompanied ACCIONA’s August 2016 Amendment Application (Appendix 11). The report was: . BL&A (2016) ‘Mortlake Wind Farm – Biodiversity impact assessment of modified project design.’ Report 12020 (5.9) to ACCIONA Energy Australia Global Pty Ltd. The work undertaken is summarised below.

2.1. Amendment biodiversity assessment This report considered the following biodiversity attributes and compared impacts of the original permitted turbine design with an amended turbine design: . Native vegetation; . Birds (including the Brolga); and . Bats (including the Southern Bentwing Bat). Native vegetation work undertaken for the amendment application is summarised below. . Whereas the original layout of the ‘Mortlake South’ wind farm avoided any impacts on native vegetation, assessment of the amended layout (BL&A 2016) addressed impacts on eight small areas of potential remnant native vegetation on roadsides and in a former railway reserve from access tracks and underground power cabling. . The amended wind farm layout was assessed in accordance with the native vegetation permitted clearing regulations that are currently applicable, namely the biodiversity assessment guidelines (DEPI 2013). . During the 16th November 2016 site visit, each of these eight areas was revisited to determine if, after a spring growth season, native grass species were evident at greater than 25% perennial cover (and greater than 50% cover in the case of the EPBC Act listed threatened community: Natural Temperate Grassland of the Victorian Volcanic Plain, or NTGVVP). Bird impact work undertaken for the amendment application is summarised below. . The original Mortlake South wind farm bird utilisation survey data were collected at bird flight height intervals corresponding only with the turbine specifications at the time (i.e. below, at or above an RSA height of 40 to 120 metres). Therefore it was not possible to directly compare the impacts on birds of turbines of different dimensions and heights. . To enable an assessment of turbines of different dimensions and heights, data from later surveys at ten other inland sites in mainland south eastern Australia were pooled to determine the percentage of birds flying at 10 metre

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intervals up to 40 metres. The August 2016 report assesses impacts based on the percentage of birds flying at different heights from this pooled data set. . During the native vegetation assessment in November 2015, it was obvious that there had been no significant changes in land use, farming activities or revegetation works. For this reason, the original 2007 bird utilisation survey results were still considered representative of bird species and relative abundance on the site and, therefore, a valid basis for assessing the impacts on birds of the amended turbine layout and specifications; with the exception of flight heights for which other data were relied upon (see previous point). Bat impact work undertaken is summarised below: . A qualitative assessment of bat impacts from the amended wind farm design was undertaken based on a combination of a lowering of the RSA (increasing risk to bats) and a reduction in the number of turbines partly off-setting this increased impact. Consideration was also given to the species of bats recorded during the 2007 bat utilisation surveys and whether threatened species would be affected. . During the native vegetation assessment in November 2015, it was noted that there had been no significant changes in land use, farming activities or revegetation works. For this reason, the original 2007 bat surveys results were still considered representative of the bats on the site and, therefore, a valid basis for assessing the impacts on bats of the amended turbine layout and specifications.

2.2. Further bird and bat impact assessment The impacts on bird and bats of the original and two possible amended turbine designs have been further assessed in this witness statement using a more refined quantitative approach (see below). The turbine layouts and designs assessed in this statement are described below: . The original turbine specifications assessed by BL&A comprised: o Tower height of 80 metres; o Blade length of 40 metres (diameter of 80 metres); o Rotor Swept Area (RSA) maximum height of 120 metres above the ground; and o RSA minimum height of 40 metres above the ground. . The largest possible, highest turbine design assessed in this statement is: o Tower height of 120 metres; o Blade length of 66 metres (132 metres diameter); o RSA maximum height of 186 metres above the ground; and o RSA minimum height of 54 metres above the ground. . The largest possible, lowest turbine design assessed in this statement is: o Tower height of 84 metres; o Blade length of 66 metres (132 metres diameter); o RSA maximum height of 150 metres above the ground; and o RSA minimum height of 18 metres above the ground.

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In addition, the number of turbines proposed is to be reduced from 51 to 42. This has been taken into consideration in comparing the former with the amended turbine designs and layout. The more refined, quantitative approach involved comparing an assumed number of bird flights that could pass through the circular RSA plane of the original turbine design with that of the two modified turbine designs. This involved generating a ratio of assumed bird flight numbers of the latter to the former. The model assumed all flights were perpendicular to the RSA, which is clearly not realistic as flights can approach the RSA from any direction. However, as there is no empirical basis for generating an alternative scenario, this is therefore a ‘worst case’ comparison but one that still informs decision-making. A summary of the findings is presented in Section 3 of this statement and the modelling is described in Appendix 3.

2.3. Sources of information Each of the above assessments involved reviewing the bird utilisation survey data for the Mortlake Wind Farm, collected in September 2007 (BL&A 2009). These data were still considered valid as there have been no significant changes in agricultural practices in the area to indicate bird species composition and activity would be substantially different. This was confirmed during the native vegetation assessment of the site in November 2016. As the original data did not enable comparison of flight heights with amended turbine specifications, data from more recent bird utilisation surveys at ten other similar sites in south eastern Australia were collated (BL&A unpublished data). Since the Mortlake surveys, wind turbine technology change has accelerated. In anticipation of this, BL&A’s more recent bird utilisation surveys (i.e. since the original Mortlake surveys) have recorded bird flight height in 10 metre intervals up to 60 metres, then in 20 metre intervals up to 140 metres. Above this height, judging height to this level of precision is challenging. When the original Mortlake bird utilisation survey was undertaken, bird fight height was only recorded below, at, and above RSA height according to the turbine specifications at the time (i.e. below 40 metres, between 40 and 120 metres and above 120 metres). The purpose of the more recent field data recording method was to provide more accurate information on the level of bird activity at different heights so that the impact of any lowering of the height of the minimum RSA height on birds could be assessed. Although species composition differed slightly among these sites, using flight height data from these sites to understand impacts below 40 metres above the ground was considered valid for use as a quantitative estimate, as 95.4% of birds observed at these sites were recorded at less than 40 metres above the ground compared with 93.7% at Mortlake, a very similar bird flight height distribution.

