APPENDIX A. Submission Summary Matrix
Table A1 – Summary of submission details
Submission No. Surname First name Suburb State Submission 38963 Burton Marie Forest Reefs NSW Objects 39639 Gerathy John Carcoar NSW Objects 40916 Carthew Fiona Collector NSW Objects 41219 Walker Ann Yarrabin NSW Objects 41221 Walker John Yarrabin NSW Objects 41525 Jarvis Lyn Wellington NSW Objects 41739 Hodgson Judith Collector NSW Objects 41829 anon (2) Wellington NSW Objects 41859 anon (1) Wellington NSW Objects 42007 Gardner Ann Penshurst VIC Objects 42011 Ross Frank Collector NSW Objects 42069 Walsh Anthony Collector NSW Objects Waubra 42077 Laurie Sarah Foundation VIC Objects 42081 McKay James Collector NSW Objects 42085 McKay James Collector NSW Objects 42100 Bell Jenny Breadalbane NSW Objects 42102 Edwards Rod Breadalbane NSW Objects 42104 Watts Alan/Colleen Carcoar NSW Objects 42111 Schneider Patina Forest Reefs NSW Objects 42157 Papadopoulos George Yass NSW Objects 42159 McKeachie Velma Collector NSW Objects 42175 Arnott Charlie Boorowa NSW Objects 42177 McGuiness Sam Boorowa NSW Objects 42206 Anon (1) Withheld NSW Objects 42206 Anon (2) Withheld NSW Objects 41094 anon Collector NSW Objects 42294 FOC Objects 39308 Marshall Stanley Gunning NSW Objects 42149 Mitchell Fiona Breadalbane NSW Objects 42169 Arnott John Boorowa NSW Objects 42151 Arnott Michael Boorowa NSW Objects 42179 Arnott Angelica Boorowa NSW Objects 42155 Arnott Margaret Boorowa NSW Objects 40265 Anon 1 Collector NSW Objects 40269 Anon 2 Collector NSW Objects 40271 Anon 3 Collector NSW Objects 40273 Anon 4 Collector NSW Objects 40277 Anon 4 Collector NSW Objects 42182 Batchelor Trista Collector NSW Objects 42286 Bell Diana Collector NSW Objects 40363 Bell Kate Collector NSW Objects 42037 Bell Sue Collector NSW Objects 42184 Cram Daniel Collector NSW Objects 42001 Dougall Zoe Collector NSW Objects 42018 Eddey David Collector NSW Objects 42288 Eddey Wendy Collector NSW Objects 42039 Hannan Frank Collector NSW Objects 42167 Howard Robin Collector NSW Objects 41863 Jelbart Chris Collector NSW Objects
152 Collector Wind Farm Preferred Project and Submission Report January 2013
Submission No. Surname First name Suburb State Submission 42139 Johnstone Diane Collector NSW Objects 42136 Katen Stephen Collector NSW Objects 42043 Lovelock Lynn Collector NSW Objects 42133 Mitchell Nick Collector NSW Objects 40882 Ten Dam Julius Collector NSW Objects 42041 Wedlock Jana Collector NSW Objects 41818 Barlow Malcolm Crookwell NSW Objects 41995 Mathaus Phyllis Goulburn NSW Objects 41999 Snowden Lloyd Goulburn NSW Objects 41847 Lowe Stephen Mudgee NSW Objects 42016 McHenry Stuart / Heather Penshurst VIC Objects 41991 Glavinic Denis Phillip ACT Objects 41993 Causer Brett Queanbeyan NSW Objects 41836 Lyons Michael Wellington NSW Objects 42062 Name withheld Collector NSW Objects 41148 Snowden Kerry Collector NSW Objects 40916 Carthew Fiona Collector NSW Objects 40878 Obj_Anon 1 Collector NSW Objects 40880 Obj_Anon 2 Collector NSW Objects 42106 Clean Energy Council Supports 41968 Perry Angela North Bondi NSW Supports 41912 Turner Ash Concord NSW Supports 42047 Poile Belinda Dulwich Hill NSW Supports 39175 Garden Benjamin Campbell ACT Supports 42056 Heinze Biance Canberra ACT Supports 42045 Poile Bradley Collector NSW Supports Anderson Bruce Baynton VIC Supports/Comme 42005 nts 41962 Prell Charlie Crookwell NSW Supports 42147 Seymour Daisy Wahroongha NSW Supports 42184 MacDonald Daniel Dudley NSW Supports 41972 Byrnes Dennis Cullerin NSW Supports 42023 Fitzpatrick Dermot Tas Tas Supports 42143 Yap Eugene Carlingford NSW Supports 42033 Poile Felicity Collector NSW Supports 42021 Poile Garry Collector NSW Supports 42165 Martin Jacinta Wahroongha NSW Supports 42093 Hendersen Jennifer Darlinghurst NSW Supports 42141 Poile Jennifer Collector NSW Supports 42014 Hallenstein Joe Highgate Hill Supports 41987 Byrnes Joe Cullerin NSW Supports Proudfoot Kristen Gunning NSW Supports/comme 42029 nts 42060 Hallenstein Lucie Wantirna Supports 42003 Anglicas Luke Neutral Bay NSW Supports 42035 Payne Madeleine Coorparoo Supports 42031 Poile Maureen Collector NSW Supports 42153 Troy Michael Orange NSW Supports 41953 Scott Murray Heathcote NSW Supports 42087 Weston Neil Wollstonecraft NSW Supports 42058 Chen Ning Sydney NSW Supports
153 Collector Wind Farm Preferred Project and Submission Report January 2013
Submission No. Surname First name Suburb State Submission 41964 Davies Nola Dunbogan NSW Supports 42049 Ellis Oliver Dulwich Hill NSW Supports Busch Osha Fishermans NSW 42067 Reach Supports 41966 Walsh Owen North Bondi NSW Supports 41937 Huynh Rose Yagoona NSW Supports 39383 Sannen Sarah AYCC? Supports 42089 Holmes a Court Simon Supports 41985 Hollings Steve Supports 42145 Mills Teaghan Lavington NSW Supports 42083 Jeyaretnam Terrence Supports 42117 Anon Braidwood NSW Supports Anon Goulburn NSW Supports/comme 42054 nts 42051 Anon North Rocks NSW Supports 42098 Anon Austinmer NSW Supports 42091 Anon Goulburn NSW Supports 42075 Anon Goulburn NSW Supports 42073 Anon Lilyfield NSW Supports 42071 Anon Sherwood Supports 42009 Anon Cromer NSW Supports 41989 Anon Double Bay NSW Supports 41947 Anon Kirribilli NSW Supports 41951 Anon Annandale NSW Supports 41960 Anon Bermagui NSW Supports 41974 Anon NSW NSW Supports 41982 Anon Drummoyne NSW Supports 41980 Anon Gymea NSW Supports Northern Illawarra Sustainability Helensburgh NSW 41978 Alliance Supports 41976 Anon Lakelands NSW Supports 39378 Anon Asquith NSW Supports 42027 Upper Lachlan Shire Council (ULSC) Objects Goulburn Mulwaree Shire Council 39810 (GMSC) Comments NSW Office of Environment & 41889 Heritage (OEH) Comments 39390 Department of Defence Comments NSW Environment Protection Agency 41433 (EPA) Comments 39596 Civil Aviation Safety Authority (CASA) Comments 39104 Air Services Australia Comments NSW Trade & Investment - Division of Resources & Energy (Resources & 41275 Energy) Comments Murrumbidgee Catchment Management Authority 42127 (Murrumbidgee CMA) Comments NSW Department of Primary Industries - Division of Catchments & 42025 Lands (Catchments & Lands) Comments NSW Trade & Investment - 42290 Department of Primary Industries Comments
154 Collector Wind Farm Preferred Project and Submission Report January 2013
Submission No. Surname First name Suburb State Submission (Division of NSW Fisheries (Fisheries)) and (Division of NSW Office of Water (NOW)) NSW Roads and Maritime Services 42292 (RMS) Comments 42202 NSW Health Comments
155 Collector Wind Farm Preferred Project and Submission Report January 2013
Table A2 - Summary of Public submissions (non-form letter)
4200 3896 3896 3963 4121 4122 4152 4173 4182 4185 4200 4201 4206 4207 4208 4208 4210 4210 4210 4211 4215 4215 4217 4217 4220 4109 3930 4229 ISSUES 7 3 5 9 9 1 5 9 9 9 7 1 9 7 1 5 0 2 4 1 7 9 5 7 6 4 8 4 Strategic Justification X X X X X X X Landscape and Visual Impact X X X X X X X X X X X X X X Noise Assessment X X X X X X X X X X X X X X X Flora and Fauna Assessment X X X X X X X X Indigenous Heritage X X X X X Traffic and Transport X X X Hazards and Risks X X Aviation Impacts X X X X X X Telecommunications Impacts X Fire and Bushfire Impacts X X X X X X X X Health and Safety X X X X X X X X X X X X X X X X X X Water Quality Climate and Air Quality X X X X Soils and Landforms X X X Non-Indigenous Heritage X X X Waste Minimisation and Management Property Values X X X X X X X X X X Mineral Exploration Socio-Economic Considerations X X X X X X X X X X X X X Land Use Community and Stakeholder Consultation X X X X X X X X X X
156 Collector Wind Farm Preferred Project and Submission Report January 2013
Table A3 - Summary of Public submissions (Form letter)
40 40 40 40 40 40 40 40 40 41 41 41 41 41 41 41 41 41 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 4026 26 27 27 27 36 87 88 88 91 14 81 83 84 86 99 99 99 99 00 01 01 03 03 04 04 06 13 13 13 14 15 15 16 16 17 18 18 28 28 ISSUES 5 9 1 3 7 3 8 0 2 6 8 8 6 7 3 1 3 5 9 1 6 8 7 9 1 3 2 3 6 9 9 1 5 7 9 9 2 4 6 8 Strategic Justification Landscape and Visual Impact X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X Noise Assessment X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X Flora and Fauna Assessment X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X Indigenous Heritage X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X Traffic and Transport Hazards and Risks Aviation Impacts X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X Telecommunicati ons Impacts Fire and Bushfire Impacts X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X Health and Safety X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X Water Quality Climate and Air Quality Soils and Landforms X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X Non-Indigenous Heritage X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X Waste Minimisation and Management Property Values X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X Mineral Exploration Socio-Economic Considerations X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X Land Use Community and Stakeholder Consultation X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X
157 Collector Wind Farm Preferred Project and Submission Report January 2013
Table A4 - Summary of Government Agency submissions
ISSUES 39014 39390 39596 39810 41275 41433 41889 42025 42027 42127 42202 42290 42292 NO NO NO NO NO Strategic Justification ISSUES ISSUES ISSUES ISSUES Objects ISSUES Landscape and Visual Impact Noise Assessment Flora and Fauna Assessment Indigenous Heritage Traffic and Transport Hazards and Risks Aviation Impacts X X X Telecommunications Impacts X Fire and Bushfire Impacts Health and Safety X X Water Quality X Climate and Air Quality Soils and Landforms Non-Indigenous Heritage Waste Minimisation and Management Property Values Mineral Exploration Socio-Economic Considerations X Land Use Community and Stakeholder Consultation
158 Collector Wind Farm Preferred Project and Submission Report January 2013
APPENDIX B. Landscape & Visual Impact Assessment Response Summary
Collector Wind Farm
View toward the proposed Collector Wind Farm
LANDSCAPE & VISUAL IMPACT ASSESSMENT
RESPONSE TO PUBLIC SUBMISSIONS
Prepared for:
December 2012
Prepared by:
GREEN BEAN DESIGN l a n d s c a p e a r c h i t e c t s
1 GREEN BEAN DESIGN l a n d s c a p e a r c h I t e c t s PO Box 3178 Austral NSW 2179 - Mobile 0430 599 995 Project: Collector Wind Farm
Project Number: 11-144
Report Title: Landscape and Visual Impact Assessment – Response to submissions
Revision: Revision V1 – Final Issue
Author: Andrew Homewood, BSc. (Dual Hons), DipLM, DipHort Registered Landscape Architect, AILA, MEIANZ
Date 18 December 2012
Green Bean Design – Capability Statement
Green Bean Design is an experienced landscape architectural consultancy specialising in landscape and visual impact assessment. As an independent consultancy GBD provide professional advice to a range of commercial and government clients involved in large infrastructure project development.
GBD principal landscape architect Andrew Homewood is a registered landscape architect and member of the Australian Institute of Landscape Architects and the Environmental Institute of Australia and New Zealand.
Andrew has over 20 years continuous employment in landscape consultancy and has completed numerous landscape and visual impact assessments for a variety of large scale and state significant infrastructure and renewable energy projects, including wind energy and solar power developments.
Green Bean Design has been commissioned to prepare LVIA for nineteen wind energy projects across New South Wales, Victoria and South Australia including assessments for: x Silverton Wind Farm x Boco Rock Wind Farm x Collector Wind Farm x Crookwell 3 Wind Farm x Sapphire Wind Farm x Willatook Wind Farm x Eden Wind Farm x Birrema Wind Farm x Rye Park Wind Farm x Paling Yards Wind Farm x Port Kembla Wind Farm x Bango Wind Farm x Deepwater Wind Farm x Golspie Wind Farm x Liverpool Range Wind Farm x White Rock Wind Farm
GREEN BEAN DESIGN l a n d s c a p e a r c h i t e c t s
2 GREEN BEAN DESIGN l a n d s c a p e a r c h I t e c t s PO Box 3178 Austral NSW 2179 - Mobile 0430 599 995 Introduction
Green Bean Design (GBD) was commissioned to prepare a landscape and visual impact assessment (LVIA) for the proposed Collector wind farm by APP Pty Ltd on behalf of RATCH-Australia Corporation. GBD prepared the LVIA between January 2011 and January 2012.
The LVIA was placed on public exhibition, together with the Collector wind farm Environmental Assessment, between the 26th July and the 24th September 2012 as one of the key assessments of the Director Generals Requirements. Following the public exhibition period the Proponent provided GBD with a single response with specific regard to the Collector wind farm LVIA.
The response dated 11th September 2012 was prepared by Richard Lamb & Associates (RLA) who was commissioned by Hegarty and Elmgreen Solicitors to undertake an assessment of relevant aspects of the LVIA component of the Collector wind farm Environmental Assessment.
Response to submission
GBD’s response to the RLA submission is set out in the following table. RLA comments have been copied either in whole or part as relevant from the submission and are presented in the left hand column. The corresponding response is provided in the right hand column.
