neoen australia pty ltd windfarm, solar farm and …...1 scap agenda item 3.1.1 1 april 2019 neoen...

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SCAP Agenda Item 3.1.1

1 April 2019

Neoen Australia Pty Ltd Windfarm, Solar Farm and Battery Storage Facility – ‘Crystal Brook Energy Park’ Crystal Brook – Mid North 354/V003/18

TABLE OF CONTENTS

AGENDA REPORT ATTACHMENTS 1: LOCATION AND SITE PLANS 2: AGENDA REPORT FROM 10-11 OCTOBER 2018 MEETING 3: MINUTES FROM 10-11 OCTOBER 2018 MEETING 4: INFORMATION PROVIDED BY REPRESENTORS 5: FURTHER INFORMATION REQUEST 6: APPLICANTS SECOND RESPONSE DOCUMENT 7: ABC AND BROADCAST AUSTRALIA RESPONSES

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ADDENDUM REPORT

Application Summary Application No 354/V003/18 (ID:3140) KNET Reference #13762522 Applicant Neoen Australia Pty Ltd

(Crown Sponsor: Department of the Premier and Cabinet) Proposal 125 MW Windfarm, 150MW Solar Farm, 130 MW Lithium-ion

Battery and associated infrastructure Subject Land Various land parcels 3.5km NE of Crystal Brook (Mid North) Zone/Policy Area Primary Production Zone Relevant Authority Minister for Planning Role of the Commission:

Section 49(7) & 7(c): the State Commission Assessment Panel must undertake an assessment of the proposal and report to the Minister for Planning.

Lodgement Date 29 March 2018 (Date application submitted to DPTI) Council Port Pirie Regional Council Development Plan Consolidated 31 October 2017 Categorisation Merit Public Notification Crown Representations Refer previous report Referral Agencies EPA, Commissioner for Highways (DPTI), DEW, NVC, AMLR

NRM, NY NRM, DSD-AAR, Minister for the Mining Act, CFS, CASA, ElectraNet, SA Water, Epic Energy, Commonwealth Department of Defence.

Officers Report Lee Webb – Senior Specialist (Environmental) Planner ASSESSMENT REPORT 1. BACKGROUND At its meeting held on 10-11 October 2018, the State Commission Assessment Panel held a public hearing in Port Pirie to consider verbal submissions from representors, the local Council and a response from the applicant. Following the Port Pirie meeting, the SCAP resolved to adjourn its further consideration of the proposal, pending the preparation of an additional response document to address those planning issues raised by representors (and other reports as required) and that this response would be made available on the SCAP website. A further information request, prepared by DPTI-Planning staff with input from SCAP Members, was subsequently forwarded to the applicant on 23 October 2018. NEOEN’s response document (Development Application Response to Verbal Submissions dated 10 December 2018) was received and then published on 21 December 2018. A copy of the previous SCAP Agenda Report and attachments, Meeting Minutes, Further Information request, and Applicant’s response are contained in the ATTACHMENTS. 2. APPLICANTS SECOND RESPONSE DOCUMENT The second response document provides a comprehensive overview and response to those matters raised by SCAP members (and representors), noting that this information must be read in conjunction with the planning and technical documentation already provided with their development application.