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3. FINDINGS A summary of BL&A’s findings in relation to native vegetation is presented below. This is followed by summaries of BL&A’s findings in relation to the impacts on birds and bats of the largest possible turbine designs compared with the turbine design originally assessed by BL&A. The detailed calculations on which this comparison is based are presented in Appendix 3 to this statement. The findings are summarised for birds and bats separately below.

3.1. Native Vegetation The proposed layout changes were considered to result in the following impacts to vegetation classed as “potential native vegetation” (see Figure 1 on the August 2016 BL&A report). These were: . Three site access points that impact potential native vegetation along Grinters Lane (areas of impact 1, 3 and 4); . Three cable crossings that impact potential native vegetation along Grinters Lane (areas of impact 2, 5 and 6); and . Three cable crossings that impact potential native vegetation along the disused rail reserve (areas of impact 7 and 8). The above impacts (areas of impacts one to eight) were considered in that report to result in the potential removal of up to 0.314 hectares of native vegetation. However, the information gathered from an additional visit to each site on 16th November 2016 indicated that no remnant native vegetation existed at any of the eight sites considered. The sites were dominated by exotic pasture grasses and other weeds, including Canary Grass, Lesser Canary Grass, Yorkshire Fog, Annual Meadow Grass, Perennial Rye Grass, Sweet Vernal Grass, Tall and Soft Brome, Plantain, Spear Thistle, Mallow and Common Vetch. Two example sites (site 1 and 4) are shown on the next page. Thus, no permit to remove native vegetation will therefore be required for the amended wind farm layout.

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Potential native vegetation site 1 (refer to BL&A 2016 for location of site numbers)

Potential native vegetation site 3 (refer to BL&A 2016 for location of site numbers)

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Potential native vegetation site 6 (refer to BL&A 2016 for location of site numbers)

Potential native vegetation sites 7 and 8 (refer to BL&A 2016 for location of site numbers)

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3.2. Birds . Birds most exposed to collision risk from turbines at Mortlake Wind Farm are native and introduced species adapted to agricultural landscapes that are abundant and widespread in south eastern Australia, with no species listed on the FFG Act or EPBC Act as rare or threatened are considered to be at risk. As reported in BL&A (2009), the most abundant bird species on the Mortlake South site during the spring 2007 bird utilisation surveys were English Skylark, Australian Magpie, Raven spp. and Common Starling. These four birds accounted for 82% of all birds observed during the survey. There were comparatively few other species on the site. . During the site inspection on 16th November 2016, it was evident that the most abundant bird species throughout the wind farm site were still these four species, with Skylark and Australian Magpie being particularly evident. . The greatest change in area of RSA arises from the increase in area of the RSA above 40 metres, a zone where only four to six percent of birds are active. . Lowering the RSA by 22 metres to 18 metres above the ground will affect birds flying in the zone below 40 metres above the ground that was previously unaffected by the originally assessed wind turbine. For the purpose of this assessment, the lowest RSA height has been assumed to be 20 metres above the ground as bird flights have been recorded at this height in 10 metre increments only. It is unlikely that the additional two metre drop to 18 metres above the ground would significantly affect these findings. In total, birds in the 20 to 40 metre height zone represent an average across ten sites of over 33 percent of all birds recorded during bird utilisation surveys. This represents the greatest difference in potential bird impact between the permitted and largest possible turbine designs. Figure 1 in Appendix 3 shows this zone. . The consequence of the largest possible turbine design was calculated by assuming that bird flights through the RSA in both the original and current assessments were perpendicular to the RSA (i.e. to the plane in which the turbine blades rotate). For both the lower and higher turbines the same survey area was used (i.e. up to 180 metres above the ground) to ensure comparability of estimated flight numbers affected. . This analysis for the lowest, largest possible turbine found an increase in the maximum possible number of birds flying through the RSA of over four times (4.52 – see Appendix 3). The main reason for this is the drop in RSA height to approximately 20 metres instead of 40 metres above the ground, a zone of greater bird activity. The same analysis for the highest, largest possible turbine, found a decline in the number of birds flying through the RSA to about 85% of that for the original assessed turbine. This was because only about five percent of birds occur within the RSA height of this turbine design. . As explained in Appendix 3, assuming bird flights are perpendicular to the RSA means that this estimate is conservative and worst case, and represents a highly unlikely maximum possible proportional increase in turbine impact from collision, which was not assessed.

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. Given the species of birds involved (common native and introduced species not listed as rare or threatened), the impacts of the modified turbine design on birds were not considered to be of conservation concern. This is because the species most affected are abundant, widespread and not threatened so population-scale consequences from the difference in turbine design are negligible.

3.3. Bats . As ultrasonic bat detectors only record the number of bat calls, not the number of individual bats, it is possible to identify those bat species utilising the wind farm, but it is not possible to record absolute number of bats in the same way as for birds. . The bat surveys in 2007 used ultrasonic bat detectors deployed at ground level at Mortlake Wind Farm. Recording of bat activity above 25 metres above ground level was not undertaken at Mortlake, thus impacts of the change in turbine design were assessed based on pooled bat detector data from recording heights of 25 and 50 metres above the ground from other sites in similar settings in south eastern Australia (BL&A unpubl. records). As bat detectors generally do not record bat calls beyond about 25 metres and for some species less, a 25 metre height separation can be assumed to be sampling different height zones. . These data show that at 50 metres above the ground bat call numbers are about 15% of the number recorded from ground level. At 25 m above the ground numbers are about 25% of the number recorded from ground level. The proposed change in turbine height and cross-sectional area occurs in the recording zone sampled at 25 metres and above. Therefore, the increased potential collision risk for bats occurs in the zone where 28% of bat activity occurs, indicating that a minority of bat flights would still pass through the revised RSA. The difference between the original and largest possible turbine design (lower) drops turbine blades into a zone of higher bat activity (i.e. between 25 and 50 metres), representing an up to an additional 17% of bat activity occurring within the RSA. The difference between the original and largest possible turbine design (higher) puts turbine blades into an additional zone likely to have very little bat activity (i.e. between 120 and 186 metres). . The same pooled bat data (BL&A, unpubl. data) indicate that species diversity at 50 metres is lower, with recorded bats dominated by higher-flying species such as White-striped Freetail Bat and Gould’s Wattled Bat. . Given the species of bats involved (common, widespread species in agricultural landscapes in south eastern Australia and no species listed under FFG Act or EPBC Act as rare or threatened) and the small additional proportion of bat activity in the larger RSA for the lower design, the added impacts of the largest possible turbine design (lower) are unlikely to lead to effects on bat populations of conservation concern. The difference in impact of the largest possible turbine design (higher) on bats is likely to be negligible given that much of the increased RSA is at a height with very little bat activity.