1.1 RLA Comment: 1.2 GBD Response:
Summary of my experience and CV
“I (Richard Lamb) have developed my own methods We note RLA’s claims of experience; however, GBD for landscape assessment, based on my education, are not cognisant of the landscape assessment knowledge from research and practical experience. I methodology claimed to have been developed by am familiar with research and technology associated RLA, or how RLA’s method addresses existing wind with the assessing and representing the visual impacts farm industry and State Government planning of wind farms”. guidelines, or to which wind farm developments in “I (Richard Lamb) have been the principal consultant particular the RLA methodology has been applied. for over 400 consultancies concerning the visual GBD are not cognisant of the 400 consultancies impacts and landscape heritage area of expertise claimed to have been undertaken by RLA and how during the last 10 years.” many of these 400 consultancies have included the assessment of wind farm developments. GBD cannot verify RLA’s claim to have ‘familiarity with the research and technology associated with the assessment and representation of visual impacts of wind farms’.
3 GREEN BEAN DESIGN l a n d s c a p e a r c h I t e c t s PO Box 3178 Austral NSW 2179 - Mobile 0430 599 995 The Collector wind farm LVIA has been prepared by an experienced visual consultant and Registered Landscape Architect with over 20 years consultancy experience. This experience includes participation in 18 LVIA for wind farm developments across New South Wales, Victoria and South Australia as well as numerous LVIA for State significant infrastructure projects. The methodology developed by GBD has been refined over the past 10 years by reference to leading land management authorities and organisations such as: x West Australian Planning Commission
x The American Bureau of Land Management
x The Landscape Institute (UK)
x Institute of Environmental Management and
Assessment (UK)
x Countryside Commission (UK)
x Scottish Natural Heritage (UK)
GBD have utilised their visual experience to deliver guest lectures on visual impact assessment to undergraduate students at the University of New South Wales and landscape diploma students at TAFE. GBD also provided a submission to the NSW Government Rural Wind Farms Enquiry and have undertaken a peer review of the Draft Planning Guidelines for Wind Farms (December 2011) on behalf of the New South Wales Department of Planning & Infrastructure (D0P&I).
4 GREEN BEAN DESIGN l a n d s c a p e a r c h I t e c t s PO Box 3178 Austral NSW 2179 - Mobile 0430 599 995 2.1 RLA Comment: 2.2 GBD Response:
GBD Methodology for the LVIA
‘The methodology does not include a preliminary The preparation of a Preliminary LVIA, as outlined in assessment that includes identification of potential Step 1 Assess the Landscape Values of the National community and stakeholder interests and the Assessment Framework (NAF) guidelines is not assessment of landscape values assisted by that required by the DoP&I and is not called up in the process…’ Collector wind farm Director Generals Requirements (DGR’s). The NAF guidelines have been developed to consider wind farm developments across all States and Territories including those such as Victoria, where a separate and standalone Preliminary LVIA is required to be submitted as part of the planning application process for wind farm developments prior to a full assessment being carried out. The Collector wind farm LVIA has, as stated in the LVIA report (page 13 Table 2), incorporated the Step 1A Preliminary Landscape Assessment tasks within the LVIA which include: x desktop review (refer LVIA page 16);
x seek information from Local Authority;
x identify potential community and stakeholder;
interests (refer LVIA Section 14);
x site survey; and
x preliminary assessment of landscape values.
In GBD’s opinion community values such as those of the residents of Collector and other rural residents, or the values of the landscape to them have been given due weight and are documented in Section 14 of the LVIA report. The results of a survey carried out on behalf of the Collector wind farm project indicated that 60% of respondents stated that the project would have no, or a minimal impact, on aspects of the landscape they enjoyed. 13% responded that the wind farm would ruin the landscape and create an
5 GREEN BEAN DESIGN l a n d s c a p e a r c h I t e c t s PO Box 3178 Austral NSW 2179 - Mobile 0430 599 995 eyesore. The comments provided by RLA appear to have misconstrued the information provided in the LVIA report.
2.3 RLA Comment: 2.4 GBD Response:
“As a result it is possible that community values such The community values of the landscape have been as those of the residents of Collector and other rural given due weight and are included and outlined in residents, or the values of the landscape to them, Section 14 of the LVIA report. have not been given due weight”.
2.5 RLA Comment: 2.6 GBD Response:
“…however this means that the extent of the study The 10 km zone of visual influence (ZVI) has not been area and the zone of visual influence at Step 1 B.1 has determined by GBD. The 10 km viewshed has been been determined totally by GBA” (sic). determined totally by the DoP&I as per the Collector wind farm DGR’s. The consideration of cumulative (the 10 km viewshed)… ‘potentially limits the impacts has considered wind farms developments up consideration of cumulative impacts in a way which to a distance of 25 km from the Collector wind farm may not reflect community concerns’. (and well in excess of the 10 km viewshed) and is in accordance with the requirements of the DGR’s. The comments provided by RLA have largely misconstrued the information provided in the LVIA, and particularly the determination of the 10 km viewshed by the DoP&I and the fact that the 10 km viewshed has not been applied to the determination of potential cumulative visual impacts.
3.1 RLA Comment: 3.2 GBD Response:
Draft National Wind Farm Development Guidelines The Draft National Wind Farm Development (2010) Guidelines (2010) were cited for completeness during
‘Why the guidelines are cited is not clear since there is the preparation of the Collector wind farm LVIA; no discussion that relates to them and this staged however, following the preparation of the Collector approach as recommended in the Guidelines was not wind farm LVIA, and as those familiar with the followed’. assessment of wind farm developments would be aware, the Environment Protection and Heritage Standing Committee has decided to cease further development of these Guidelines and for the purpose of the Collector wind farm LVIA the Guidelines are now redundant.
6 GREEN BEAN DESIGN l a n d s c a p e a r c h I t e c t s PO Box 3178 Austral NSW 2179 - Mobile 0430 599 995 3.3 RLA Comment: 3.4 GBD Response: Auswind Best Practice Guidelines Noted ‘The six point summary of the Auswind Best Practice Guidelines is similar to the methodology finally adopted, except for the absence of an assessment of landscape sensitivity’.
4.1 RLA Comment: 4.2 GBD Response: Components of the Methodology
“It (the methodology) contains the assessment of The assessment of landscape sensitivity is mentioned landscape sensitivity. Sensitivity is a parameter not in the Draft NSW Planning Guidelines Wind Farms mentioned in any of the other guidelines referred 2011, which is referred to and discussed at page 14 of to…” the LVIA report and summarised in the LVIA report at Appendix A. ‘There is no preliminary consultation required as a A consideration of landscape sensitivity and guide to determining the values of the landscape to determination of the degree to which a particular the community, the location of sensitive viewing landscape can accommodate change arising from a places to individuals and groups, what the community particular development is documented by a number may consider to be the zone of visual influence or the of leading authorities (such as the UK Landscape cultural values of the landscape’. Institute) and is a standard approach associated with
‘As a result, it is questionable as to whether the landscape and visual impact assessment. representation of the views affected by the proposal, The results of community consultation and a which are only 5 in the public domain, are of determination of community landscape values are relevance to the perceptions of those who will live in included in the Collector wind farm LVIA Section 14 and view the landscape in which the wind farm will exist’. The selection of the 5 public domain photomontage locations are in accordance with the aspects of the landscape most enjoyed by the local community as identified in the community consultation process, including typical views from trips along the Federal Highway. As noted in the LVIA report, a number of photomontages have been undertaken from surrounding residential dwellings; however, landowners requested that they were not published in the LVIA report.
7 GREEN BEAN DESIGN l a n d s c a p e a r c h I t e c t s PO Box 3178 Austral NSW 2179 - Mobile 0430 599 995 5.1 RLA Comment: 5.2 GBD Response: Parameters for Landscape Sensitivity
‘The parameters of sensitivity appear not to require The parameters of landscape sensitivity are outlined community input and are primarily based on the in the LVIA report at Section 7. The assessment of expert opinion of the consultants. There do not landscape sensitivity is a professional assessment and appear to be any culturally determined parameters of includes a number of culturally determined sensitivity…’ parameters that consider human modifications to the landscape as included in Table 6 of the LVIA report. ‘…for example whether the township of Collector is a sensitive location, or whether a customary route The township of Collector has been identified as a through the landscape such as Collector Road is a high sensitive view location in Table 15 of the LVIA more sensitive viewing place than, say, the Hume report. Highway’. Road corridors have not been identified as a singular Landscape Character Area; however (and more ‘The differences between view locations with regard importantly), views from for motorists travelling to assessment of visual impacts are not explained…’ along local roads and highways have been assessed
‘As is the case for distance and visibility, sensitivity is are included in the Collector wind farm LVIA at Table double counted in the methodology’. 16.
The differences between potential view locations are outlined in the LVIA report at Table 14.
It is not clear what this comment means. Landscape sensitivity and visual sensitivity are separate determinations. It is not clear why this should be considered ‘double counting’?
6.1 RLA Comment: 6.2 GBD Response: Viewshed, Zone of Visual Influence and Visibility
‘…visibility, despite the name which implies No specific comment has been provided under this objectivity, in this methodology is a subjective heading. Our response refers to the general claims assessment’. and opinions provided by RLA.
‘This does not accord as a principle with knowledge of It is not clear why the name ‘visibility’ implies visual perception. There is a minimal difference in the objectivity, and this has not been stated as such in the visibility of a turbine at 3 km compared to one at 1 km LVIA report. The methodology is based on upon a because of the minimal visual information that is professional opinion informed by academic research necessary to fit its image into existing knowledge of which RLA may, or may not, be aware. The
8 GREEN BEAN DESIGN l a n d s c a p e a r c h I t e c t s PO Box 3178 Austral NSW 2179 - Mobile 0430 599 995 structures’. assigned levels of visibility to Collector wind farm LVIA Table 5 have been adopted and developed from ‘As a result a viewer can identify, recognise and research undertaken by the University of Newcastle respond to the turbines based on minimal visual (UK) and subsequent report Visual Assessment of information. Therefore an analysis of the precise level Wind farms: Best Practice (2001) commissioned by of detail and the amount of a turbine visible from Scottish Natural Heritage. This study has been quoted every possible viewing location other than at very in a number of LVIA prepared for Australian wind significant distances, for example by using ZVI maps, farm developments and should be familiar to is largely unnecessary. The default characteristics consultants engaged in the preparation of wind farm recall a mental image of the complete object. A LVIA. turbine, part of the rotor and nacelle of which is all that is visible behind a knoll, is a complete turbine as a GBD are not clear which principle of visual perception perceived image’. is being referred to in the comment, or if this principle is specific to the methodology claimed to ‘As a result the validity of arbitrarily assigned levels of have been developed by RLA. The comment visibility or directly relating this to visual impact based misconstrues the intent of the description of visibility on the distance between a viewer and what is viewed in relation to the visible magnitude and scale of wind should be questioned. In the same vein, the turbines at an increasing view distance. assessment of the perceived zone of influence of the wind farm should be acknowledged to be different A visit to any existing wind farm development will from the arbitrary 10 km zone of influence that has demonstrate a clear and discernible difference in been adopted’. both the scale and magnitude of visible wind turbines at a 1 km and 3 km viewing distance. This is also ‘Despite their (other wind farms) being visible in the illustrated in the LVIA report Figure 5 Visibility and photographs taken by GBD, the LVIA claims that they Distance where a comparison between a view are not responsible for any cumulative impacts’. distance of 1.5 km and 4 km is illustrated.
GBD do not contest that a wind turbine will not be ‘perceived’ as a wind turbine between distances of 1 km and 3 km.
We note RLA’s opinion that the production of ZVI is largely unnecessary; however, this opinion is not in accordance with the requirements of the Collector wind farm DGR’s.
Whilst we also note RLA’s claim that a view toward any portion of a wind turbine (for example where portions of the tower and nacelle may be visible
9 GREEN BEAN DESIGN l a n d s c a p e a r c h I t e c t s PO Box 3178 Austral NSW 2179 - Mobile 0430 599 995 above a hill or ridgeline) is an image perceived as a whole turbine, the reality is that the majority of the turbine is screened from view. The pursuit of perceptual visual studies is a worthy academic cause; however, with regard to the potential visual impact of the Collector wind farm, this LVIA is concerned with what the brain ‘sees’ as detected by the eyes.
As previously noted the assigned levels of visibility are not arbitrary.
An arbitrary 10 km zone of visual influence has not been adopted by GBD. The 10 km viewshed has been nominated by DoP&I within the Collector wind farm DGR’s.
It is not clear that any claim has been made to the effect that despite being visible in the photographs taken by GBD, other wind farms are not responsible for any cumulative impacts. A cumulative impact assessment is included at Section 9 of the Collector wind farm LVIA.
7.1 RLA Comment: 7.2 GBD Response: Visibility as a separate parameter
‘In fact, the significance of views from the Hume The potential visual impact of the proposed Collector Highway are discounted on the basis that they are wind farm on vehicles travelling along the Hume fleeting’. Highway have been assessed and determined as low. This determination results from: ‘As a result, it is my opinion that the assessment of x the direction of travel relative to the proposed cumulative impact is flawed and needs to comprehensively address the dynamic aspects of the wind turbine layout; view experiences available on the roads through the x the screening potential of roadside tree planting region, with both major and minor roads to be along portions of the Hume Highway; and considered’. x the very short duration of view. ‘In relation to distance of viewing, it is corrects (sic) as It is GBD’s opinion that the cumulative impact stated that the perceived image of the size of a assessment has assessed and exceeded the turbine decreases with distance’ requirements of the DGR’s. The LVIA has considered
10 GREEN BEAN DESIGN l a n d s c a p e a r c h I t e c t s PO Box 3178 Austral NSW 2179 - Mobile 0430 599 995 the impact of the proposed Collector wind farm on both major (Hume and Federal Highway) as well as local minor roads.
We note RLA’s concurrence, but are not clear how this relates to RLA’s previous comment which claims that there is a minimal difference in the visibility of a turbine at 3 km compared to one at 1 km?
8.1 RLA Comment: 8.2 GBD Response:
Rating of visibility of the proposed Collector Wind Farm layout
‘The application of this parameter is not adequately The rating of visibility outlines the results of the ZVI explained’. diagrams which, for the Collector wind farm LVIA, have been determined at hub height (views to at least half the swept rotor area). Visibility is a key issue in the determination of visual significance. If the Collector wind turbines are not visible from a view location, then a nil impact will be recorded. If a small proportion of the Collector wind turbines are visible then a lesser degree of impact is likely to occur when compared to a view location from which all the Collector wind turbines may be visible.
Having claimed the production of ZVI unnecessary, RLA claim that ‘it is impossible, on the logic of the method, for 100% of the turbines to be visible in any view’. It is not clear what this means as the ZVI diagrams (LVIA Figures 3 and 4) clearly illustrate those areas of landscape within the 10 km viewshed from which a theoretical view toward all the wind turbines may occur.