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The following summary of the response focusses on the critical issues and aspects that required further clarification. Policy Framework The zone boundaries between general farming and ranges type-zones within or adjacent to the project area have not changed since 2002 (with the name of the zones being updated in 2017). Windfarms and ancillary structures have never been ‘non-complying’ in either zone, with the Port Pirie Council Development Plan anticipating windfarm developments within farming areas since the introduction of a Windfarms PAR in October 2003. State-wide policies for windfarm developments were introduced in the General Farming (now Primary Production) Zone on 11 October 2011 via the interim Windfarms (Ministerial) DPA. These windfarm provisions also applied to the Ranges Zone, but only for a period of 12 months (as were removed under the finalized Windfarms DPA on 18 October 2012). The Beetaloo Valley is largely within the Rural Landscape Protection Zone of the adjoining Northern Areas Council (where any windfarm development would still be assessed on their merits, but the policies provide no specific endorsement of such a land use, such that a Category 3 form of notification would be required under a standard assessment pathway and would be difficult to support given the intent and weighting of policy). The respective Development Plans provide sufficient guidance on where windfarm developments are envisaged, and where they are more clearly discouraged. The current application proposes no turbines within the RLP Zone (with the only project component being an underground cable adjacent an existing above ground water pipeline). It is also noted that the northern portion of the RLP Zone (within the Port Pirie Council area) is within Policy Area 12, an area of lesser environmental value (as expressed in their respective desired character statements) than Policy Area 11, such that Policy Area 12 allows recreational infrastructure and small scale tourism accommodation, amongst low intensity cropping and grazing activities. The applicant has provided some commentary on the existing planning policy framework (refer item 1.2 in their second response document), and this is generally consistent with this and previous assessment reports. The Primary Production Zone clearly envisages the establishment of a windfarm and ancillary infrastructure, and that previous policy reviews and amendments would have considered the availability of this land for more intensive uses (and the overall visibility of such structures) within a modified landscape. From a land use perspective - subject to all other design, construction and operational issues being addressed – the development is consistent with the zone provisions. Design Aspects The applicant provided a comparison of the height of the proposed turbines with others recently approved in other States to illustrate the trend for taller structures in the windfarm industry to improve generation output and efficiencies. This trend could lead to cheaper power prices (and increased competition) and reduce the number of turbines (and consequential impact on the environment). Clarification of turbine layout and turbine dimensions was provided, including that the turbine towers would have a maximum width of 7.5 metres at the base and that micro-siting is a standard part of the final design for logistical reasons and to further minimise impacts. Minimum setbacks from dwellings and the 500m Wedge-tailed Eagle buffer zone would not change due to micro-siting considerations (which would be dealt with as part of further design development process, such that they were no closer). A 100m micro-siting

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allowance has been sought by NEOEN, and based on a recommended requirement to submit final plans and details, this is considered an acceptable distance.

Source: NEOEN – 2nd Response Document p9.

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Noise effects The applicant advised that a leading acoustic consulting firm (i.e. Sonus) was engaged to determine the acceptability of noise generation levels, in accordance with the EPA Wind Farms Environmental Noise Guidelines (July 2009). NEOEN further advised that for this proposal the measurement of background noise levels is not an essential component of a planning assessment as the wind farm has been designed to achieve 40 dB(A) or less. Noise associated with the size, number and location of the turbines is inherently covered by the noise measurement and the location (including spacing) of turbines is included in the applicant’s noise model. Whether turbines are closely spaced or not makes no qualitative difference to acoustic emissions. Neither the applicant nor Sonus are aware of evidence for any ‘clustering effect’, and do not accept that such effect exists. The proposed windfarm has been assessed against the EPA Guidelines and the assessment concludes that the wind farm can be readily designed to achieve the Guidelines. The EPA guidelines are based on establishing external noise level criteria at which a wind farm will not unreasonably interfere with the amenity of nearby residents. Therefore, the size, shape and type of wind turbine do not influence the efficacy of the EPA Guidelines, provided the particular arrangement can achieve the criteria. The EPA has conducted recent and extensive research and testing with the finding that the EPA Guidelines provide an appropriate tool for a contemporary wind farm environmental noise assessment. The EPA has provided the following commentary on this process:

In mid-2018, a technical review of the EPA Wind Farms Environmental Noise Guidelines (July 2009) was undertaken by EPA’s Principal Noise Adviser. The technical review considered national and international research and the revised international standard IEC 61400-11:2012 Wind Turbine Generator systems – Part 11: Acoustic emission measurement techniques. The review incorporated appropriate amendments, including the new data analysis procedure recommended in the IEC standard. It also reviewed the noise criteria and considered information on infrasound, low frequency sound, tonality and amplitude modulation noise characters. Subsequent to that technical review, the World Health Organisation (WHO) guidelines for the European Region were released in October 2018. This triggered further review to compare the South Australian noise criteria with those from the WHO guidelines, other Australian jurisdictions and internationally. This confirmed that the South Australian noise criteria are still amongst the strictest in the world. The main issues challenging the SA EPA guidelines were:

New WHO guidelines on noise for the European Region The harm caused by windfarm noise Low frequency / infrasound and tonality Assessment methodologies including accounting for background noise.

The result of this review was that the SA EPA considers that the criteria in its guidelines are still appropriately protective. While the noise criteria have not changed, some additional descriptive guidance has been proposed to address the issues raised. Both the WHO and the National Health and Medical Research Council (NHMRC) state that there is no evidence of harm from windfarms that meet the current noise criteria. The NHMRC 2015 statement says:

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“After careful consideration and deliberation of the body of evidence, NHMRC concludes that there is currently no consistent evidence that wind farms cause adverse health effects in humans.”