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3.4. Conclusion The information gathered from an additional visit to each site on 16th November 2016 indicated that no remnant native vegetation existed at any of the eight sites considered. Thus, no permit to remove native vegetation will therefore be required for the amended wind farm layout. In conclusion, the largest possible turbine designs will not have a significant additional impact on birds or bats of conservation concern under applicable threatened species legislation or policies including under FFG Act or EPBC Act.

3.5. Collision risk A comparative bird collision risk modelling exercise for alternative turbine designs was not considered necessary to inform decision-making as the amended turbine layout and design affect only common, widespread species of agricultural landscapes in south eastern Australia. No threatened species are considered to be at risk from the amended design. Collision risk modelling for birds would likely result in a lower estimated number of birds interacting with the RSA that the current analysis. This is because the current analysis assumes all bird flights arrive perpendicular to the RSA whereas in reality they approach from varying angles, meaning that many flights will pass through the RSA height zone without interacting with the actual plane in which turbine blades are rotating. Notwithstanding this, if the difference between turbine designs in the number of flights that could result in collisions with turbine blades flights is the same then this will result in a similar ratio of collision rate for the original to the largest possible turbine designs.

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4. REVIEW OF SUBMISSIONS Of the 36 submissions received by the state Minister for Planning, six raised concerns about flora and fauna impacts of the proposed revised turbine specifications and layout. Table 4 summarises the issues raised by each of these six submissions and provides a consolidated response to the issues raised.

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Table 2: Response to submissions

Issue raised Submission Response numbers

Monitoring program needs 17, 21, 23, The EPBC Act approval provides for a five-year bird and bat impact monitoring program. The to be kept at five years, not 27, 32 rationale for this Commonwealth requirement is not clear. reduced to two years. It is possible to ascertain the rate at which wind turbines strike birds and bats after two years of carcass searching. Five years will not significantly change the estimated rate of bird and bat strike. It may gradually increase the number of species found but the rate at which birds are detected is low (3% of searches for birds and 2% of searches for bats, BL&A, unpubl. data). The rate for threatened birds is 0.0004, or 0.045% of searches (i.e. one in 2,500 searches). As indicated in Section 3.2 of this statement, the most abundant birds on the Mortlake South wind farm site are common farmland species, including an abundance of introduced species. Most of the birds found to date under turbines (based on 6,600+ searches) belong to a handful of common farmland or common raptor species (BL&A, unpubl. data). Wind farms pose a negligible risk to threatened bird and bat species where these occur infrequently, which is the case at the Mortlake Wind Farm. These findings indicate that a five year monitoring program is not warranted.

Increased impacts on birds 19, 23 The extent of the increased impact on birds is described in more detail in this witness statement. and bats, including Wedge- As indicated, the birds that will be affected by the wind farm are the common farmland birds that tailed Eagles, Brolgas and are widespread in south eastern Australia so the increased impact is not of conservation concern. owls, The Wedge-tailed Eagle was not recorded on the site during the bird utilisation surveys, which indicates that it occurs at a very low utilisation rate. Impacts on this raptor will therefore not be significant as the probability of regular enough collisions to affect the population (which numbers in the tens of thousands (Olsen 2005)) is extremely low. There are few habitats for owls on the site. The occasional Barn Owl may move through the site,

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Issue raised Submission Response numbers particularly after wet years inland. No owls have been recorded during BL&A carcass searches of 10 wind farms in southern Australia as striking operating wind turbines in Australia, suggesting strongly that this group is not particularly affected by wind turbines. As outlined in the biodiversity impact assessment of the modified project design (BL&A 2016), no significant impacts on the Brolga are likely. As indicated in BL&A (2009), the site lies generally to the south of the usual range of the Brolga in this part of Victoria. More recent VBA records indicate that this is still true. There have been few additional records in the VBA and, as explained in the amendment report (BL&A 2016), the new VBA records of the Brolga attributed to BL&A by a third party were mapped in the wrong location. There has been one instance of the Brolga appearing in the area (in October 2013) and a rapid follow up survey of two days failed to locate it, indicating that it had moved on. The conclusion that the site is unlikely regularly to support the Brolga is still valid. Furthermore, all evidence shows that turbines will not lie within the default breeding and flocking site turbine free buffers (respectively 3.2 km and 5 km) proposed in DEPI (2012) of any Brolga breeding or flocking site. Therefore, the likelihood of significant impacts on the Brolga arising from the amended turbine design is negligible.

Factual basis of avifauna 27 The factual basis of the assessment of the effects on birds and bats of the modified turbine and bat impact assessment design is adequate for decision-making. Surveys consistent with the AusWEA (2005) guidelines is inadequate have been undertaken and were considered acceptable for making decisions on the original Mortlake South proposal by the decision-maker. (Note that the Mortlake East proposal was refused as a consequence of the Brolga information not being considered adequate for decision- making; the Mortlake South proposal was approved). Apart from the passage of time, nothing has changed significantly at the wind farm site to indicate that additional bird surveys are required. The current statement and the information in BL&A (2016) demonstrates that the information collected on the site in 2007 remains valid. This, combined with a more recent analysis of bird

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Issue raised Submission Response numbers flight heights and their implications presented in this statement, are sufficient to inform a decision on the acceptability of the changed impacts on birds and bats of the proposed modification.