RLA claim the methodology skews the possible outcome of an assessment toward the low end of visibility and therefore the low end of visual impact. It is not clear how this can be the case when 54 of the residential view locations have been determined to
11 GREEN BEAN DESIGN l a n d s c a p e a r c h I t e c t s PO Box 3178 Austral NSW 2179 - Mobile 0430 599 995 be located within areas of high visibility. Whist visibility can decrease with distance (as acknowledged by RLA in their previous comment); it is the presence of vegetation surrounding residential dwellings and alongside road corridors that will have the more significant impact on the restriction of visibility.
9.1 RLA Comment: 9.2 GBD Response:
Landscape Character Areas and Sensitivity Assessment
‘In other words, the assessment was based only on The determination of landscape sensitivity is an professional judgement. In addition the systematic assessment that relies on professional judgement. description and analysis of landscape characteristics The criteria applied to the assessment of landscape which is claimed to have been carried out is not sensitivity are presented in the LVIA report at Table 6 transparent and it uses criteria from a part of the and draw on the Land Use Consultants report on world that has little relationship to the visual or landscape sensitivity for wind farm developments in physical attributes of the Collector area’. the Shetland Islands. This report includes references to a number of standard texts produced by leading agencies such as the Countryside Commission and Scottish Natural Heritage. These standard texts (which should be familiar to consultants with experience in the assessment and representation of visual impacts of wind farms), are also referenced in the Government of Western Australia Department for Planning and Infrastructure’s manual ‘Visual Landscape Planning in Western Australia’. The criteria included in the Collector wind farm LVIA are as relevant to the landscape surrounding the Collector wind farm as they are to landscapes surrounding wind farms in Europe, Asia or the Americas. As noted previously, GBD are not cognisant of the RLA landscape assessment methodology or how it is applied in the determination of landscape sensitivity for wind farm developments.
The RLA comment is stated as a matter of opinion. In GBD’s opinion: x the assessment of sensitivity has been
12 GREEN BEAN DESIGN l a n d s c a p e a r c h I t e c t s PO Box 3178 Austral NSW 2179 - Mobile 0430 599 995 adequately described; x the criteria adopted have been adequately justified; and x community consultation has been undertaken.
10.1 RLA Comment: 10.2 GBD Response:
Visual Impact Assessment Criteria and Matrices
‘Tables 15 and 16 present what are described as The LVIA states that the degree of visual impact Visibility Matrices for residential and public view resulting from the construction and operation of the locations in the 10 km viewshed. The right hand wind farm would result from a combination of factors column contains the assessment of visual impact for such as: any dwelling or road. It is difficult to determine how it x visibility or extent to which the proposed wind was arrived at, given the complexity of the farm structures would be visible from parameters that are claimed to be behind it, other than those that are on the tables.’ surrounding areas;
x degree of visual contrast between the Project ‘… if the sensitivity of the viewing place is negated by their being low numbers of viewers, there is no point structures and the capability of the surrounding is assessing it. In my opinion, it is also not helpful to landscape to visually accommodate the wind have a parameter for numbers of viewers in a farm; sensitive location such as a residence.’ x category and type of situation from which people It is notable that although views from 110 residences could view the wind farm (examples of view were assessed, the whole village of Collector appears to be represented by only one (R32) categories include residents or motorists);
x distance between the view location and the The period of view parameter appears to be the factor that counteracts the high numbers of people and high Collector Wind Farm turbines; view sensitivity for locations such as the Hume x potential number of people with a view toward Highway and Federal Highway. This needs to be the Project from any one location; explained and justified. x duration of time people could view the Project The Trail (Bicentennial Trail) was not specifically from any static or dynamic view location; and assessed with regard to cumulative impacts. x visual sensitivity of view location surrounding the The summary of visual impact (Section 8.4 at Pages Project. 68-69 of the LVIA concludes as follows:
13 GREEN BEAN DESIGN l a n d s c a p e a r c h I t e c t s PO Box 3178 Austral NSW 2179 - Mobile 0430 599 995 The criteria applied to these factors are set out in the It should be noted that the term ‘visual impact’ does LVIA. In GBD’s opinion it is not apparent that a low not necessarily imply or represent an individual’s number of viewers negate the sensitivity of the negative response toward the visibility of wind viewing place, as the LVIA report has identified turbines, and that perceptions of wind farms amongst residential dwellings with a low number of viewers individuals within any community can be positive, with a high visual impact. negative or neutral. The village of Collector has been assessed as a ‘It is no (sic) clear what this means. It seems to imply singular receptor location. The decision to assess the that visual impacts are objective facts that are village of Collector as a single area location was the independent of community values. If so, this would result of a number of factors such as: be of great concern with regard to the adequacy of x number of and complexity of views from the assessment of this application’. residential dwellings;
x unreasonable level of logistics involved in
coordinating access to each individual dwelling;
and
x potential for views to extend from the curtilage
of residential dwellings as well as surrounding
communal areas.
Table 15 of the LVIA report records this location as R32 and describes the potential extent of visibility including areas of the village likely to be afforded screening due to topography and vegetation, as well as areas of the village with a greater degree of visibility toward portions of the proposed wind farm. The Collector wind farm LVIA has determined the residents within the village may experience a moderate to high visual impact. The summary statement concludes ‘it should be noted that the term visual impact does not necessarily imply or represent an individual’s negative response toward the visibility of wind turbines, and the perceptions of wind farms amongst individuals within any community can be positive, negative or neutral’.
14 GREEN BEAN DESIGN l a n d s c a p e a r c h I t e c t s PO Box 3178 Austral NSW 2179 - Mobile 0430 599 995 The criteria for the period of view are set out in the LVIA Table 12. The period of view parameters include: x Long term for a period of over 2 hours;
x Moderate term for 30 minutes to 2 hours;
x Short term for 10 minutes up to 30 minutes; and
x Very short term for less than 10 minutes.
These periods of time have been determined against the overall period of view that may be available during daylight hours (assumed to be a period of around 12 hours, discounting seasonal variation). Therefore, as a percentage of the maximum viewing time available during daylight hours: x a period of 2 hours represents approximately
17% of daylight hours;
x a period of 30 minutes represents approximately
4.5% of daylight hours; and
x 10 minutes represents approximately 1.5% of
daylight hours.
The LVIA has therefore determined that a period of view toward the wind turbines in excess of 17% of available daylight time will result in a long term period of view and conversely a period of view toward the wind turbines below 1.5% of available daylight time will result in a very short term view. Again, GBD have considered these relative periods of view with regard to the what the brain ‘sees’ in response to what the eye detects, rather than the image of the wind turbine being carried forward in our sub consciousness for all time.
The Trail has not been specifically assessed with regard to cumulative impacts. We have reviewed this and confirm that the proposed Collector wind farm
15 GREEN BEAN DESIGN l a n d s c a p e a r c h I t e c t s PO Box 3178 Austral NSW 2179 - Mobile 0430 599 995 would have an overall low cumulative impact for direct, indirect and sequential views. At over 5,300 km long, the proportion of the Trail extending through the Collector wind farm site would represent approximately 0.2% of the total Trail and taking into account additional wind farms in the regional would still be less than 0.5% of the Trail.
This summary does not imply that visual impacts are objective facts that are independent of community values. It simply states that within any community (for example the residents of Collector) there will be a range of visual attitudes toward the proposed wind farm, including those that are negative, as well as neutral and positive. This range of attitudes has been documented by community consultation as well as the submissions received during the public exhibition period. Again, we believe that RLA have misconstrued the intent of this important statement.
11.1 RLA Comment: 11.2 GBD Response:
Cumulative Impacts
‘As a result the 10 km viewshed adopted in the LVIA The LVIA has not adopted a 10 km viewshed, but for the assessment of impacts in not the correct responds to the requirements set out by the DoP&I in context for an assessment of cumulative impacts’. the Collector wind farm DGR’s. The cumulative impact assessment is presented at Section 9 of the ‘Cumulative impact is not only the impression of LVIA and identifies wind farms well in excess of the 10 greater magnitude, but also the impression of greater km viewshed such as the Gunning, Capital and overall presence or dominance of the landscape by Woodlawn wind farm developments. features such as wind farms, which form an easily recognised cognitive category identifiable from great It is not clear how RLA define ‘great distances’ or distances’. what empirical evidence they base this claim on. GBD field experience has determined that wind farms form ‘With regard to the sense of change that is part of an easily recognised cognitive feature up to a distance cumulative impact, people may form the impression of approximately 20 km, beyond which it becomes that the land is changing from rural/natural increasingly difficult to distinguish the presence or landscape to a more industrial character…’ movement of rotors.
16 GREEN BEAN DESIGN l a n d s c a p e a r c h I t e c t s PO Box 3178 Austral NSW 2179 - Mobile 0430 599 995 The Collector wind farm would be very much larger Some people may form an opinion that the wind farm than Cullerin, and in that context it follows that there will result in the landscape taking on an industrial is a cumulative impact and it is more attributable to character. Opponents to wind farms often express the Collector wind farm than to Cullerin. It is for the negative opinions that compare wind farms to applicant to show that this is not a significant matter. factories. However, people may also form different impressions based on a range of social, cultural and personal beliefs. Whilst the sense of place surrounding the Collector wind farm is no doubt rural in character, there is little that remains ‘natural’. The landscape surrounding the wind farm has been highly modified post European settlement and bears visible signs of a productive agricultural industry.
We cannot dispute the claim that the Collector wind farm would be larger than the operational Cullerin wind farm. With 68 proposed wind turbines the Collector wind farm would be approximately 4.5 times larger. Having gained experience consulting on wind farm projects for up to 200+ turbines, GBD consider the Collector wind farm to be a moderate sized development when compared to other proposed wind farm developments in New South Wales. As the Cullerin wind farm is an existing and operational development, any cumulative impact would be attributable to the Collector wind farm – it is not clear how this could be otherwise? The LVIA has demonstrated that the Collector and Cullerin wind farms would not result in a significant cumulative impact and specifically notes that: “There would opportunities for ‘direct’ and ‘indirect’ views toward the Collector and Cullerin Wind Farms from surrounding residential dwellings and public view locations including local roads and highways; however, visibility toward both wind farms would be restricted in some locations due to tree cover and undulating landform within the surrounding landscape. The relatively small size of the Cullerin Wind Farm
17 GREEN BEAN DESIGN l a n d s c a p e a r c h I t e c t s PO Box 3178 Austral NSW 2179 - Mobile 0430 599 995 development would minimise potential for significant cumulative visual impact, as would the general alignment and layout of the Collector Wind Farm in relation to the Cullerin Wind Farm where, from a majority of surrounding view locations, both wind farm developments would be observed as a continuation along the same topographic feature of the local landscape”.
In GBD’s opinion the LVIA cumulative impact assessment (presented at Section 9 of the LVIA) has demonstrated that there is no significant cumulative impact likely to occur as a result of the Collector wind farm.
END
18 GREEN BEAN DESIGN l a n d s c a p e a r c h I t e c t s PO Box 3178 Austral NSW 2179 - Mobile 0430 599 995 APPENDIX C. Photomontage Response Summary
RATCH - Collector Windfarm Response
Truescape review and response to opposition commentary on the TrueView images submitted.
www.truescape.com Truescape review and response to opposition commentary on the TrueView images submitted.
Truescape’s response to Whelans Insites Image comparisons
Whelan Insites produced a booklet with some comparisons of parts of Truescape’s images to images they produced from single frame images.
,WLVLPSRUWDQWWRQRWHWKDWLWLVPLVOHDGLQJWRFRPSDUHLPDJHVWDNHQIURPWKHVDPHYLHZSRLQWWKDWKDYHVLJQL¿FDQWO\GLIIHUHQW¿HOGVRIYLHZEXWDUHSULQWHGDWWKHVDPH SK\VLFDOVL]HUHJDUGOHVVRIWKLVGLIIHUHQFH7KHLPDJHZLWKWKHVPDOOHU¿HOGRIYLHZLVDVXEVHWRIWKHLPDJHZLWKWKHODUJHU¿HOGRIYLHZ,QVLWHLQFRUUHFWO\FRPSDUHVWKHLU LPDJHVWRWKH7UXHVFDSHLPDJHVWKLVZD\ZKLFKPHDQVWKDWWKHLPDJHVZLWKWKHJUHDWHU¿HOGRIYLHZDSSHDUWRUHGXFHWKHVFDOHRIWKHWXUELQHVIURPWKHYLHZHU¶VSHUVSHFWLYH FRPSDUHGWRWKHORRNRIWKHLPDJHZLWKWKHVPDOOHU¿HOGRIYLHZ+RZHYHUZKHQWKHLPDJHVDUHSULQWHGFRUUHFWO\DWWKHVDPHVFDOHDSURSHUFRPSDULVRQFDQEHPDGH
Please see ‘Appendix A’ZKLFKVKRZWKHIXOO7UXH9LHZLPDJHVDQGFURSSHGSRUWLRQVRIWKH7UXH9LHZLPDJHVWKDWUHSUHVHQWWKHVDPH¿HOGRIYLHZDVWKH,QVLWHVLQJOHIUDPH images. Once the comparison cropped image and the Insite Images are then printed at the same size and put side by side then an accurate comparison can be made. It is interesting to note that the scale and positioning of the simulated wind turbines in the cropped portions of the TrueView images are compared with the Insite images the scale of the simulated turbines look ‘reasonably similar’ in both images.