Given the state of knowledge, the current SA EPA guidelines are considered protective.

DPTI Planning provided copies of the additional and tabled submissions to the EPA and the applicant’s response document for further review and consideration. No amendments have been made to the current EPA referral advice as a result of this review. It is acknowledged, however, that further work is being undertaken, such as NHMRC research to improve the state of knowledge about potential health effects from wind farms. The EPA has advised that the outcomes of this research will inform the adequacy of the SA guidelines. As an interim measure – and predating the current assessment – the EPA’s draft revised guidelines will be released in the next few weeks. Any additional matters raised will be included into a future review of the SA guidelines to be conducted once the two NHMRC-funded research projects addressing sleep disturbance and infrasound have been completed (expected in 2020). For comparative purposes, the applicant’s response document provides a comparison of the South Australia guidelines with those from Queensland, New South Wales and Victoria. The maximum 40 dB(A) noise limit for sensitive receivers (or 35 dB(A) for receivers in a Rural Living Zone) are generally consistent with the other jurisdictions, which range from 35 – 45 dB(A). Furthermore, the World Health Organisation (WHO) has very recently released recommendations for noise from wind farms (during the October SCAP hearing). Although the noise descriptors are different, a wind farm complying with the EPA Guidelines will also comply with the WHO Guidelines. This position was also confirmed by the Commonwealth Windfarm Commissioner at a meeting of state planning authorities with responsibility for windfarm assessments in November 2018. The Australian Medical Association has also prepared a separate Position Statement on wind farms and health, which concurs with the NHMRC position. The information provided by Mr Stephen Cooper, Ms Mary Morris, and Ms Sarah Laurie does not meet an accepted threshold of conclusive, peer-reviewed evidence that windfarms (which meet the SA EPA noise guidelines through appropriate setbacks) cause detrimental impacts to the physical health of nearby residents. Communications Interference A critical issue for regional communities is the provision and maintenance of telecommunications services for personal, educational, business and emergency service use. The potential for these services to be disrupted or eroded through the construction or operation of a new development must be carefully considered. The applicant – in its initial application – provided a technical assessment of potential electromagnetic interference and potential mitigation measures by GHD. Public submissions queried the extent of degradation and the effectiveness, timeliness and cost of the mitigation measures. NEON has acknowledged that the technical terminology used has led to confusion over the extent of the findings, particularly the meaning of the terms nil, negligible and minor that are open to interpretation. The response document clarifies these terms in the context of each service type and discusses the difference between actual degradation to signal (i.e. the signal power level received at the particular receiver) and perceived degradation to services (i.e. what a

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person using that service can notice). It was also acknowledged there are many sources of radio interference, and as such a precise calculation of the effect on each resident would be difficult to achieve. The approach adopted by the applicant is to use well-established principles from previous tests and experiences. Additional information is provided on the location of communications infrastructure and reception coverage areas for NBN, mobile phone and AM/FM radio services. Some level of radio signal loss will occur with the introduction of turbines, but it is not anticipated that the losses will be perceptible to end users. It was reiterated that the township of Crystal Brook is in an area of good television coverage and there will remain a line of sight between “The Bluff” transmitter tower and the township, with the applicant maintaining a commitment to the installation of new antennas (and in the worst case, satellite television) if any residents experience issues caused by the wind farm. In addition, NBN Wireless Broadband services should not be affected as it is a directional service and no antennas should be pointing in the direction of the turbines. Around the area, mobile phone connectivity will continue to benefit from the existing signal strength from the Crystal Brook and Gladstone towers, particularly along Wilkins Highway (for Telstra and Optus users). NEOEN has acknowledged that their initial EMI report does not mention the nearby AM tower, as AM waves are not typically affected by wind turbines (i.e. due to their long wavelength) and it is sufficiently far away from the closest turbine to not be affected (i.e. at over 3.1km). To further consider any potential impacts, DPTI-Planning made contact with Broadcast Australia (which manages the local AM Radio Services and Digital Television and FM Radio Services (from the Crystal Brook and The Bluff transmitter stations respectively); and the ABC which also manages local radio and television broadcast transmission services. In summary, there is likely to some impact to AM services (but not FM services) and DTV signal strength, but only within close proximity to the windfarm (i.e. <2km). A number of mitigation options have been recommended – on the proviso that baseline monitoring / field surveys of existing service strength is undertaken prior to the commencement of construction. Through the adoption of appropriate conditions and service upgrades at the operational stage (in consultation with these organisations and at the applicant’s cost), there should be no undue impact to neighbouring residents. GPS signals are not expected to be affected for those outside of the direct wind farm area. The provision of replacement satellite TV or internet services are an option of last resort and all other viable alternatives will be investigated before resorting to satellite services. NEOEN’s response document has suggested that where satellite television coverage does not provide local content, alternative versions would need to be streamed from online sources (such as network or Freeview apps). The local Council’s request for a nil effect on services is considered unrealistic to achieve (in the strictest sense) in terms of absolute signal levels, as the smallest of disruptions (from any source) can have an effect on the received signal power. NEOEN has advised of a commitment, as best as possible, to ensure a nil effect on the perceived signals. It is further detailed that the methodology for the proposed pre-construction reception coverage survey would involve the hiring of a sub-contractor with suitable signal level monitoring equipment. They would drive around the area of interest, with equipment mounted to their vehicle continuously polling the signal strength at the relevant frequency for the service of interest. These data points would be logged against a GPS location and later processed into a coverage map. This would allow for a comparison post turbine installation, conducted with