The cumulative impact of 32-Moyne As the proposed modifications to the wind farm design affect common, widespread bird and bat the wind farm on avifauna SC species of agricultural landscapes in south eastern Australia, the cumulative impacts of the and bats should be changes is not considered to be of conservation concern. considered

The impact of the wind farm 32-Moyne The impacts of the project on the Brolga have been considered, in BL&A (2009), supplemented by on the Brolga should be SC BL&A (2016) and earlier responses to submissions above. considered

Impacts on native 32-Moyne The impacts on potential native vegetation of the modified wind farm layout have been considered vegetation, particularly on SC and no native vegetation will be affected by the proposed layout changes. No permit to remove public road reserves should native vegetation under Cl. 52.17 of the Planning Scheme is required. be carefully considered.

No consideration given to 32-Moyne The original impact assessment for the Mortlake South Wind Farm (BL&A, 2009) identified the actual size and height SC common, widespread bird species as dominating the avifauna of the area where wind turbines differences in the RSA in were proposed. There are no indications that the landscape has changed since the work done at terms of the increased the site (confirmed by a site visit) to indicate that the mix and abundance of birds would be any impact on birds. different. The conclusion that the site is not home to any regular or significant numbers of any threatened bird or bat species still holds. The increase in RSA from the original 5,027 m2 up to 13,686 m2 will increase the airspace occupied by the turbine blades. The additional analysis in this witness statement showed that most of the increase in RSA occurs

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Issue raised Submission Response numbers above 40 metres, where bird activity is comparatively low (i.e. about four to five percent of observed birds were above this height). Given this, it has been estimated that over four times more bird flights will be exposed to collision risk by the proposed amended design compared with the original design. This increased potential for collision is not considered of conservation concern as it affects common, widespread bird and bat species adapted to agricultural landscapes. The proposed change will not change the impacts of the project on threatened bird and bat species as none occurs in the area consistently or in significant numbers.

Bird survey data is out of 32-Moyne The site of the Mortlake Wind Farm lacks extensive remnant indigenous ecosystems. The entire date and/or unsuitable for SC site has been modified extensively for intensive agricultural uses, such as stock grazing and assessing bird impacts of cropping. This has removed all native habitats from the site. The species of birds that occur on the changed turbine the site are therefore common, widespread farmland species, including an abundance of dimensions and an up to introduced species (see Section 3.2 of this statement). date bird survey should be There has been no significant change in land use based on a site inspection (16th November undertaken to inform the 2016). Review of Google Earth imagery indicates that a small area in the north-east of the site impact assessment may have been converted from pasture to cropping in the intervening period but this represents a minor change in the ecological character of the site that would not change the avifauna significantly. Notwithstanding the passage of nearly ten years, neither bird habitat choice, which is fixed, nor the nature of the habitats on the site have changed. Re-surveying the site for birds is therefore not warranted.

An updated assessment of 32-Moyne The impacts of the project on the Brolga have been considered in BL&A (2009), supplemented by the impacts of the project SC BL&A (2016) and earlier responses to submissions above. As there are few records of the species on the Brolga should be on or within five kilometres of the Mortlake South Wind Farm and no significant wetlands on the

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Issue raised Submission Response numbers undertaken consistent with site, Level 2 and Level 3 assessments (as set out in DEPI 2012) are not required. the Victorian Brolga and wind farm guidelines (DEPI, 2012)

The adequacy of the bat 32-Moyne The same arguments outlined above in relation to the validity of the bird impact assessment for surveys from 2007 for the SC the modified wind farm design also apply to the bat impact assessment. It is noted that a very current assessment need to small number of calls from the Southern Bentwing Bat were recorded, indicating low activity levels be considered and, therefore, a very low risk of a significant impact on this threatened species.

The wording of the Bat and 32-Moyne The proposed wording provides for a BAM plan that enables unexpected significant impacts on Avifauna Management Plan SC species of conservation concern to be identified and provides for appropriate responses in the (BAM Plan) condition should event of such an impact being detected. be considered in the light of Council’s difficulties in enforcing these on other projects.

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5. DECLARATION I have made all the inquiries that I believe are desirable and appropriate and no matters of significance which I regard as relevant have to my knowledge been withheld from the Panel. Signed:

Brett Alexander Lane Director Brett Lane & Associates Pty Ltd Suite 5, 161-163 Camberwell Road, Hawthorn East, Vic. 3123

5th November 2016

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6. REFERENCES BL&A (2009) ‘Mortlake East and South Wind Farms Ecological Assessment.’ Consultant’s report to Acciona Energy Australia Pty Ltd, Report 7128 (2.8). BL&A (2016) ‘Mortlake Wind Farm, Biodiversity Impact Assessment of Modified Project Design.’ Consultant’s report to Acciona Energy Australia Global Pty Ltd, Report 12020 (5.9) DEPI (2012) Rev. 1. ‘Interim guidelines for the assessment, avoidance, mitigation and offsetting of potential wind farm impacts on the Victorian Brolga population, 2011’. DEPI, East Melbourne. DEPI (2013) ‘Permitted clearing of native vegetation – biodiversity assessment guidelines.’ DEPI, East Melbourne DELWP (2015) ‘Permitted clearing of native vegetation - biodiversity assessment handbook – version 1.0’ DEPI, East Melbourne.

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Appendix 1: Qualifications and experience of Brett Lane

Page | 20 Brett Lane Principal Consultant and Director

Profile Brett has over 35 years’ experience in ecological research and management. He has worked in a range of positions with environmental consultancies in Melbourne and Brisbane and with non‐government environmental groups in Australia and East Asia. He has specialist knowledge in birds and wetlands, and extensive experience in ecological impact assessment, including in the infrastructure, renewable energy, property development and mining industries. Brett has undertaken and managed many hundreds of ecological assessments and prepared and reviewed documents that have accompanied development applications on behalf of private companies, government infrastructure agencies and private individuals. His extensive experience has given him an excellent knowledge of the regulatory environment relevant to native vegetation, flora and fauna and he can advise on the scope of scientific information needed to inform the development assessment and decision‐making process. He has also defended his scientific work as an expert witness in courts and tribunals. Brett founded BL&A in 2001.