The differences in the positions and slight difference in scale of the turbines in the TrueView images compared to the Insite images are probably due to one or more of the following:
1. ,WLVQRWFOHDULI,QVLWHVXUYH\¿[HGWKHLUFDPHUDSRVLWLRQVRULIWKH\GLGZKDWHTXLSPHQWZDVXVHGWRGRVR1RWHLIDKDQGKHOG*36XQLWZDVXVHGWKLVGRHVQRWKDYH DQ\ZKHUHQHDUWKHGHJUHHRIDFFXUDF\RISURIHVVLRQDOJUDGHVXUYH\HTXLSPHQW 2. ,WGRHVQRWDSSHDUWKDW,QVLWHVXUYH\¿[HGDQ\UHIHUHQFHSRLQWVWRHQDEOHWKHLUSKRWRJUDSKVWREHDFFXUDWHO\DOLJQHGWRWKHLUFRPSXWHUPRGHO 3. ,WDSSHDUVWKDW,QVLWHPDWFKHGWKHLUFRPSXWHUPRGHOWRWKHLUSKRWRJUDSKVE\DOLJQLQJREMHFWVE\H\HZKLFKLVDEHVWJXHVVDVRSSRVHGWRKDYLQJVXUYH\¿[HGUHIHUHQFH points to accurately align the image to. We refer to their statement ‘if the existing features in the model overlay in accordance with the existing features in the photograph, then it follows that the proposed wind turbines modelled in AutoCAD is also overlayed in the correct locations on the photograph creating an accurate photomontage’. 7KHLPSOLHGDVVXPSWLRQKHUHWKDW µWKLQJVZLOOIROORZ¶7KLVLVDQXQFRQWUROOHGWHFKQLTXHZKLFKFDQUHVXOWLQVLJQL¿FDQWHUURUVDVLWLVGHSHQGHQWRQWKHFRPSXWHURSHUDWRU¶V DELOLW\WRµEHVWJXHVV¶ZLWKRXW¿[HGVXUYH\SRLQWVWRDOLJQ:LWKRXWVXUYH\FRQWUROWKH,QVLWHLPDJHVFDQQRWEHFRQVLGHUHGDVµYDOLGDWHGRUFHUWL¿HG¶+RZHYHUDVWKHLULPDJHV DUHUHDVRQDEO\VLPLODUWRWKHFURSSHGSRUWLRQVRIWKH7UXH9LHZLPDJHVWKH\KDYHEHHQH\HEDOOHGLQWKHLUPRGHOIDLUO\ZHOO 4. 7KH7UXHVFDSHFDPHUDSRVLWLRQVDQGDOLJQPHQWUHIHUHQFHSRLQWVZHUHVXUYH\¿[HGWRDFFXUDWHO\UHIHUHQFHWKHWXUELQHVLQWKH7UXHVFDSHPRGHOLQWRWKH7UXH9LHZ photography.
The difference in visibility of the turbines in the Insite images compared to the TrueView images is probably due to the different weather and lighting conditions in the FRPSDULVRQSKRWRJUDSKVDQGWKHGLIIHUHQWWHFKQLTXHVWKDWKDYHEHHQHPSOR\HGWRVLPXODWHWKHWXUELQHVWKHPVHOYHV7UXHVFDSHKDVWDNHQOLJKWLQJFRQGLWLRQVLQFOXGLQJFRUUHFW WLPHRI\HDUDQGWLPHRIGD\LQWRDFFRXQWDVZHOODVWKHFRUUHFWWXUELQHFRORXUZKHQVLPXODWLQJWKH7UXH9LHZLPDJHV7KHUHLVQRLQIRUPDWLRQSURYLGHGE\,QVLWHDVWRZKDW they have done in this regard which could be a reason why the Insite towers look as dominant in their images as they do.
Truescape response to Dr Richard Lamb’s commentary.
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page 2 Truescape review and response to opposition commentary on the TrueView images submitted.
'U5LFKDUG/DPEUHIHUHQFHVDUHDVRISHUFHLYHGGLVWRUWLRQLQWKH7UXH9LHZLPDJHV:HDFNQRZOHGJHWKDWLIWKHLPDJHVDUHYLHZHGRQDÀDWSODQHVXFKDVUROOHGRXWRQDWDEOH DQGQRWPRXQWHGLQWKHLUYLHZVWDQGVWKHQWKHUHLVDPLQRUDUHDRIDSSDUHQWGLVWRUWLRQDWERWKHQGVRIWKH7UXH9LHZLPDJHV+RZHYHULIWKHLPDJHVDUHYLHZHGFRUUHFWO\LQ WKHLUGLVSOD\VWDQGVLQWKHZD\GHSLFWHGLQWKHGLVSOD\GLDJUDP ZKLFKLVSULQWHGLQWKHWDEOHRQWKHULJKWKDQGVLGHRIHDFKLPDJH WKHQWKLVPLQRUDUHDRIGLVWRUWLRQLVDOOEXW mitigated.
Dr Richard Lamb makes reference to a dam and a water surface in two images and states that ‘it is obvious that water surface is not horizontal relative to the centre of the images’ :KLOHZHDFNQRZOHGJHWKHPLQRUGLVWRUWLRQDWWKHHGJHVRIWKH7UXH9LHZLPDJHVZKHQYLHZHGÀDWWKLVSDUWLFXODULQVWDQFHLVDSHUVSHFWLYHLVVXHQRWDGLVWRUWLRQ LVVXH,QWKLVVLWXDWLRQZHDUHYLHZLQJDQREMHFWRILUUHJXODUVKDSHLQWKHSHULSKHU\RIWKHSULPDU\KXPDQ¿HOGRIYLHZZKLFKKDVDÀDWVXUIDFH WKHZDWHUVXUIDFH :HDUH DOVRYLHZLQJWKLVZDWHUERG\IURPDUHODWLYHO\ORZDQJOHRIYLHZIURPWKHFDPHUDWRWKHZDWHUVXUIDFH6HH ‘Appendix B’ which shows a computer generated example here WRGHPRQVWUDWH7KHYLVXDOHIIHFWLVDUHVXOWRIWKHSRQGEHLQJDWDQREOLTXHDQJOHUHODWLYHWRWKHYLHZHUDQGLQWKHSHULSKHU\RIWKHYLHZZKLFKFDXVHVWKHZDWHUVXUIDFHWR appear to at an angle relative to the viewer when in fact it is actually how we see things in our peripheral vision but we don’t notice this directly.
Because Dr Richard Lamb has mistakenly assumed that Truescape uses standard stitching to produce our images his further assumptions that the TrueView images represent a ‘quasi wide angle view’ which ‘have some of the same shortcomings in this regard as very wide angle single images’ is also not correct. TrueView images do not have the shortcomings such as ‘increasing the apparent distance between object in the horizontal plane‘ that he refers to.
Dr Richard Lamb also expresses an opinion that images taken with a full frame camera using a 50 mm lens are best used to produce images that a computer model ‘ZLOO¿W accurately into the image and objects in it will appear to be the correct size and distance from the viewer’ It is not the focal length of a particular lens alone that dictates FRUUHFWVL]HRIREMHFWVLQDQLPDJHDVDFFXUDWHPDWFKHVFDQEHPDGHWRDZLGHUDQJHRIIRFDOOHQJWKV+RZHYHUWKHIRFDOOHQVRIWKHOHQVPXVWEHNQRZQWRPDWFKDPRGHO SURSHUO\7KHLPSRUWDQWSRLQWKHUHUHPDLQVWKDWLWLVWKH¿HOGRIYLHZUHSUHVHQWHGE\DQLPDJHSOXVWKHVL]HWKDWWKHLPDJHLVSK\VLFDOO\SULQWHGDQGWKHGLVWDQFHIURPZKLFK WKHLPDJHLVYLHZHGWKDWGLFWDWHVWKHYLHZHGVL]HRIREMHFWVQRWWKHIRFDOOHQVRIWKHOHQVXVHGWRSURGXFHWKHPRQLWVRZQ
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Truescape’s response to the ‘Friends of Collector submission’
In answer to the criticism of the TrueView images summarised in points 3.5 to 3.8 of that submission.
7UXHVFDSHLPDJHVGRQRWGRZQSOD\UHGXFHWKHVFDOHDUHQRWPLVUHSUHVHQWDWLYHLQDGHTXDWHRUXQUHOLDEOHVFDQGDORXVRURWKHUZLVH,QIDFWWKH7UXHVFDSHLPDJHVDQGWKH Insite images depict the simulated turbines at a reasonably similar size and scale when the images are correctly compared to one another.
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If the Truescape images are printed at their full size as depicted in the table and are viewed in their proper display stands and are viewed from the correctly from 50 FHQWLPHWHUVDZD\WKHQWKHLPDJHV¿OOWKHYLHZHU¶VHQWLUHSULPDU\KXPDQ¿HOGRIYLHZDQGHYHU\WKLQJLQWKHPDUHDWWKHH[DFWUHDOZRUOGVFDOHIURPWKHYLHZHU¶VSHUVSHFWLYHDV they are in the real world.
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page 3 RATCH - Collector Windfarm Response
APPENDIX A
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page 5 $33(1',;$
* Insite photography was not taken from the exact position as Truescape SKRWRJUDSK\KHQFHVOLJKW variation in view
TrueView with image overlay of Insites image
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page 6 7UXHVFDSHLPDJHZKHQSULQWHGRQ$WREHYLHZHGDWFPGLVWDQFH A3 to be viewed at 50cm distance A4 to be viewed at 35cm distance
page 7 ,QVLWHLPDJHZKHQSULQWHGRQ$WREHYLHZHGDWFPGLVWDQFH A3 to be viewed at 50cm distance A4 to be viewed at 35cm distance
page 8 RATCH - Collector Windfarm Response
APPENDIX B
www.truescape.com $33(1',;%
Top view of TrueView 124° viewing angle with simulated water body
TrueView showing 124° viewing angle with simulated water body
page 10 APPENDIX D. Noise Impact Assessment
COLLECTOR WIND FARM Submission Response Rp 003 draft 2012127SY
13 November 2012
6 Gipps Street Collingwood 3066 Victoria Australia T: +613 9416 1855 F: +613 9416 1231 A.C.N. 006 675 403 www.marshallday.com
Project: COLLECTOR WIND FARM
Prepared for: Ratch Australia c/o APP Pty Limited PO Box 1573 North Sydney Sydney NSW 2059
Attention: Clair Baxter
Report No.: Rp 003 draft 2012127SY
Disclaimer Reports produced by Marshall Day Acoustics Pty Ltd are prepared based on the Client’s objective and are based on a specific scope, conditions and limitations, as agreed between Marshall Day Acoustics and the Client. Information and/or report(s) prepared by Marshall Day Acoustics may not be suitable for uses other than the original intended objective. No parties other than the Client should use any information and/or report(s) without first conferring with Marshall Day Acoustics. Copyright The concepts and information contained in this document are the property of Marshall Day Acoustics Pty Ltd. Use or copying of this document in whole or in part without the written permission of Marshall Day Acoustics constitutes an infringement of copyright. Information shall not be assigned to a third party without prior consent.
Document control Status: Rev: Comments Date: Author: Reviewer: Draft - For review and comment 13/11/2012 J. Adcock D. Griffin
TABLE OF CONTENTS
1.0 INTRODUCTION ...... 4
2.0 MDA REPORT – OPERATIONAL NOISE ASSESSMENT SUMMARY ...... 5
3.0 NOISE ASSESSMENT POLICY ...... 7 3.1 Margin above background noise level ...... 7 3.2 Policy objective ...... 9
4.0 MATTERS SPECIFIC TO COLLECTOR WIND FARM ...... 10 4.1 Baseline noise levels ...... 10 4.2 Noise predictions ...... 11 4.2.1 A-weighted predictions ...... 11 4.2.2 Candidate turbines ...... 13 4.2.3 Low frequency predictions ...... 13 4.3 Seasonal effects ...... 14 4.4 Tonality & Amplitude Modulation ...... 14 4.5 Low frequency noise ...... 15 4.6 Other wind farm sites ...... 15
5.0 CONCLUSIONS ...... 17
Rp 003 draft 2012127SY DPI Submission Response Page 3
1.0 INTRODUCTION An environmental noise impact assessment of the proposed Collector Wind Farm was carried out by Marshall Day Acoustics (MDA), and was documented in the report titled Collector Wind Farm Noise Impact Assessment dated 4 June 2012 (report reference Rp 002 R07 2010127SY and subsequently referred to as the MDA report). The MDA report addressed environmental noise associated with: Construction traffic and activities Operational wind turbines Ancillary electrical infrastructure including substations and grid connections The MDA report was submitted as Appendix F to the Collector Wind Farm Environmental Assessment dated June 2012 (the Environmental Assessment). In response to the Collector Wind Farm Environmental Assessment, a submission was made by the Friends of Collector to the NSW Department of Planning and Infrastructure on 24 September 2012. Volume 1 Section 4 of the submission titled Peer Review of the Collector Wind Farm Noise Assessment contains a critique of the MDA report prepared by the Acoustic Group on behalf of the Friends of Collector (subsequently referred to as the AG Report). The AG report primarily raises matters relating to operational noise. The AG report includes general commentary relating to wind farm noise policy (i.e. that is not specific to the Collector Wind Farm), and specific commentary regarding the assessment methodologies outlined in the in the MDA report. This document provides information in response to the matters raised by the AG report. For ease of reference, this report provides a summary of the operational noise assessment prepared by MDA, followed by a discussion of the noise policy used to assess the Collector Wind Farm, and a final section dealing with specific matters raised in the AG report.
Rp 003 draft 2012127SY DPI Submission Response Page 4
2.0 MDA REPORT – OPERATIONAL NOISE ASSESSMENT SUMMARY In accordance with the Director-General’s Requirements (DGRs) for the proposed Collector Wind Farm, and further advice provided by the NSW Department of Planning and Infrastructure (DPI), the following documents have been used to assess operational noise levels: the South Australia Environmental Protection Authority (EPA) Environmental Noise Guidelines: Wind Farms (2003) (the 2003 SA Guideline) the draft document NSW Planning Guidelines: Wind Farms issued by the NSW Department of Planning and Infrastructure in December 2011 (the draft NSW Guideline) The operational noise assessment involved background noise monitoring at a number of locations. The background noise monitoring confirmed that the areas surrounding the development site are characterised by relatively low noise levels. As a result of observed anomalies in some of the results which are believed to have been attributable to seasonal effects, the background noise monitoring has not been used for the purpose of setting limit values for the site. Instead, the results have been referenced as confirmation of the low background noise environment in the area. Accordingly, for the purposes of the noise impact assessment, background noise levels have been assumed to be below 30dB at all wind speeds. The lowest noise limit of 35dB from the above policies has therefore been applied to the assessment. In practice, there will be periods when background noise levels are higher than 30dB, particularly during periods of increased wind. This was evident in the background noise monitoring presented in Appendix H and Appendix I of the MDA report. Noise levels from the operational wind farm have been predicted in accordance ISO 9613-2: 1996- Acoustics – Attenuation of sound during propagation outdoors – Part 2: General method of calculation (ISO 9613-2). This method has been used with input choices that are specific to wind turbine noise assessments. The ISO 9613-2 standard was originally validated for the assessment of noise sources positioned less 30m above ground level. Subsequent validation work has demonstrated the suitability of the method for the source heights and environments associated with modern wind farm development. Specifically, the method has been internationally proven as a reliable wind farm noise prediction tool, based on well documented research publications, and the findings of successfully completed and operational wind farms in Australia and abroad. Detailed supporting references for this prediction method were provided in section 4.4.1 of the MDA report. Noise predictions using ISO 9613-2 have been found to provide a reliable representation of the regularly occurring upper noise levels occurring under atmospheric conditions which enhance the propagation of sound. The noise predictions were carried out for three (3) turbine models nominated by the project proponent as being representative of the range of candidate turbines being considered for the project. The predictions are specific to the proposed development, accounting for turbine layout, the terrain of the area, and the location of all dwellings in the vicinity of the proposal.