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the same method and ideally in similar climactic conditions to verify claims of signal disruption at the time of operational commencement (and for a suitable period thereafter). It is recommended that a comprehensive plan be prepared, that outlines the pre-development field testing methodology and the thresholds for the nominated mitigation options and/or infrastructure upgrades to be implemented, including the reporting framework, assessment criteria and timeliness of such works for local residents. All remedial works must be at the applicant’s expense. Both Broadcast Australia and the ABC have also recommended that Electromagnetic Noise levels generated by high voltage / high power electricity generation equipment will also need to be considered in both the design and operation of the development to ensure there is no impact to the reception of broadcast services in Crystal Brook and general environs. Traffic and Access In response to safety and traffic delay concerns with the access point proposed on Wilkins Highway, including the Commissioner of Highway’s preference for an access point other than the Wilkins Highway, the applicant has identified the following options:

• Wilkins Highway: Along a relatively straight and flat 1.8km stretch of the highway further to the west and away from the problematic reverse curves and inclines at the Hughes Gap/Wilkins intersection. Works to create a pull-off area (or other appropriate measure) may be required.

• Hughes Gap/Gladstone-Laura Road: Located on a long, flat, fairly straight section of road with excellent driver sightlines to entry points to the site, allowing the safe use of graduated speed reduction zones up to any access points. The land on either side is owned by involved landowners, so it will also be possible to add pull-off areas, turning bays or other works to reduce the impacts of construction traffic on local residents. Further investigation is required to determine how construction traffic should be routed to Hughes Gap Road from the Princes Highway without impacting unduly on residents of the Crystal Brook township and surrounds.

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• Eastern: Via the eastern half of the site, at or near the intersection of Gumdale Rd and Pipe Line Track. The advantages include very low traffic volumes and a very low number of occupied dwellings. The routing of construction traffic from Adelaide will need careful investigation to mitigate impacts on local residents and traffic. Three access route options have been considered.

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The best option is to use the eastern access point (via routes A, B or C) for wind turbine construction traffic, while substation and solar construction traffic (substantially less by vehicle movement volume and vehicle size) may use a western entry point on either the Wilkins Highway or Gladstone-Laura Rd. This will help to distribute traffic impacts more widely between local residents, and minimise construction traffic over the more ecologically sensitive portion of the site on the hills. Solar Farm - PVHI ‘Photovoltaic Heat Island’ effect (PVHI) has recently been subjected to considerable study with the rapid rise in large-scale solar installations around the world, mostly sited in agricultural areas. Studies have shown that the PVHI effect may occur within the perimeter of solar arrays, but remains a localised phenomenon, with the affect dissipating within close proximity of the solar field. Consequently, use of appropriate setbacks from non-involved property boundaries should prevent any impacts on non-involved landholders – particularly to more sensitive crops, horticultural activities and more sensitive land uses. It is noted that the potential extent and impacts of PVHI from large solar farms has recently been considered by the Victorian Civil and Administrative Tribunal (VCAT) in the matter of ESCO Pacific Pty Ltd v Wangaratta RCC [2019] VCAT 219 (14 February 2019). A 30m setback was recommended to ensure that any potential impacts from this affect are fully contained within the development site, although a lesser distance could be considered based on existing vegetation, roadways or similar buffer feature to neighbouring land. NEOEN has adopted a 25-metre setback from the edge of neighbouring non-involved property owners for its solar development. Obstacle Lighting NEOEN has confirmed that the appropriate aviation impact assessment was undertaken, which involved an Aviation Impact Statement (AIS), Solar Glare Review, Qualitative Risk Assessment; and Obstacle Lighting Review in accordance with Airservices Australia requirements (the Australian air navigation regulator). The response document clarified that CASA’s default position, which it now applies to every project, is that turbines of 150m or greater should have obstacle lighting. Very few