Biography Key Skills Working in industry since 1979  Qualifications  Experienced advisor on state and federal biodiversity BA (Zoology & Physical Geography) Monash University legislation and policy Certificates and Licenses Management Authorisation – Salvage and Translocation  EPBC Act and EES Referrals Victorian Animal Ethics Approval Employment History  Preparation of environmental assessment reports 2001 – present (preliminary documentation, public environmental Director, Brett Lane & Associates Pty Ltd, Melbourne report and environmental impact statement) 1999 – 2000  Preparation of native vegetation planning permit Natural Resource Specialist, PPK Environment & applications Infrastructure Pty Ltd, Melbourne 1996 – 1998  Design of developments to comply with biodiversity Senior Ecologist, Ecology Australia Pty Ltd, Melbourne legislation and policies 1993 – 1996  Expert witness for VCAT, planning panels and courts Principal Terrestrial Ecologist, WBM Oceanics Australia, Brisbane  Ecological risk assessment 1991 – 1993 Assistant Director (East Asia), Asian Wetland Bureau,  Native vegetation assessment Kuala Lumpur, Malaysia 1987 – 1991  Terrestrial fauna assessment and wetland ecology Director, Brett A Lane Pty Ltd (Melbourne) 1980 – 1986  Ornithologist specialising in wetland and migratory Wader Studies Co‐ordinator, Royal Australasian shorebirds Ornithologists’ Union (now Birdlife Australia,  Wind energy development specialist and minimizing Melbourne impacts on wildlife including collision risk modelling 1979 Research Assistant, Kinhill Planners Pty Ltd., Melbourne

Project Examples Property Development Eynesbury Township, Eynesbury, Victoria: Flora, Fauna and Habitat Hectare Assessment, Targeted Flora Surveys, Growling Grass Frog Survey, Plains‐wanderer Survey and Development of an Offset Tracking Tool. Net Gain Analysis for Planning Permit Applications of subsequent stages and advice on offset management (2003 – present) Taylors Rd, Sydenham, Victoria (Broadcast Australia):t EPBC Ac Referral, preparation of EPBC Act Public Environment Report (PER), Offset Site Search and Offset Management Plan, Spiny Rice‐flower Propagation and Translocation Plans, Seed Collection (2006 – present) Somerfield Estate, Keysborough, Victoria: Flora, Fauna and Growling Grass Frog Survey and Offset Plan Preparation, preparation of offset tracking reports for each stage of development (2008 – present) Modena Estate, Burnside, Victoria: Flora and Fauna Assessment, targeted threatened species surveys, EPBC Act referrals and assessment approvals, development of offset and mitigation plans (2002 – present) Renewable Energy , Dundonnell, Victoria: Overview and Targeted Assessments including Brolga, bat, migratory bird, Striped Legless Lizard, Flora Surveys, assessment of powerline route and road access options, EPBC Act Referral, Input to EES Referral, preparation of EES technical appendix on flora and fauna, Brolga impact assessment, collision risk modelling (2009 – present) Granville Wind Farm, Granville Harbour, Tasmania: Overview Assessment, targeted surveys including Orange‐bellied Parrot and bat surveys, EPBC Act Referral and advice for regulator negotiations (2011 – present) , MacArthur, Victoria: Overview assessment, detailed flora and fauna surveys, impact assessment, input to EPBC Act Referral and state EES, assessment of powerline and road rout options, appearance at state Planning Panel hearings as expert witness, preparation of pre‐construction and operational flora and fauna management plans, net gain analysis and identification of suitable offsets (2004 – 2012) , Victoria: Overview assessment, native vegetation and threatened flora surveys, targeted threatened fauna surveys, assessment of powerline and road route options, offset site sourcing and assessment, preparation of expert witness statement and appearance at VCAT (2010 ‐ 2015) Mt Gellibrand Wind Farm, Mt Gellibrand, Victoria: Overview assessment, detailed flora and fauna surveys, including targeted Brolga and migratory bird surveys, and Striped Legless Lizard tile grid surveys, input to state planning permit application, preparation of witness statement and appearance at state Planning Panel hearing, preparation and early implementation of pre‐ construction flora and fauna management plans, including bat and avifauna management plan, native vegetation mapping, offset mapping, development of Brolga monitoring and mitigation strategies (2004 – present). Road and Rail Infrastructure Avalon Airport Rail Link, Little River, Victoria: Flora and Fauna Mapping, Constraint Analysis and Net Gain Analysis (2011 – 2013) Dingley Bypass, Keysborough, Victoria: Flora and Fauna Assessment, including targeted flora surveys, habitat hectare assessment and Net Gain analysis, expert witness at VCAT case (approved) (2008 – 2014) Nagambie bypass, Nagambie Victoria: Flora and Fauna Assessment, including habitat hectare assessment and Net Gain analysis (2008) Second Murray River Bridge Crossing at Echuca‐Moama: Detailed Flora Assessment, Targeted Flora Survey (2008 – present) Ecosystem Monitoring and Management Scientific Review Panel, Kerang Lakes Bypass project (North Central Catchment Management Authority, Goulburn Murray Water): Scientific review of detailed technical reports to inform decisions of water savings plans and associated watering plans for five wetlands that form part of the Ramsar‐listed Kerang Lakes wetlands system. (2013) Northern Victoria Irrigation Renewal Program (NVIRP): Assessed the impact of a major federal water industry investment project on Matters of National Environmental Significance, including threatened flora, threatened fauna and listed migratory birds using wetlands located in the potential impact area. (2009‐2011)

Mortlake Wind Farm – Amendment Application –Witness Statement of Brett Lane Report No.12020 (6.2)

Appendix 2: Qualifications and experience of Elinor Ebsworth, Khalid Al-Dabbagh and Bernard O’Callaghan

Page | 23 Elinor Ebsworth Senior Ecologist

Profile

Elinor is a competent ecologist with over four years’ experience in ecological consultancy. She completed a Bachelor’s degree in Science (Honours) at the University of Tasmania and has worked for BL&A since 2015. During her time as a consultant, Elinor has worked on numerous projects involving ecological assessments, management and monitoring. Her reporting experience includes assessments under the Biodiversity Assessment Guidelines, formulation of environmental management plans and preparation of ecological monitoring reports.