Rp 003 draft 2012127SY DPI Submission Response Page 5
Section 4.4.3 of the MDA report provided maximum predicted noise levels at each of the dwelling locations, including locations with and without an involvement in the project. In relation to dwellings without an involvement in the project, Table 1 provides a summary of the predicted noise levels for the nearest dwellings. At all other locations, the highest predicted noise levels are below 26dB. Table 1: Summary of predicted noise levels at dwellings not involved with the project
Predicted noise level No. of dwellings not involved with project
35dB < LAeq,10min Zero (0) dwellings
32dB < LAeq,10min ≤ 35dB Two (2) dwellings
29dB < LAeq,10min ≤ 35dB Eleven (11) dwellings
26dB < LAeq,10min ≤ 29dB Eight (8) dwellings
The noise predictions presented in Section 4.4.3 of the MDA report, and summarised above, represent the highest predicted noise levels expected to occur in practice when measured and rated in accordance with the 2003 SA Guideline. Specifically, they account for simultaneous downwind propagation of noise from all turbines associated with the proposal. In practice, operational noise levels will vary with wind speed and wind direction and will frequently be lower than predicted. At low wind speeds, the turbines either do not operate, or operate at reduced rotational speed, equating to significantly lower noise levels. In upwind directions, noise levels may be up to 10-15dB lower than predicted. In addition to the prediction of A-weighted noise levels required for an assessment of compliance with the relevant policies, the MDA report provided additional information concerning low-frequency noise and infrasound. Section 4.4.1 of the MDA report provides details of the methods used to predict the low frequency noise in terms of the C-weighted levels specified by the draft NSW guidelines, including a discussion of the technical limitations of predicting C-weighted noise levels. Predicted low-frequency noise levels are then presented in Section 4.4.4 of the MDA report, along with further discussion of the predictions. The results and discussion presented in Section 4.4.4 conclude that C-weighted wind turbine noise levels are expected to be below the lowest threshold value of 60dB stipulated in the draft NSW guidelines. Section 4.5 of the MDA report then provided additional discussions concerning a range of matters including low frequency noise, infrasound, vibration and amplitude modulation. This information included reference to a range of international documents, including Australian and international government publications, which support the view that current noise assessment practices remain appropriate. Further, the reference publications support the view wind farms do not represent a significant source of infrasound or low-frequency noise.
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3.0 NOISE ASSESSMENT POLICY The AG report suggests that the 2003 SA Guideline is not an appropriate method for assessing the noise impact of a wind farm. The AG report’s contention is based on a range of factors such as background noise levels in rural areas and the alleged characteristics of wind farms such as low-frequency noise. The 2003 SA Guideline has been applied to the Collector Wind Farm in accordance with the following clause of the Director-General’s Requirements: The assessment must be undertaken consistent with the following guidelines (as or otherwise agreed with the DECCW): → Wind Turbines – the South Australian Environment Protection Authority’s Wind Farms – Environmental Noise Guidelines, 2003; The aims of the 2003 SA Guideline are noted as follows: The document aims to help developers, planning and enforcement authorities, other government agencies and the broader community assess environmental noise impacts from wind farms. In addition, Section 2.3 of the 2003 SA Guideline states: The criteria have been developed to minimise the impact on the amenity of premises that do not have an agreement with wind farm developers. The above factors clearly establish the basis for using the 2003 SA Guideline to assess the noise impact associated with the Collector Wind Farm. The following addresses the key policy views noted in the AG report. Other general factors are raised in the AG report, such as low frequency noise, and these are separately discussed in Section 4 in the context of the Collector Wind Farm noise assessment. 3.1 Margin above background noise level A key reason for the AG report’s contention concerning the SA 2003 Guideline, and its use as an assessment of noise impact, is that the policy does not require a margin between background noise and turbine noise to be maintained if the turbine noise level is sufficiently low. In this respect, the AG report refers to previous versions of Australian Standard AS 1055 Acoustics – Description and measurement of environmental noise to support their view that significant impacts are deemed to occur if the source noise exceeds the background noise by 5dB. The version of AS 1055 referred to in the AG report is a superseded standard dated 1989, rather than the 1997 publication listed to in the AG report bibliography. The alternative criterion proposed in the AG report is sourced from AS 1055.2 1989 Part 2: Application to specific situations, Appendix A. The relevant extract is reproduced below in Figure 1.
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Figure 1: Extract from superseded standard AS 1055.2-1989 In relation to the AG report’s use of the method referred to in the above extract, we note the following: The standard was superseded by a revised document in 1997 which did not retain the procedure referred to in the AG report was not included in the revised standard The foot note which contains the procedure referred to in the AG report does not provide an indication of the range of backgrounds to which the margin should apply; it is however noted that the subsequent Appendix of the superseded standard only refers to environments with background noise levels ranging from 30-60dB. The preface to the superseded standard states that it is not a regulatory document and users should ascertain, from the relevant Regulatory Authority, details of specific requirements laid down in each State or Territory. Given the above considerations, the relevance of the alternative assessment reference suggested in the AG report is unclear. Notwithstanding the above, it must be emphasised that the 2003 SA Guideline was specifically developed in recognition of the low background noise environments where wind farms are typically developed. The 2003 SA Guideline recognises the need to restrict wind farm noise levels to an acceptable margin above background, and states that the impact of a noise is closely linked to the it exceeds the background noise. However, the 2003 SA Guideline also specifies a minimum limit value on the basis that it is not necessary to continue to maintain this margin above the background noise level in instances when both the background and source noise levels are low. In the case of the 2003 SA Guideline, the value of 30dB is chosen as the background value below which it is not necessary to continue to adhere to a margin of 5dB above background. Accordingly, the minimum limit value is defined as 35dB. It is worth noting that this approach is consistent with other wind farm policies applied in Australia and abroad. The approach is also is consistent with the NSW Industrial Noise Policy, and the draft NSW Guideline, which similarly do not require the margin above background to be adhere to once the background noise levels fall below 30dB.
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3.2 Policy objective The AG report suggests that the appropriate criterion should be selected to ensure that there are no adverse impacts, and that the Applicant should be required to guarantee this. Appropriate noise policies for infrastructure developments must provide an acceptable level of amenity protection, whilst providing a viable framework that allows essential development. An important distinction here is the concept of an acceptable level of amenity protection, in contrast to an assurance of no adverse impact for surrounding residents. The level of a noise is one of many factors which influence perceptions of the noise; other factors are not related to the level, and include non-acoustic factors such as an individual’s attitude to the noise in question, and the perceived benefits of the source of noise in question. Accordingly, whilst a policy may impose strict requirements to limit a noise source to low levels, the subjective nature of noise perception means that it is not possible to ensure an individual will perceive the noise to be acceptable; this will always be a matter of individual judgement. Environmental noise policies are therefore intended to provide an acceptable level of amenity protection for the majority of people. This is consistent with the introduction of the 2003 SA Guideline which states: The core objective of these guidelines is to balance the advantage of developing wind energy projects in this Stage with protecting the amenity of the surrounding community from adverse noise impacts.
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4.0 MATTERS SPECIFIC TO COLLECTOR WIND FARM 4.1 Baseline noise levels The AG report states that baseline conditions have not been accounted for in the Collector Wind Farm noise impact assessment. The AG report also provides comments on the limitations and anomalies evident in the background noise data. In response, we note the following: Background noise monitoring was carried out at eight (8) locations to gather information about baseline conditions in the area The results of the background noise monitoring were used to confirm that the area is characterised by low background noise levels The MDA report states that the background noise levels, and indicative noise criteria derived from them, have been presented for reference purposes only Appendix H of the MDA report quantitatively and qualitatively describes trends in the data set which are believed to be attributable to seasonal influences (fauna and insects). As a result, the MDA report specifically states that background noise levels may regularly be lower than measured during the survey period. In recognition of the character of the area surrounding the development site, the assessment has been made on the basis of the lowest possible range of background noise conditions. Specifically, the assessment allows for the effect of background noise levels being regularly below 30dB, even at higher wind speeds, in lieu of actual measured data. This means that the lowest possible limit of 35dB has been applied to the assessment. In practice, background noise levels will regularly be higher, particularly at high winds speeds. The assessment therefore represents a cautious approach. Based on the above, and contrary to the assertions of the AG report, baseline conditions have been accounted for in the assessment. They have been accounted for in the manner that is required to conduct an assessment in accordance with the 2003 SA Guideline. The AG report’s comments concerning the account of baseline is directly linked to their view that alternative assessment approaches to the 2003 SA Guideline should be applied to the Collector Wind Farm. Refer to Section 3.1 above for further comments concerning the AG report’s suggested alternative approaches. In relation to the background noise monitoring, the following additional notes are provided in response to the AG report: A separate analysis of night-time background noise conditions is presented in Appendix H of the MDA report to address the related requirements of the DGR (see section titled Diurnal Noise Trends of Representative Datasets of Appendix H). In relation to night- time conditions, we confirm that the assessment has been cautiously made on the basis of background noise levels being below 30dB at all wind speeds Photographs of all background noise monitoring locations were gathered during the survey. At the request of the project proponents, these photographs were not included in the report, in the interest of respecting the privacy of the residents. Subject to permission being obtained from the residents, these photographs can be provided if requested
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Wind speeds at the microphone are discussed in Appendix E (see section titled Additional Survey Considerations), and confirms that wind speeds remained below 5m/s at the weather stations installed at the Woodpark and Tamaroo dwellings 4.2 Noise predictions The AG report queries the predicted noise levels in the MDA report, and the extent to which the predicted noise levels represent the range of meteorological conditions which could occur. In questioning the predicted noise levels, the AG report makes reference to inversions and the “Van den Berg effect”. The AG report also queries the candidate turbines used for the study, and refers to predictions in relation to low frequency sound. 4.2.1 A-weighted predictions Section 4.4.1 of the MDA report provides a detailed description of the International Standard ISO 9613-2 which has been used for the Collector Wind Farm noise assessment. The section documents national and international publications which support the use of the standard as an appropriate method of predicting typical upper noise levels under atmospheric conditions which enhance the propagation of sound, including wind and temperature inversion effects. In the time since the MDA report was produced, further support for the use of this standard has been documented in the UK Institute of Acoustics (UK IoA) Discussion Document on “A Good Practice Guide to the Application of ETSU-R-97 for Wind Turbine Noise Assessment”. This UK IoA document indicates ISO 9613-2 to be current best practice, and the most widely used and validated prediction method for wind farm noise. To confirm the material already documented in the MDA report, the predictions represent the upper noise levels expected to occur under worst case conditions when measured in assessed in accordance with the applicable policy. The method conservatively assumes simultaneous downwind propagation from each turbine to each receiver location. The AG report is critical of the absence of predicted noise level data for alternative conditions in which the noise levels will be lower. However, the typical worst case noise levels presented in the MDA report have enabled compliance to be demonstrated with the minimum applicable 2003 SA guideline limit. In other conditions, noise levels in practice will be lower, increasing the margin of compliance with the relevant noise limits. Notwithstanding the above, the following comments are provided in relation to calculations for alternative conditions in which the noise levels will be lower: The ISO 9613-2 prediction method only relates to conditions which enhance sound propagation. Noise levels will be lower in alternative conditions, however the only ISO 9613-2 weather condition adjustment relates to longer term averages which are not an appropriate basis for assessment Alternative calculation techniques such as CONCAWE define a method for calculating noise under varied atmospheric conditions. Whilst this is a perceived benefit of CONCAWE, studies have shown the method to be unreliable for this purpose. Section 4.4.1 of the MDA report referred to the European study1 which demonstrated
1 Bass, Bullmore and Sloth - Development of a wind farm noise propagation prediction model; Contract JOR3-CT95-0051, Final Report, January 1996 to May 1998.