Biography Key Skills Working in industry since 2012  Native vegetation assessments

Qualifications  Vegetation monitoring BSc Geography and Environmental Studies, University of  Habitat hectare assessments Tasmania, Hobart Employment History  Listed Flora assessments

2015 - present  Fauna habitat assessments Senior Ecologist, Brett Lane and Associates Pty Ltd, Victoria  Targeted surveys for listed species 2014 - 2015  Ecological monitoring Research Associate, Environmental Change Biology (Bowman) Lab, University of Tasmania  Offset site selection 2012—2014 Botanist, GHD Pty Ltd, Victoria 2006—2009 (casual) Environmental Management Officer, Hobart Water, Tasmania

Project Examples Property Development Bacchus Marsh Grammar School, Staughton Vale, Victoria: Flora and Bushfire Assessment, including habitat hectare assessment (2015) Bellarine Highway, Point Lonsdale, Victoria: Flora and Fauna Assessment, including habitat hectare assessment (2015) 15 Bowmans Lane, Keysborough, Victoria: Flora and Fauna Assessment, including habitat hectare assessment (2015) Braemar College road widening for access, Woodend: Flora and Fauna Assessment, including habitat hectare assessment (2016) Cave Hill Quarry, Lilydale, Victoria: Updated Flora and Fauna Assessment, including habitat hectare assessment (2015) Centre Road, Berwick, Victoria: Flora and Fauna Assessment, including habitat hectare assessment (2015) Citation Reserve, Mount Martha, Victoria: Flora and Fauna Assessment, including habitat hectare assessment (2015) Donnybrook Road, Donnybrook, Victoria: Determination of Matters of National Significance within the Melbourne Strategic Assessment Area (2015) Honda MPE Hume Highway, Somerton, Victoria: Flora and Fauna Assessment, including habitat hectare assessment (2015) Inverloch RACV Resort, Inverloch, Victoria: Offset Monitoring including flora quadrats, photo point and pest animal monitoring (2015) Modeina, Burnside, Victoria: tagging of Spiny Rice‐flower (2016) Mullane Road, Pakenham, Victoria: Flora and Fauna Assessment, including habitat hectare assessment (2016) Stamford Park, Rowville, Victoria: Flora and Fauna Assessment, including habitat hectare assessment (2015‐2016) St Andrews Beach Golf Course: Flora and Fauna Assessment, including habitat hectare assessment; Bushfire assessment (2016) Victorian Volcanic Plain, Western Victoria: Searches for Matters of National Significance (including NTGVVP and Spiny Rice‐ flower) within potential offset sites (2015) Waverley Golf Club, Rowville, Victoria: Flora and Fauna Assessment, including habitat hectare assessment (2015‐2016) Renewable Energy , Ararat, Victoria: Revised vegetation assessment and Pest Animal Monitoring (2015) Berrybank Wind Farm, Berrybank, Victoria: Desktop native vegetation assessment for revised layout (2015) Dundonnell Wind Farm, Dundonnell, Victoria: Transmission line Native Vegetation Assessment, including habitat hectare assessment and targeted surveys (2015) Kiata Wind Farm, Kiata, Victoria: Desktop native vegetation assessment for revised layout (2015) Ryan Corner and Hawkesdale Wind Farms, Victoria: Desktop native vegetation assessment for revised layout (2015) Salt Creek Wind Farm, Hexham, Victoria: Access track overview assessment (2015) Road and Rail Infrastructure Murray River Crossing ‐ Echuca, Victoria and Moama, New South Wales: Masked Owl Habitat assessment (2016) Murray River Crossing ‐ Echuca, Victoria and Moama, New South Wales: Squirrel Glider Habitat Linkage Strategy (2015) Telecommunications Infrastructure NBN Tower, Goughs Bay, Victoria: Flora and Fauna Assessment, including habitat hectare assessment (2015) NBN Tower, Lovely Banks, Victoria: Flora and Fauna Assessment, including habitat hectare assessment (2016)

Dr. Khalid Al Dabbagh Senior Zoologist

Profile

Khalid has over 35 years’ experience in Zoology, specialising in ornithology and animal ecology. Khalid has extensive experience in identifying fauna species and their habitat as well as undertaking impacts assessments for a wide range of other projects types. Khalid is particularly experienced in assessing development impacts on birds and bats. He has helped to prepare environmental management plans and mitigation recommendations for numerous projects. Khalid has worked on over 50 wind farm projects, undertaking bird utilisation studies, bat surveys and bird and bat mortality estimates.

Biography Key Skills Working in industry since 1980  Ornithologist

Qualifications  Implementation of bird and bat management plans at PhD (Animal Population Ecology), University of Leicester, wind farms England  Mortality assessment at wind farms MSc (Ornithology), University of Baghdad BSc (Biology), University of Baghdad  Terrestrial Fauna Assessments Certificates and Licenses  Targeted surveys for listed flora and fauna species Management Authorisation – Salvage and Translocation Construction Induction ‘White Card’  Bird and Bat Utilisation Surveys Employment History  Scoping assessments 2002 – Present  Zoologist & Ecologist, BL&A, Melbourne. Management plan preparation for listed fauna values 1994– 2002 and offset sites Section Editor, Handbook of Australian, New Zealand  Striped Legless Lizard salvage protocol implementation and Antarctic Birds, Birds Australia, Melbourne 1993 – 1994  Project design recommendation Research assistant, Arthur Rylah Institute for Environmental Research, Heidelberg, Victoria  EPBC Act and EES Referrals 1980 – 1992  Offset site selection Senior lecturer, University of Baghdad, Iraq. 1983 – 1989 Senior research Scientist, Iraqi Biological Research Centre 1976 – 1983 Lecturer, University of Basrah, Iraq