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CONCAWE and ENM to be unsuitable for wind farm noise assessments, and indicated calculated noise level variations which were not measured in practice. In this respect, it is informative to note that whilst the CONCAWE method was developed in the UK, the method is no longer widely used in that country (for wind farms or other industrial sources). To support this, research commissioned by the UK Department of Environmental and Climate Change (DECC) reported2 that of the 46 wind farm noise assessments reviewed, 93% adopted the ISO 9613-2 prediction method, with the remainder adopting a simplified prediction method; no assessments utilised the CONCAWE calculation method More recent calculation standards such as the Nord 2000 method enables calculations under a wider range of conditions, but the method is not in widespread use in Australia. The method has also been shown to be most reliable when considering downwind propagation, as per the conditions considered with ISO 9613-2. In terms of the noise expected to occur under alternative conditions which reduce the noise, the following points are noted from the range of publications referred to in Section 4.4.1 of the MDA report: Due to the increased wind speeds in which the wind turbines operate, downwind noise propagation can occur over a range of wind directions approaching cross-wind conditions. Under cross-wind conditions (wind in the direction perpendicular to the line between a turbine and a receiver), noise levels will be marginally lower, but the reduction in noise level (relative to the predicted noise level) may be as little as 2-3dB depending on wind speed Under upwind conditions (wind directed from a receiver to a turbine), noise levels may be as much as 10-15dB lower than predicted. Noise levels under these conditions are however highly variable as a result of the effects of atmospheric turbulence, and the resultant scattering of the propagating sound wave. Refer to In relation to temperature inversions, Section 4.4.1 of the MDA report states: it is noted that at the wind speeds relevant to noise emissions from wind turbines, atmospheric conditions do not favour the development of thermal inversions throughout the propagation path from the source to the receiver. Inversions are not considered to be a significant factor influencing the propagation of noise from wind turbines. Atmospheric conditions which enhance the propagation of sound from a wind farm are primarily related to varying sound speed profiles associated with wind direction and wind speed. Regions of reduced air movement in sheltered locations may experience thermal inversions whilst the turbines are operating, however this type of localised inversion is not representative of the overall noise propagation path, and will not refract sound that propagates upwards of the turbines. These types of conditions are also likely to only occur during low wind speed conditions when the turbines rotate slowly. In relation to the “van den Berg” effect, the primary consideration with respect to predicted noise levels is the use of hub-height referenced wind speed data to account for the effects
2 Hayes McKenzie Partnership Ltd Analysis of How Noise Impacts are Considered in the Determination of Wind Farm Planning Applications, April 2011
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of site specific wind shear. The executive summary and Section 3.2 of the MDA report (among other sections) confirm the use of hub-height reference wind speeds throughout the Collector Wind Farm noise assessment. Further, Appendix E of the MDA report provides a detailed discussion of wind shear and the use of hub-height reference wind speeds. 4.2.2 Candidate turbines The AG report suggests a discrepancy between the MDA report and the Environmental Assessment, stating that the Environmental Assessment refers to other turbine types. In contrast, the Environmental Assessment does in fact refer to the same turbines as those considered in the MDA report. The Environmental Assessment simply refers to additional types of turbines which also fall within the class of turbine which could be considered for the site. The MDA report was prepared on the basis of a noise assessment of three (3) candidate turbine types; the Suzlon S88-2.1MW V3, the REPower 3.4M 104 and the Siemens SWT-2.3-101. It is important to recognise that at this phase in the project, the purpose of the noise study is to demonstrate that the proposed development could be viably constructed with a range of commercially available products. The normal method of demonstrating the viability of the site is to predict the noise levels for one or several turbine types that are indicative of the range of the assessment. The purpose of the assessment is not to consider every possible turbine on the market, nor is this a practical objective. The candidate turbines considered in the MDA report are representative of the normal range of emission levels achieved by commercial scale variable speed and variable pitch wind turbines. The assessment therefore demonstrates that the proposed wind farm layout can be viably constructed with commercially available turbine options for the site. 4.2.3 Low frequency predictions The AG report cites material from draft NSW Guideline submission of the turbine manufacturers Vestas. The AG report refers to the Vestas statement concerning the limitations of available methods for the prediction of low frequency sound. The relevance of the Vestas submission is however unclear in light of these matters having been specifically acknowledged and addressed in sections 4.4.1 and 4.4.4 of the MDA report. In recognition of these factors, which are specifically discussed in quantitative and qualitative terms in section 4.4.4 of the MDA report, the assessment has demonstrated that wind turbine noise levels are likely to be below the lowest threshold value of 60dBC of the draft NSW Guideline. Further noise assessment work since the original MDA report has also given consideration to the low frequency noise prediction method contained in the Danish Statutory Order on Noise from Wind Turbines dated 15 December 2011. The Danish Statutory Order provides a prediction method to deal with frequencies below 63Hz, as required to calculate C-weighted noise levels in accordance with the draft NSW Guideline. Inspection of the Danish method indicates similar effects as accounted for in the ISO 9613-2 predictions presented in section 4.4.4 of the MDA report. Specifically, the method accounts for the effect of increased ground reflections for low frequencies. As a result, the calculated C-weighted noise levels are similar to those produced using the ISO 9613-2 method, and therefore also support that
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noise levels associated with the Collector Wind Farm are expected to be below the lowest 60dBC threshold of the draft NSW Guidelines. 4.3 Seasonal effects Seasonal effects may be considered in two ways; effects on propagation of noise from the proposed wind farm, and effects on the background noise in the area. In relation to propagation of noise from the wind farm, the MDA report section 4.4.1 describes the prediction method that has been used to determine typical upper noise levels associated with worst case atmospheric conditions. Noise levels associated with operation of the wind farm in other wind speeds and directions will be lower than predicted, increasing the margin of compliance with applicable 2003 SA Guideline minimum limit. Section 4.2.1 above provides further discussion of this issue. In relation to background noise levels, seasonal variations may relate to a range of factors including flora, fauna, rainfall and atmospheric conditions (separate from propagation conditions noted above). Seasonal trends were evident in some of the background noise data sets, as discussed in Appendix H of the MDA report, and referenced again in Section 4.1 above. Specifically, some of the background noise trends exhibited relatively high levels which are suspected to have been related to seasonal fauna effects (e.g. insects or frogs). In recognition of seasonal variations, and the likelihood of lower noise levels during other seasons, a cautious assessment has been made by assuming background noise levels to be below 30dB at all times, thus requiring the assessment to consider a minimum applicable noise limit of 35dB. In practice, seasonal variations are a real feature of the ambient noise environment; actual noise levels in practice will be higher than 30dB during some periods. Based on the above, and contrary to the assertion of the AG report, seasonal factors have therefore been considered in the MDA report. 4.4 Tonality & Amplitude Modulation The AG report notes that the MDA report does not include for the potential effects of tonality or amplitude modulation in the predicted noise levels. To confirm, audible tonality at receiver locations is not a normal feature of a correctly functioning wind farm. Accordingly, it is not normal practice to include tonality penalties into the noise predictions. Section 2.1 of the MDA report provides further discussion on this matter. Section 4.6 of this response document also provides further comments in relation to tonality identified at the Hallett Wind Farm in South Australia. In relation to amplitude modulation, the effect has been noted to be an occasional feature of wind farm noise at some sites. The precise causes of this type of effect are not well established, but are suspected to relate to a combination of factors including atmospheric stability, wind shear and narrow-band propagation effects. Whilst there is no available mechanism to predict if and when this effect may occur, the available information indicates a low likelihood of occurrence, based on the effect only occurring for a limited time at a limited number of sites. It is expected that a detailed research project on this subject in the UK may yield further insights, but to our knowledge, the results of this study are yet to be publicly released. Given the low likelihood of this type of effect, it is more appropriate to manage this type of effect through appropriate consent conditions than to assume an associated penalty in the predicted noise level.
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The above approaches are consistent with current practice in Australia. In the absence of Australian policy research on this type of matter, it is informative to refer to the UK DECC research that noted in all of the 46 wind farm noise assessments reviewed, penalties were not applied to the predictions for either tonality or amplitude modulation. This approach is also advocated in the UK Institute of Acoustics Discussion Document on “A Good Practice Guide to the Application of ETSU-R-97 for Wind Turbine Noise Assessment” for similar reasons to those cited above. 4.5 Low frequency noise The AG report provides repeated references to the suggestion of low frequency noise and infrasound associated with wind turbines. This matter is extensively referenced in section 4.5 of the MDA report, including details of research and government publications concerning the subject. Section 4.4.4 of the MDA report also provided predicted C-weighted noise levels for comparison with the proposed thresholds detailed in the draft NSW Guidelines. The AG report cites a range of authors in relation to alleged low frequency and infrasound. In particular, the AG report quotes text from Dr Geoff Leventhall, a prominent UK consultant in the field of acoustics and vibration. Whilst the use of the Dr Leventhall’s text in the AG report is unclear, the information appears to have been presented with the view to promoting the issue of low frequency noise and infrasound. However, as per the information provided in section 4.5 of the MDA report concerning misrepresentations, Dr Geoff Leventhall has provided the following statement with respect to wind turbine noise: "I can state quite categorically that there is no significant infrasound from current designs of wind turbines. To say that there is an infrasound problem is one of the hares which objectors to wind farms like to run. There will not be any effects from infrasound from the turbines. The turbines produce a modulated higher frequency - the swish, swish - which people may not like, but this is not infrasound. There is no low frequency in it. There is negligible infrasound and very little low frequency noise from wind turbines - a few low level tones from the gearbox. Whatever might be making people ill it is not low frequency noise - there just isn't enough of it from modern wind turbines." 4.6 Other wind farm sites The AG report makes reference to a number of other operational wind farms. Of the cited wind farms for which MDA has background information, we provide the following background information. Hallet Wind Farm, South Australia: advice from the South Australian EPA indicates that complaints from this site occurred as a result of a turbine defect which gave rise to tonal noise emissions. The defect was sufficient to represent non-compliance, and the South Australian EPA advised that the operators voluntarily reduced operation of the site whilst the defect was repaired. Mitigation measures are understood to have been installed, comprising dampers to mitigate tonal noise. We understand from the South Australian EPA that the mitigation measures have been successful, and the site is now operating within the required limits. Waterloo Wind Farm, South Australia: advice from the South Australian EPA indicates that the site is compliant with the noise limits applicable to the site.
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Te Rere Hau Wind Farm, New Zealand: the AG report indicates this site to be relevant to the MDA report for Collector Wind Farm, and cites extracts from the court decision concerning the Te Rere Hau wind farm referring to incorrect predictions and assessments. The relevance of this site is unclear. The noise prediction and assessment work referred to in the court decision was not carried out by Marshall Day Acoustics. Marshall Day Acoustics has since been engaged to assist the project operators to resolve issues relating to the errors in the environmental noise assessment prepared by their former consultant.
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5.0 CONCLUSIONS The Acoustic Group’s report (the AG report) on the Collector Wind Farm noise impact assessment has been reviewed. The following observations are noted from the review: The AG report is primarily concerned with operational noise from wind turbines The AG report presents a range of views and opinions on wind farm noise assessment which are predominantly not specific to the Collector Wind Farm noise assessment. Instead, the AG report extensively critiques the types of policies which have been used to manage wind farm development in Australia and abroad. As an indication of the scale of general noise problems suggested within the AG report, the AG report infers problematic noise at distances of 8km from a modern operational wind farm. Specific to the Collector Wind Farm noise impact assessment, the AG report suggests that a range of matters have not been addressed. This report confirms that all relevant matters have been addressed in the MDA report submitted with the Environmental Assessment. For ease of reference, this response document directs readers to the relevant sections of the MDA report which provide the required information. In addition, further references and contextual information has been provided in this response to support the material already presented in the MDA report. The conclusions of the MDA report are not altered or affected by any of the suggestions detailed in the AG report. Specifically, the noise impact assessment has addressed the requirements of the DGR, and demonstrated that the Collector Wind Farm can viably operate within strict limit values detailed in the 2003 SA Guideline. The noise assessment has also demonstrated that the wind farm could viably operate within thresholds indicated in the draft NSW Guideline. This assessment has been made carried out using conventional assessment practices and cautious assessment choices specific to wind farm developments.
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6 Gipps Street Collingwood 3066 Victoria Australia T: +613 9416 1855 F: +613 9416 1231 A.C.N. 006 675 403 21 December 2012 www.marshallday.com
APP PO Box 1573 North Sydney NSW 2059
Attention: Clair Baxter
Dear Clair
COLLECTOR WIND FARM LAYOUT REFINEMENTS The proposed Collector Wind Farm turbine and substation layout has been refined following submission of the Environmental Assessment for the project. This letter presents updated operational noise predictions for the refined scheme layout. Supplementary information is also provided for predicted low-frequency noise levels, based on a review of a statutory publication in Denmark which provides guidance for the prediction of low frequency noise levels. The scheme refinements are not significant with respect to the outcomes of the construction noise and vibration assessment. The assessment presented in the Environmental Assessment therefore remains valid for the refined scheme layout, and no further information is presented here in relation to construction noise and vibration.
LAYOUT REFINEMENTS The proposed turbine layout for the Collector Wind Farm has been reduced from a total of sixty-eight (68) turbines down to sixty-three (63) turbines. Table 1 lists the turbines that have been removed. Table 1: Wind turbines removed from proposed layout (coordinates MGA94 Zone 55)
Turbine Easting Northing
CWF 65 720847 6140638
CWF 66 721081 6140856
CWF 67 721100 6141132
CWF 68 721245 6141392
CWF 69 720925 6141697
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In addition to the wind turbines removed from the layout, the locations of the substation and six (6) other wind turbines have been refined. The amendments are summarised in Table 2. Table 2: Substation and wind turbine location amendments (coordinates MGA94 Zone 55)
Turbine Original location Modified location Change Easting Northing Easting Northing Substation 718670 6143599 718613 6143822 230m
CWF 55 718042 6135504 718101 6135495 60m
CWF 56 717976 6135216 718053 6135202 78m
CWF 57 717905 6134890 718001 6134880 97m
CWF 58 717877 6134568 717949 6134560 72m
CWF 59 717815 6134260 717899 6134253 84m
CWF 60 717758 6133946 717851 6133958 94m
PREDICTED A-WEIGHTED NOISE LEVELS Operational noise levels associated with the refined layout have been predicted using the same sound power level data, terrain details, and prediction method documented in the Environmental Assessment. Full details are provided in the Marshall Day Acoustics (MDA) report accompanying the Environmental Assessment (see MDA document reference Rp 002 R07 2010127SY dated 4 June 2012 – the original MDA report). The following provides a brief summary. Table 3: Summary of prediction data
Item Description
Turbine types Suzlon S88-2.1MW – maximum sound power 104.7 dB LWA
Repower 3.4M 104 – maximum sound power 105.0 dB LWA
Siemens SWT-2.3-101 – maximum sound power 107.0 dB LWA Turbine hub-heights 79-80m Prediction method ISO 9613-2: 1996 Acoustics – Attenuation of sound during propagation outdoors Part 2: General method of calculation Prediction input x Ground conditions – mixed ground characterised by a ground factor of G = 0.5 parameters x Temperature – 10 degrees Celsius x Relative humidity – 70% x Source heights – 80m x Receiver heights - 1.5m AGL x Terrain screening restricted to 2dB
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The results of the updated noise predictions are presented in Table 4 along with predicted noise contours for each of the three (3) turbine types in Appendix A. The results demonstrate compliance with the minimum noise limits applicable to the Collector Wind Farm at all locations. The original MDA report indicated that reduced turbine layouts were required for the candidate REpower and Siemens turbines. The updated noise predictions for the currently proposed sixty-three (63) turbine layout demonstrates compliance with all three turbine types. The exception to this, as per the original assessment, is stakeholder property N. Relevant considerations for this location are detailed in section 4.4.3 of the original MDA report. These considerations include the likelihood that the predictions overestimate the noise at this location, and the existence of a land holder agreement between the proponent and the property owner to waive layout reductions in favour of alternative remedies.
Table 4: Maximum A-weighted predicted receiver noise levels LAeq dB
House 63 x Suzlon 63x REpower 63 x Siemens Minimum Noise S88-2.1MW 3.4M 104 SWT-2.3-101 Limit A 15 15 16 35 AA 31 31 32 35 B 15 15 15 35 BB 27 27 29 35 C 19 19 19 35 CC 25 25 26 35 D 20 20 21 35 DD 28 28 29 35 E 21 21 22 35 EE 24 24 25 35 F 25 25 26 35 FF 33 33 35 35 G 33 34 35 45* GG 27 27 28 35 H 29 29 30 35 HH 29 29 30 35 I 26 26 27 35 J 30 31 32 35 K 30 31 32 35 L 29 30 31 35 M 35 35 36 45*
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House 63 x Suzlon 63x REpower 63 x Siemens Minimum Noise S88-2.1MW 3.4M 104 SWT-2.3-101 Limit N 46 47 49 45* O 30 30 31 35 P 24 24 25 35 Q 27 27 28 35 R 28 28 29 35 S 37 38 39 45* T 38 38 40 45* U 22 22 23 35 V 30 30 31 35 W 27 27 28 35 X 26 27 27 35 Y 27 27 28 35 Z 33 34 35 35 * Involved receiver
PREDICTED C-WEIGHTED NOISE LEVELS The original MDA report provided indicative C-weighted noise levels as referenced in the draft NSW Planning Guidelines: Wind Farms (the draft NSW guidelines) published in December 2011. These predictions were provided for non-involved receiver locations where a wind turbine was proposed to be located within 2km. Section 4.4.1 of the original MDA report presented details of the noise prediction methodology and the associated limitations with respect to the calculation of C-weighted noise levels. Specifically, the ISO 9613 methodology is appropriate for predicting A-weighted noise levels based on octave band data between 63-8kHz. A discussion of the uncertainties associated with the use of the ISO 9613 method for frequencies below 63Hz was provided in the report. In the time since the C-weighted calculations were produced, a review of the Danish Statutory Order No. 1284, dated 15 December 2011 (DSO 1284), has been carried out. This document introduces low frequency noise requirements applicable to wind farms in Denmark, but also provides a methodology for predicting low frequency noise between 10-160Hz. The overall form of the methodology is comparable to ISO 9613, but suggests slightly higher fixed value ground reflection enhancements for frequencies below 160Hz. In recognition of the guidance contained in DSO 1284, the updated C-weighted predictions have been developed on the basis of the ISO 9613 calculations, adjusted for the increased influence of ground reflections suggested by the DSO 1284 method below 160Hz. The fixed ground attenuation values from DSO 1284 are presented in Table 5. Note that the positive values indicated in this table indicate an effect which increases the predicted noise levels as a result of the enhancement associated with ground reflections.