Project Examples Property Development Manor Lakes, Wyndham Vale, Victoria: Flora and fauna assessment and targeted fauna surveys (2010–2011). Eynesbury, Victoria: Flora and fauna assessment and targeted fauna surveys (2008, 2011). Somerfield Estate, Keysborough, Victoria: Flora, Fauna and Growling Grass Frog surveys (2008 – 2009) Renewable Energy , Vic. 2005–2007, bird and bat utilization studies; mortality studies. 2004–2011, Bird and bat utilization surveys; Bird, Bat and Animal Pest Management Plans. 2008; bird and bat utilisation survey; Brolga Surveys. Lal Lal Wind Farm, Vic. 2006-2007; bird and bat utilisation survey; Powerful and Barking Owls Surveys. Ryan Corner Wind Farm, 2006-2007; bird and bat utilisation survey; Brolga and Southern Bentwing Bat Surveys. Dundonnell Wind Farm, 2009; bird and bat utilisation survey; Brolga Surveys. Ararat Wind Farm, 2008, 2012; bird and bat utilisation survey; Bird, Bat and Animal Pest Management Plans. Rugby Wind Farm 2011; bird and bat utilization survey. 2012; bird and bat utilization survey. , NSW (20011–2012), Bird utilisation surveys; mortality studies. , NSW, (2010–2011), Bird utilisation surveys; mortality studies. Granville Wind Farm, Tasmania 2012 – 2013, bat and threatened species surveys. Road and Rail Infrastructure Second Murray River Crossing at Echuca – Moama –Flora, fauna and native vegetation assessment, Threatened flora and fauna surveys and Bat survey (2011–2012). Dingley Bypass: Flora and fauna assessment and targeted fauna surveys (2010–2011). Avalon Airport Rail Link: Flora and fauna assessment and targeted fauna surveys (2011–2012). Ecosystem Monitoring and Management Warrambeen Monitoring, Victoria: Ecological Monitoring of threatened fauna species (2010).

Bernard O’Callaghan Senior Ecologist and Project Manager

Profile

Bernard O’Callaghan has significant expertise in environment, biodiversity, and coastal management and development with the private sector, development agencies and environmental organisations in Australia and over 25 Asia‐Pacific countries. Bernard has extensive experience in the design and implementation of environmental management plans to manage the impacts of development, conservation and renewable energy projects on threatened flora and fauna. He has prepared and reviewed environmental assessment reports for surveys carried out in Victoria, New South Wales, Vietnam, Fiji, Vanuatu and Tonga. Bernard has been responsible for the project management for large‐scale ecological surveys in urbanised and highly remote locations. Since joining BL&A, Bernard has advised on a range of wind farm and housing developments and has provided strong technical and regulatory QA for these and other development impact assessments for the company.

Biography Key Skills

Qualifications  Project Manager including programming, staffing, client Master of Environmental Management, University of New liaison, production of high quality technical reports England  Bat and avifauna management plans for wind farms Bachelor of Science, Melbourne University preparation and implementation

Employment History  Biodiversity and Climate Change policy advice 2015 – present  Protected Area Management Planning processes Senior Ecologist and Project Manager, BL&A, Melbourne, Australia  Flora and Fauna Assessments 2013‐2015  Targeted surveys for listed flora and fauna species Independent international consultant Asia– Pacific, Vanuatu  Constraints analysis 2008 ‐ 2013 Regional Program Coordinator, IUCN Regional  Scoping assessment Program, Suva, Fiji 2007 – 2008  Management plan preparation for listed fauna and flora Regional Program Coordinator, IUCN Vietnam values and offset sites Country Program, Vietnam  Salvage protocol preparation and implementation 2001 – 2005 Chief Technical Advisor, Vietnam, World Bank—IUCN  Project design recommendation 1993‐2001 International environmental management  EPBC Act and EES Referrals assignments, including IUCN, Wetlands  Offset site selection International, Asian Development Bank and Mekong River Commission  Preparation of assessment reports (preliminary documentation, public environmental report and environmental impact statement) Project Examples

Property Development St. Andrews Golf Course, Fingal, Vegetation assessment and bushfire assessment O’Herns Road, Epping 2015, native vegetation assessment Maroondah Hwy, Lilydale, Biodiversity Assessment Guidelines

Renewable Energy Mt Gellibrand Wind Farm, Mt Gellibrand, Victoria: Rotor Swept Area proposed modification assessment (2015). Coonooer Wind Farm, Coonooer Bridge, Victoria: Bird and Bat Management Plan (2015) Kiata Wind Farm, The Environment Protection and Biodiversity Conservation Act 1999 referral (2015) Capital II Wind Farm, New South Wales: Bird and Bat Adaptive Management Program, Bird Utilisation Surveys (2015) Capital Wind Farm, New South Wales: Implementation of Bird & Bat Management Program – Monthly Mortality Monitoring (2015) , New South Wales: Implementation of Bird & Bat Adaptive Management Program – Specialist surveys (2015 –2016 ) Taralga Wind Farm, New South Wales: Implementation of Bird and Bat Adaptive Management Plan (2015‐ ) . Northern New South Wales: ‐ Pre‐construction bat utilisation surveys (2015) White Rock Wind Farm. Northern New South Wales: ‐ Development of Draft Bird & Bat Adaptive Management Program (2015‐2016)

Road and coastal infrastructure Vanuatu Coastal Adaptation Project, United Nations Development Program (UNDP) ‐ Assessment of coastal infrastructure and the needs for “climate proofing” ‐ 2013‐2015. Pilot Program for Climate Resilience—Asian Development Bank— Initial Environmental Examination coastal road construction and rehabilitation, Kingdom of Tonga (2013)

Ecosystem Monitoring and Management

Nha Trang Bay, Vietnam—completion of baseline marine and coastal surveys; development of Plan of Management; Regulation development and enforcement; and Monitoring (2001‐2005) Mortlake Wind Farm – Amendment Application –Witness Statement of Brett Lane Report No.12020 (6.2)

Appendix 3: Analysis of additional potential bird flights at risk for the largest possible turbine designs The tables below include the following variables: . The height range from ground level to >140 metres above the ground that birds were observed flying during bird utilisation surveys; . The area in square metres of the plane that represents the survey area corresponding to the turbine dimensions (i.e. the RSA diameter times the height in metres) (SA), and in particular the area of that plane at each height zone (SAh) (NB: for the largest possible turbine, the survey area was fixed at 180 metre high in order not to bias the comparison of the higher and power designs); . The percentage of bird flights observed at each height zone (%H) based on findings from bird utilisation surveys at 10 (pre-development) wind farm sites in south–eastern Australia (BL&A, unpubl. data); . The number of bird flights that would pass through this plane assuming a total number of flights through the survey plane averaging one per square metre* (SN) and the number of these flights at each height zone (SNh), based on %H (i.e. SNh = %H x SN); . The area of the RSA plane (RSA) at each of the height zones (RSAh) – see figure below;

. The percentage of the plane that represents the survey area occupied by the RSA plane at each of the height zones (%RSAh) (i.e. %RSAh = RSAh/SAh). . The number of flights that pass through the RSA plane at each height zone (Nh) (i.e. Nh = %RSAh x SNh); and . The sum of those flights (N) (i.e. N = sum (Nh for each height zone)). The ratio of N for the largest possible turbine design option to N for the permitted turbine design was then compared.