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Table 5: Octave band ground attenuation, dB
Octave Band Centre Frequency (Hz) Attenuation term 16 31.5 63 125 Ground attenuation 6 5.9 5.7 4.7
Based on the approach detailed above, and the currently proposed site layout, the updated C-weighted noise level predictions are provided in Table 6 for each of the three (3) receivers referenced in the original MDA report. Note that of these three locations, only one position remains within 2km of a proposed turbine location. The predictions at locations BB and FF are therefore provided for reference purposes only for consistency with the original MDA report.
Table 6: Maximum C-weighted predicted receiver noise levels LCeq dB
House Distance to nearest Suzlon REpower Siemens turbine S88-2.1MW 3.4M 104 SWT-2.3-101 Z 1775m 48 57 51 BB 2996m 44 53 47 FF 2132m 48 57 51
The predicted noise levels presented in Table 6 are below the 65dB and 60dB LCeq day and night respective levels nominated in the Draft NSW Guidelines as thresholds which could prompt a requirement for further detailed low frequency noise assessments. The prediction of low frequency noise levels are however subject to increased margins of uncertainty. This uncertainty relates to the use of sound power level data below the normal frequency range reported by turbine manufacturers, combined with the uncertainty associated with the available prediction methods. Specifically, quoted uncertainty values for the total C- weighted noise emissions of the turbines are not provided in the available manufacturers’ literature. However, data provided by other turbine manufacturers indicates uncertainty values ranging from +/-1dB up to approximately +/-6dB at frequencies below 63Hz. These uncertainty values are considered typical of the range likely to apply for other similar size turbines, depending on the specific circumstances in which the sound power test is carried out Based on the above considerations, the C-weighted noise levels can only be regarded as indicative predictions. The uncertainty associated with the C-weighted predicted noise levels is expected to be similar to, or greater than, than the uncertainty associated with the low-frequency sound power of the turbines. Accounting for these uncertainties, and the margins between the predicted noise levels and the Draft NSW Guidelines’ thresholds, the predictions indicate that wind turbine noise levels are likely to be below the lowest threshold value of 60dB LCeq at the three (3) receivers referred to in Table 6.
121221 Lt 001 2012127SY Collector Wind Farm Layout Refinements Page 5
CUMULATIVE NOISE LEVEL ASSESSMENT Section 4.6 of the original MDA report presented an assessment of the potential cumulative effect of adjacent wind farms. The cumulative impact assessment considered the effect of noise from Collector Wind Farm to receivers near the existing Cullerin Wind Farm. Conversely, the assessment also considered the effect of noise from Cullerin Wind Farm to receivers near the proposed Collector Wind Farm. The cumulative noise level predictions have been updated to reflect the proposed Collector Wind Farm layout revisions. The predicted noise levels are equivalent to or less than those originally presented for the key receptor locations relevant to cumulative noise considerations. Updated cumulative noise contour predictions for each of the three (3) candidate turbine types for the Collector Wind Farm are presented in Appendix B.
SUMMARY The predicted operational noise levels have been updated to reflect the proposed Collector Wind Farm layout refinements. The updated predictions account for: x A-weighted noise levels associated with the proposed Collector Wind Farm x C-weighted noise levels associated with the proposed Collector Wind Farm, including an updated prediction methodology sourced from a policy applied to wind farms in Denmark x Cumulative noise levels associated with the proposed Collector Wind Farm and the existing Cullerin Wind Farm The results have demonstrated compliance with the noise criteria applicable to the development. In particular, compliance has been demonstrated for the proposed sixty-three (63) turbine layout and the three (3) candidate turbine types considered in the noise assessment. Based on the above, the findings of the original MDA report submitted with the Environmental Assessment remain applicable to the currently proposed layout refinements. The exception to this is the reference to layout reductions noted in the in the original MDA report which are no longer applicable to the currently proposed scheme.
We trust the above information is satisfactory for your immediate purposes. Please contact us if you have any questions or require clarification. Yours faithfully MARSHALL DAY ACOUSTICS PTY LTD
Justin Adcock Associate
121221 Lt 001 2012127SY Collector Wind Farm Layout Refinements Page 6
APPENDIX A UPDATED PREDICTED OPERATIONAL WIND FARM NOISE CONTOURS
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CC kV 330 330kV 44 50 R 38 35 41 44 GG 53 BB Q N 50 h Sout C d o FF l l aR e d c ri t e o L r R T d P S Z Y AA M K 59 HH 44 47 56 41 38 35 X L O W KEY V J 50 Collector Involved Residence G Non-involved Residence Wind turbine site H Electricity transmission line I \ Existing road d Z R + e Noise contours dB(A) Tre O ed D rk U Substation and Control Compound a H
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) Collector Township F Project Site 0 0.5 1 1.5 km F:\GIS\APP\Collector Windfarm\December 2012\Suzlon Power 63 substation.mxd 63 Power 2012\Suzlon Windfarm\December F:\GIS\APP\Collector
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CC 330k 330k R 3 1 3 GG 0 BB N 0 h Sout C d o FF l l aR e d c ri t e o r 0 R T d P S Y AA K 6 0 6 3 1 3 W KEY Collector Involved Residence G Non-involved Residence Wind turbine site Electricity transmission line I \ Existing road d Z R + e Noise contours dB(A) Tre O ed D rk U Substation and Control Compound a H
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CC 330kV 330kV 8 47 *# *# *# *# R *# 8 8 *# *# 38 *# *# 41 35 44 GG *# *# 50 *# BB 8 *# *# 8 *# *# Q 8 *# *# *# 8 *# N *# *# × *# *# *# 50 *# *# *# *# 8 C *# o *# FF l Rd South l *# e *# c rida 8 t o Le *# r
R T *# *# d P × *# *# 8 S *# × *# Z *# Y 8 *# AA 8 M *# 8 K 8 × *# 8 *# *# *# *# *# 59 *# *# # HH 47 56 * # 44 *# * 8 8 41 38 *# X 35 *# 8 L 8 *# *# *# O 8 *# W *# 8 8 KEY *# 8 8 8 V *# × Involved Residence 50 J 8 8 Collector 8 Non-involved Residence G 8 *# Wind turbine site ×
Electricity transmission line H Existing road 8 I y d 8 w Noise contours dB(A) R H e Tre l Substation and Control Compound ed a rk r Construction Compound a e M d Collector Township e F Project Site F 8 0 0.5 1 1.5 km 8 F:\GIS\APP\Collector Windfarm\December 2012\Siemens Power 63 substation.mxd Power 63 Windfarm\December 2012\Siemens F:\GIS\APP\Collector 8
Siemens Power 63 Substation
APPENDIX B UPDATED PREDICTED CUMULATIVE OPERATIONAL WIND FARM NOISE CONTOURS
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CC 330k 330k R 3 3 1 GG 3 BB N 0 h Sout C d o FF l l aR e d c ri t e o r R T d P S Y AA K 6 1 3 3 W KEY Involved Residence 0 Collector Non-involved Residence G Wind turbine site Cullerin Range Wind Turbine Electricity transmission line I \ Existing road d Z R + e Noise contours dB(A) Tre O ed D rk U Substation and Control Compound a H
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) Collector Township F Project Site 0 0. 1 1. km F:\GIS\APP\Collector Windfarm\December 2012\Suzlon Power 63 substation and cullerin.mxd and substation 63 Power 2012\Suzlon Windfarm\December F:\GIS\APP\Collector
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CC 330k 330k R 3 1 3 GG 0 BB N 0 h Sout C d o FF l l aR e d c ri t e o r 0 R T d P S Y AA K 6 0 0 6 3 1 3 W KEY Involved Residence Collector Non-involved Residence G Wind turbine site Cullerin Range Wind Turbine Electricity transmission line I \ Existing road d Z R + e Noise contours dB(A) Tre O ed D rk U Substation and Control Compound a H
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) Collector Township F Project Site 0 0. 1 1. km F:\GIS\APP\Collector Windfarm\December 2012\RE Power 63 substation and cullerin.mxd and substation 63 Power 2012\RE Windfarm\December F:\GIS\APP\Collector
RE Power 63 Substation and Cullerin N
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CC 330k 330k R 3 1 3 GG 0 BB N 0 h Sout C d o FF l l aR e d c ri t e o r R T d P S Y AA K 6 1 3 3 W KEY Involved Residence Non-involved Residence 0 Collector Wind turbine site G Cullerin Range Wind Turbine
Electricity transmission line Existing road I \ d Z Noise contours dB(A) R + e Tre O Substation and Control Compound ed D rk U Construction Compound a H G Collector Township H ) Project Site F 0 0. 1 1. km F:\GIS\APP\Collector Windfarm\December 2012\Siemens Power 63 substation and cullerin.mxd and substation 63 Power 2012\Siemens Windfarm\December F:\GIS\APP\Collector
Siemens Power 63 Substation and Cullerin
APPENDIX E. Ecological Impact Assessment
Issue Response Further action proposed Development Footprint and Turbine Layout The Office of Environment and Heritage (OEH) applies the hierarchical As stated in the Executive Summary of the BA: We could supply the PEI principles of avoid, mitigate and, as a last resort, offset to be considered During the process of the biodiversity assessment, the design of the which shows the original in the assessment of all 3A proposals. The proponent has not proposal has been refined taking into account biodiversity constraints. development envelope demonstrated that the first principle of avoidance has been applied to The proposal now has: in terms of constraints, the locations of turbines across the landscape. OEH considers that but this is essentially A reduced number of turbines (initially up to 80 turbines were avoidance of Endangered Ecological Communities (EECs) is not evident superseded by the BA, being considered; the final layout comprises 68 turbines). in the proposal. which has more survey A reduced number of turbines in sensitive areas (four fewer effort and investigation turbines in forest to avoid threatened species habitat, four to back it up and could fewer turbines in woodland, three fewer turbines in EEC). confuse the issue. No turbines proposed along Lake George escarpment, removed to avoid raptor habitat. We could provide a new constraint map set Minimised the removal of hollow-bearing trees through specifically aimed at micrositing turbines and associated layout features away addressing this issue. from paddock trees and outside of forest as much as possible. This provides evidence that avoidance (including areas of EEC) has clearly been demonstrated by the proposal. The area of impact of the proposal on EECs is referred to numerous Iterative design changes has resulted in numerous updates to the Final EEC total loss times in the text and various tables in the EA, Biodiversity Assessment proposed layout and subsequent variations in the area of the figures to be confirmed (BA) and Offset Strategy. The figures vary and it is unclear exactly how development footprint. As such, some discrepancies have occurred in in the Offset Strategy. much of each will be impacted. OEH requires a single figure for how the consistency of the final figures across documents. Recommend that the EA much of each EEC in all conditions will be impacted by the proposal, be updated to be both permanently and temporarily. consistent with the Offset Strategy. Temporary and Permanent Loss OEH does not support the separation of the impacts on Box-Gum It is recognised that there are inherent difficulties in reinstating None Woodland (BGW) EEC into categories of temporary or permanent loss. woodland vegetation however, the definition of the BGW EEC also OEH considers that there are considerable difficulties in reinstating includes grassland derived from the clearing of this community. It is BGW EEC; although some rehabilitation of disturbed patches is likely to considered reasonable that grassland vegetation may be successfully constitute a reinstatement of habitat. OEH therefore requires that re-established in areas of temporary impact such as crane hardstands impacts and subsequent offsets be simply calculated as permanent loss. and cable trenches. The differences between re-establishing woodland vs. grassland vegetation were discussed with OEH at the onsite meeting held on the 27 July 2011 and it was decided that areas temporarily impacted during the construction phase in woodland would be considered permanent (given the inherent difficulties in re-establishing woodland vegetation) however, that those within grassland could reasonably be expected to be rehabilitated and that they were to be considered temporary. This is supported in the letter dated 5 August 2011, detailing OEH’s comments and observations at the meeting, in which it states: OEH believes the EA and biodiversity assessment must include all areas of native vegetation with an overstorey component that require clearing, as a long term impact, rather than the current, “temporary” impact. These areas will also require offsetting (as they are currently not proposed to be offset). These areas (including BGW with an overstorey component) were subsequently included within the area to be permanently impacted and in the offset calculations. There was no requirement by OEH to include areas without an overstorey component. In order to meet the “maintain or improve” principle of offsetting, high High conservation value BGW would be “red flagged” by the PVP Recommend considering conservation value BGW should not be cleared and low conservation Developer and Biobanking Credit Calculators however, the BA is not increasing the offset value BGW should be offset at approximately a 10:1 ratio. employing these methodologies. An offset has been proposed which ratio. Demonstrating a addresses the requirement to meet a “maintain or improve” outcome maintain or improve for areas of high conservation BGW and is consistent with ratios outcome is difficult nghenvironmental has achieved using the ratios in similar vegetation outside the two types1. endorsed methods. In relation to offsetting low conservation value BGW, previous correspondence received from OEH (email from Julian Thompson, 9 June 2011) states: Offsets – NGH indicates it is developing an offset strategy. OEH has indicated a preference for using bio-metric methodology to calculate appropriate offsets however, NGH proposes a “maintain or improve biodiversity” standard. Both options are open to be followed in a Part 3A
1 nghenvironmental have employed biobanking assessment methodology in BGW at Bungendore and Queanbeyan where ratios of around 1: 5 - 1:6 were consistently returned. process. Either way, OEH insists that offsets must be secured in perpetuity, as impacts are likely to be in perpetuity. The information provided by NGH is that adequate offset lands for EEC’s should be available on-site. NGH commented that OEH advice on a 10:1 offset ratio is inconsistent and implied that EEC in low condition requires a much lower offset. This is not consistent with the bio-metric methodology where low condition EEC offsets around the 10:1 ratio are common (but are site specific of course). 10:1 offset ratio is a guide only. The offset ratio proposed in the current Offset Strategy (5:1) is considered to be suitable given the condition of the site and the ability to achieve a ‘like for better’ offset in terms of vegetation type. That is, common vegetation that will be cleared will offset by EEC vegetation, achieving a higher overall offset ratio for EEC that will be cleared. We note that past assessments by nghenvironmental utilising the BioBanking methodology in similar vegetation types have resulted in ratios of around 6:1. OEH is unsure why turbines are located in high quality areas of EEC and considers this does not meet the principles of avoid, mitigate, offset, as per the threatened species guidelines. Accordingly OEH considers the following turbines should be either removed or relocated to reduce the impact on the EECs and the threatened species known to occur within these communities Turbines located within cluster 4 in the north eastern part of The value of this area is acknowledged. The removal of turbines the development footprint occur in intact, moderate to good from this area is being quality BGW, where the following threatened species were considered recorded: Eastern Bentwing-bat, East Coast Freetail Bat, Yellow-bellied Sheath-tail Bat and the Brown Treecreeper. This cluster of turbines may impact on the Eastern Bentwing-bat’s migratory path from the Mt Fairy staging cave to the Wee Jasper maternity cave as this species is more likely to travel through vegetated landscapes. Turbines located in cluster 6 appear to be located within a The value of this area is acknowledged. The removal of turbines large area of high quality BGW as it is mapped as being of from this area is being EPBC Act quality, this cluster also provides habitat for the considered Diamond Firetail. Turbines in the southern section of cluster 5 should be The value of this area is acknowledged. The removal of turbines relocated to the exotic pasture adjacent to avoid the area of from this area is being Tablelands Snow Gum EEC. considered Offsetting The BioBanking methodology is the NSW Government’s recognised The use of the BioBanking methodology was not stipulated by the None methodology for calculating and securing offsets. OEH believes the DGR’s for the proposal. Further, OEH have acknowledged and offset strategy must clearly propose a suitable biodiversity offset to be supported a range of options to secure the offset site in perpetuity as set aside for conservation in perpetuity in accordance with that stated in the letter dated 5 August 2011, detailing OEH’s comments mechanism. It must be clearly stated the offset area will be managed in and observations at the on site meeting: perpetuity with allocated funds for management. OEH as a matter of policy requires the offset package to be fixed to the land in perpetuity (eg. Biobanking, Dedication of the land to the public reserve system, Conservation Agreements, Trust Agreement with the Nature Conservation Trust, Planning Agreement and conservation Property Vegetation Plans). Page 14 of the Offset Strategy clearly states that the offset will be secured in perpetuity with funding provided by the wind farm operator for management: It is proposed that the wind farm operator be responsible for the management of the offset site, during the operation of the wind farm. The operator is likely to finance the owner of the site to undertake management actions (such as fencing and weed control) and retain responsibility for the site. This provides surety that the actions will be undertaken, as the requirement to offset is a condition of the wind farm operator’s consent. At the decommissioning stage, the ongoing management would be the responsibility of the landowner. It is expected that by this time the majority of the required management actions would have been undertaken and ongoing management tasks will largely coincide with routine agricultural activities. A formal vehicle will be required to manage the offset site in perpetuity. A Property Vegetation Plan is the likely vehicle. The agreement will specify management recommendations and restrictions on land use, in accordance with the finalised offset plan for the site. OEH has concerns that the EA does not quantify the BGW condition in While there is no requirement to classify condition according to these None accordance with the existing government endorsed tools (PVP two tools, Page 12 and 13 of the Biodiversity Assessment clearly Developer and BioBanking Credit Calculator). define how vegetation condition is defined within the assessment. It states that: All of the above (vegetation) classes excluding the ‘exotic’ class would equate to the ‘moderate to good’ definition specified within the biometric guidelines due to the dominance of native vegetation in the groundlayer or having a native overstorey with a percent foliage cover greater than 25% of the lower value of the over-storey percent foliage cover benchmark of that vegetation type. The exotic class would equate to ‘low’ condition vegetation. The site is constrained by high conservation values which have been The BA acknowledges that areas of moderate to good condition BGW None identified in Appendix B of the EA. OEH recommends that the project and FHGW would be red-flagged under the OEH Biometric guidelines avoids these areas as they are important in fragmented landscapes. The however, the assessment is not following this assessment pathway. EA makes reference to BGW and FHGW in Figures 3-5 to 3-8 as being in The information has been included to acknowledge the conservation moderate to good condition (i.e. red-flagged), but this is not supported value of these areas only. The position taken on vegetation condition in the Biometric Status (chapter 3.5, page 38). The EA needs to clarify (and how this relates to the Biometric condition) is clearly stated in the position taken on vegetation condition, as this has major impacts chapter 2.4.2, page 12-13 of the BA. upon the offsets required. OEH recognises that micrositing of turbines has avoided some It is acknowledged in the BA that the regional area is highly disturbed None vegetation, however this EEC woodland is important at a regional scale and fragmented – particularly, clearing for agriculture has for habitat connectivity and therefore has a high regional conservation preferentially reduced the BGW community. value. The regional are is a highly disturbed and fragmented landscape. It should also be noted however, that the infrastructure footprint of this wind farm is small in comparison to the spread of infrastructure. That is, the infrastructure footprint will represent a small and disparate proportion of the area within the site boundaries, being comprised of narrow access tracks, electricity easements and discrete turbine footings and hardstand areas. In contrast to other large scale infrastructure developments, this provides the opportunity to minimise impacts by micrositing infrastructure around better quality areas and those required to maintain landscape connectivity. Dispersal of flora and fauna is not anticipated to be greatly impacted specifically because of this pattern of impact – barriers to dispersal are not created for flora or highly mobile fauna. Control plans (to rehabilitate and disturbed areas and control weeds) are a component of the proposal and will ensure that the potential to degrade adjacent areas (due to the large edge effect of the pattern of impact) is addressed. At a regional scale, the protection in perpetuity of this community will enhance landscape connectivity. Hollow-bearing Trees (HBTs) An accurate calculation of numbers of HBTs in the offset site is required, It is acknowledged within the offset strategy that the HBT count at the None as the extrapolation provided in the EA significantly over estimates the offset site is likely to be an over estimate given that the worst case number of HBTs. The proponent must ensure that they are not including methodology utilised for the development site was used in the cleared areas in the estimate, and should refer to how vegetation calculation. However, even if this is an over estimate, the worst case density has been considered in the calculation. The EA should number of trees required at the offset site (460) constitutes only 7% demonstrate that the hollow size in the offset is representative of the of the estimated number to occur (7000) allowing for a large buffer disturbance footprint. (93%) around this figure. Given that the same methodology was used at the development and offset sites, that they are in close proximity to each other, and that the offset site contains woodland vegetation that is considered to be of high quality at a similar or higher density than that of the development site, it is considered likely that the offset site would contain well over the 460 trees required. Even if only the most densely vegetated areas (at densities which are uncommon at the development site) are included (91ha), this would equate to 3185 trees. Survey The BA states that a Sugar Glider was observed while spotlighting, The precise locations of common species were not recorded during None however no information is provided on the location of the sighting. A surveys. The recording of a Sugar Glider onsite was not considered map should be provided indicating where species were found. significant. Given the inherent difficulties in distinguishing Sugar Gliders from Highly experienced and qualified field ecologists undertook the spot None Squirrel Gliders by spotlight, OEH requires justification of species lighting survey. Staff were confident in the identification of the sugar identification. It would be useful for the proponent to undertake glider and It is considered unlikely that the species was misidentified. trapping in potential habitat to ascertain whether Squirrel Gliders are Where there is uncertainty regarding identification, such as with present. OEH recognises that some good quality habitat has previously several flora species, this is always stated. been avoided in the turbine layout however, further investigation of this As stated in the BA (chapter 4.2.3, page 44) habitat at the species is required before it can be established that the species does not development site is considered sub-optimal for the squirrel glider as it use the habitat in the development footprint. lacks the Acacia and shrub mid storey preferred by this species. Regardless, the higher quality areas have been avoided by the proposal and a trapping survey is not considered to be warranted.
19November2012
NickValentineNationalManagerͲEnvironment APPCorporationPtyLimited POBox1573NorthSydneyNSW2059 Phone:+61299639924 Fax:+61299541951Mobile:+61417219465
bega suite1,216carpst DearNick (pobox470) RE–CollectorWindFarmSubmissions2012(4864) begansw2550 t61264928333 Thank you for asking nghenvironmental to provide updated estimated impact areas, to bathurst reflectchangestotheCollectorWindFarmproposal.Thechangesentailtheremovaloffive pobox434 bathurstnsw2795 proposedturbinesfromCluster4.Thisalsoreducesthetotallengthofthenewaccesstracks t0488820748 required by approximately 5 kilometres. We used GIS software to revise our impact area sydney calculations. unit18,level3 21maryst Overall, permanent habitat loss is reduced from an estimated 24.62ha to approximately surryhillsnsw2010 20.48ha. The majority of this reduction is contained within BoxͲGum Woodland derived t61282028333 grasslandinlowcondition(2.13ha)andBoxͲGumWoodland(withtreecover)inmoderate waggawagga suite1,39fitzmauricest condition(1.64ha).Inaddition,theremovalofthemostnorthernturbinewithincluster4 (pobox5464) reducesthepermanentimpactwithinWhiteGumForestingoodconditionby0.25ha.The waggawaggansw2650 reduced impact provides positive outcomes for BoxͲGum Woodland EEC (listed under the t61269719696 TSCAct)byreducingthepermanentlossofthiscommunitybyapproximately3.8ha.HollowͲ f61269719693 canberra bearingtreesrequiringremovalwouldalsobereducedbasedontherevisedlayout. unit17/27yallournst Updatedtablesarepresentedoverleaf,whichyoucouldusewithintheSubmissionsReport (pobox62) fyshwickact2609 todemonstratethereductioninimpact.Pleasenote,theDevelopmentEnvelope(assessed t61262805053 areas in which infrastructure was assumed to have potential to occur) have not been f61262809387 altered,onlytheindicativeinfrastructurelayout.WehavealsopreviouslyprovidedanExcel dunsborough spreadsheetreflectingthechanges(emailtoClairBaxter12November2012). 37peronave (pobox1037) Ifyouhaveanyquestions,pleasecontactmeonthenumberbelow.Iwouldbepleasedto dunsboroughwa6281 t61897591985 discussthisprojectwithyoufurther.
[email protected] Yourssincerely, www.nghenvironmental.com.au
BrookeMarshall Manager,SouthCoast&SnowyMountains nghenvironmentalPtyLtd CertifiedEnvironmentalPractitioner(CEnvP) T(02)64928333D(02)64928303M0437700915F(02)64947773 ABN:31124444622ACN:124444622 nghenvironmentalisaregisteredtradingnameofNGHEnvironmentalPtyLtd;ACN:124444622.ABN:31124444622 Table1.Estimatedimpactareabyvegetationtype
Infrastructure Quantity Width(m) Length(m) Area(ha)1 BGW(ha)2 DGL(ha)2 BBDGF(ha)2 WGF(ha)2 FHW(ha)2 NP(ha)2 EX(ha)2 Turbinefooting a 63 25 25 3.94 0.63 2.19 0.00 0.06 0.25 0.06 0.75 Cranehardstand(inwoodlandandforest)a 15 15 32 0.72 0.48 0.00 0.00 0.05 0.19 0.00 0.00 Cranehardstand(inpastureareas)b 48 15 32 2.30 0.00 1.68 0.00 0.00 0.00 0.05 0.58 Additionalcraneoperationarea(woodlandand 15 37.35 37.35 2.09 1.40 0.00 0.00 0.14 0.56 0.00 0.00 forest)a 48 37.35 37.35 6.70 0.00 4.88 0.00 0.00 0.00 0.14 1.67 Additionalcraneoperationarea(pastureareas)b Tracks(bufferduringconstruction)b 12 29897 5.98 1.15 3.05 0.00 0.05 0.21 0.12 1.40 Tracks(permanentformedwidth)a 1 6 29897 17.94 3.43 9.17 0.00 0.18 0.62 0.35 4.21 Substationandcontrolbldga 1 50 150 0.75 0.00 0.75 0.00 0.00 0.00 0.00 0.00 Constructioncompound,stagingandstorageb 1 300 100 3.00 0.00 3.00 0.00 0.00 0.00 0.00 0.00
Developmentenvelope 898.49 BreakdownͲhabitatlossbyimpacttype(*excludes exoticvegetation): 20.48 5.93 12.11 0.00 0.43 1.62 0.41 * aPermanenthabitatloss(includesallfootings, hardstandsandoperationareasinwoodlandand forestandpermanentformedwidthofnewtracks) Percentageofhabitatwithinthedevelopment 2.28 0.66 1.35 0.00 0.05 0.18 0.05 * envelopepermanentlyimpacted bTemporaryhabitatloss(areasthatcanbe 14.33 1.15 12.61 0.00 0.05 0.21 0.31 * rehabilitatedpostconstruction) Percentageofhabitatwithinthedevelopment 1.59 0.13 1.40 0.00 0.01 0.02 0.03 * envelopetemporarilyimpacted
1Derivedfromestimatedinfrastructurefootprints 2DerivedfromGISvegetationmapping
Table2.Estimatedimpactareabyvegetationcondition
CollectorWindfarm Vegetationtypes Permanentlosswithineachconditionclass Totalofeach vegetationtype withinDE
Good Moderate Poor Total BoxͲGumWoodland 1.23 1.12 3.58 5.93 220.85 BoxͲGumWoodlandDerived Grassland 1.76 2.48 7.86 12.11 427.63
BrittleGum/BroadͲleaved PeppermintDryGrassForest 0.00 0.00 0.00 0.00 8.07 WhiteGumForest 0.02 0.41 0.00 0.43 28.10 TablelandsSnowGumGrassy Woodland 1.62 0.00 0.00 1.62 37.71 NativePasture 0.00 0.41 0.00 0.41 7.64 Exotic/planted 0.00 0.00 4.96 4.96 168.72 25.46 898.72
Table1.EstimatedpermanentimpactareawithinEECvegetation
CollectorWindfarm EEC Permanenthabitatlosswithineachclass HighconstraintEEC ModerateconstraintEEC BoxͲGumWoodlandand DerivedGrassland6.60 11.44 TablelandsSnowGumGrassy Woodland 1.62 0.00 TotalareawithintheDE290.57 395.62
Level 7 | 116 Miller Street | North Sydney | NSW 2060 | Phone | 61 2 9957 6211 Fax | 61 2 9954 1951 | www.app.com.au