Page | 30 Mortlake Wind Farm – Amendment Application –Witness Statement of Brett Lane Report No.12020 (6.2)

*Note that the number of bird flights adopted for this analysis (i.e. one per square metre of survey area plane, SA) is notional and assumes all flights are perpendicular to the RSA plane. By applying it consistently between the two turbine designs a ratio can be generated that compares the number of bird flights potentially at risk of collision if passing through the RSA. The increased numbers of flights passing through the RSA can therefore be compared between the permitted and largest possible turbine designs. The number of flights that pass through the RSA is not the number affected by collision as only a small proportion of the air space is occupied by the turbine blades and other turbine parts. Collision risk has been discussed in section 3.5 of this witness statement. Table 1 below presents the results of the analysis for the original turbine design. Table 2 presents the same analysis for the largest possible turbine design (lower). Table 3 provides the same analysis for the largest possible turbine design (higher) Note that calculations in these tables have been based on the height intervals at which bird flights were recorded. Therefore they should be considered as approximations; the minor differences in the upper and lower heights of the RSA of the amended turbine design would make a negligible difference to the comparison. Table 1: Analysis of impact on birds of original turbine design H %H SAh SNh RSAh %RSAh Nh Area at Area of 80 m Ht range % area at No. % flights Ht (sq. No. flights diam. Turbine (m) RSA flights m) (sq. m) 0-10 18% 800 2318 10-20 23% 800 2962 20-30 20% 800 2576 30-40 13% 800 1674 40-50 14% 800 1803 363 45% 817 50-60 6% 800 772 620 77% 599 60-80 4% 1600 515 1,531 96% 493 80-100 1% 1600 128 1,531 96% 123 100-120 0% 1600 0 983 61% 0 120-140 1% 1600 128 >140 0% 1680 0 Total SA =12,880 RSA = 5,027 N = 2,032

Page | 31 Mortlake Wind Farm – Amendment Application –Witness Statement of Brett Lane Report No.12020 (6.2)

Table 2: Analysis of impact on birds of largest possible turbine design (lower) H %H SAh SNh RSAh %RSAh Nh Ht range % flights Area at No. flights Area of 132 m % area at No. (m) Ht (sq. diam. Turbine RSA flights* m) (sq. m) 0-10 18% 1320 4277 0 0 0 10-20 23% 1320 5465 0 0 0 20-30 20% 1320 4752 532 40% 1915 30-40 13% 1320 3089 865 66% 2024 40-50 14% 1320 3326 1,055 80% 2659 50-60 6% 1320 1426 1,185 90% 1280 60-80 4% 2640 950 2,545 96% 916 80-100 1% 2640 238 2,602 99% 234 100-120 0% 2640 0 2,450 93% 0 120-140 1% 2640 238 1,920 73% 173 140-160 0% 2640 0 0 50% 0 160-180 2640 0 532 20% 0 Total SA (= SN) = 23,760 RSA = 13,686 N = 9,201

Table 3: Analysis of impact on birds of largest possible turbine design (higher) H %H SAh SNh RSAh %RSAh Nh Ht range % flights Area at No. flights Area of 132 m % area at No. (m) Ht (sq. diam. Turbine RSA flights* m) (sq. m) 0-10 18% 1320 4277 0 0% 0 10-20 23% 1320 5465 0 0% 0 20-30 20% 1320 4752 0 0% 0 30-40 13% 1320 3089 0 0% 0 40-50 14% 1320 3326 0 0% 0 50-60 6% 1320 1426 532 40% 575 60-80 4% 2640 950 1,920 73% 691 80-100 1% 2640 238 2,450 93% 221 100-120 0% 2640 0 2,602 99% 0 120-140 1% 2640 238 2,545 96% 229 140-160 0% 2640 0 2,240 85% 0 160-180 2640 0 1,397 53% 0 Total SA = 23760 RSA = 13,686 N = 1,715

Page | 32 Mortlake Wind Farm – Amendment Application –Witness Statement of Brett Lane Report No.12020 (6.2)

The increase in RSA from the original 5,027 m2 to 13,686 m2 will increase the airspace occupied by the turbine blades by more than twice. The ratio of the modelled number of bird flights passing through the RSA for the largest possible turbine (lower) to the number passing through in the original design is 9,201/2,032, or 4.52 (Table 2). The ratio of the modelled number of bird flights passing through the RSA for the largest possible turbine (higher) to the number passing through in the original design is 1,715/2,032, or 0.84 (Table 3). Therefore, for the lower height, largest possible turbine, over four times more bird flights are modelled to pass through the RSA than for the original assessed turbine design. For the higher height, largest possible turbine, fewer bird flights are modelled to pass through the RSA than for the original assessed turbine design. This difference is striking and shows the significant changes in impact that arise from different RSA heights. The assumption in this modelling that bird flights are perpendicular to the RSA plane is conservative as more flights are likely to approach the RSA plane at an angle, with a lower probability therefore of encountering a turbine blade within this plane. The difference is therefore a maximum possible difference based on a worst case assumption. The difference in bird impact from collision with turbine blades within the RSA plane will probably be lower than this. It is not possible to calculate how much lower without making further assumptions and the empirical basis for these is lacking, and would involve consideration of flight direction and turbine orientation, data for which has not been collected. Notwithstanding this, this worst-case scenario is still informative for decision-making purposes. However, it is noted that the proposed number of turbines is to be reduced from 51 to 42. This has been taken into consideration in comparing the former with the amended turbine designs and layout. The species affected by this additional impact are abundant, widespread native and introduced species that occur throughout south eastern Australia that are adapted to agricultural landscapes. These additional impacts are not of concern from a conservation perspective as no threatened species will be significantly affected by the change.

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