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windfarms that do not affect a Certified, Registered or Military aerodrome are ultimately required by planning authorities to incorporate obstacle lighting. NEOEN does not support obstacle lighting in circumstances that do not require such treatments or pose a minimal risk to aviation, such that by day, the wind towers will be conspicuous, while by night or in times of low visibility, aircraft are required to fly 1000 feet above them. If constructed, it is also likely that local residents (and those living further away) would not be supportive of a requirement that was both unnecessary and would needlessly increase the project’s visual impact and/or cost. If there is no statutory requirement for obstacle lighting to installed, and an appropriate risk assessment has been undertaken (with the necessary steps to update minimum flight rules), then a condition requiring their installation is not recommended (noting that any associated met masts will be lit). Flora and Fauna Impacts The initial development application was accompanied by a report from EBS Ecology, who adopted a well-accepted methodology and approach to the assessment of these issues (including related clearance applications under the Native Vegetation Act 1992). NEOEN has advised that turbines, cable and access routes would be micro-sited to minimise vegetation clearance wherever practically possible, and that if CBEP is approved by the Minister, there will be more detailed vegetation impact assessment undertaken in association with the micro-siting process. NEOEN has acknowledged that the location of the project site does provide connectivity with other intact vegetation patches which include areas contiguous with the Mount Remarkable Conservation Park. Whilst there will be some impacts, it is recommended that appropriate management plans (CEMP, OEMP etc) be incorporated with any approval documentation, to enable further investigations and the adoption of any state agency requirements that will assess the existence of alternative solutions that involve no clearance, less clearance or clearance of vegetation that is less significant (or has been degraded to a greater extent than the vegetation proposed to be cleared). Dust Management DPTI-Planning is aware of dust and erosion issues from the clearance and/or disturbance of ground surfaces during the construction of solar farms – particularly in semi-arid areas of the state within the Upper Spencer Gulf region. The two large scale solar farms built in South Australia (Bungala, north of Port Augusta; and at Tailem Bend) and have been the subject of multiple inspections during the construction and commissioning phases. This has provided a better understanding of methods and practices to limit localised dust impacts. NEON has noted that the potential for dust impacts depends greatly on soil characteristics, climatic conditions and vegetation cover during and post-construction. It is also noted that the solar site is currently cropped on arable land, which will assist with minimising soil disturbance, whilst the intended method of construction (piles etc), and more practical measures (staging, internal traffic speeds, road base, water carts and suppression, adverse weather restrictions etc), have proven to be effective, even in more adverse conditions with appropriate contactor oversight. A Dust Management Plan is recommended, either as a standalone requirement or a sub-plan with a CEMP. Visibility and Screening The construction of large structures within a relatively open rural landscape will have both an amenity and character impact (over existing site conditions and views). Current Development plan policies provide for various setback requirements, but also acknowledge that the visibility of wind turbine generators will occur in areas set aside for that purpose. The current proposal is consistent with these provisions, however this does not preclude the use of natural topography, increased setbacks, existing vegetation or the provision of

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additional buffer plantings, to provide additional screening of these structures from neighbouring residences or those with more direct views from distance. NEOEN has provided an explanation of their photomontage methodology (refer second response document), and there is no need to repeat their analysis, with a detailed explanation of the selected locations, editing steps, design software used and professional teams contracted to undertake the work. This work is consistent with other projects, with the following caveat noted by NEOEN on how such visual representations are often interpreted (and their limitations within the parameters of normal human vision):

Whilst a photomontage can provide an image that illustrates a very accurate representation of a wind turbine in relation to its proposed location and scale relative to the surrounding landscape, this [Landscape and Visual Impact Assessment] (LVIA) acknowledges that large scale objects in the landscape can appear smaller in photomontage than in real life and is partly due to the fact that a flat image does not allow the viewer to perceive any information relating to depth or distance.

There are undoubtedly areas and individual situations where additional landscape or buffer plantings can be established to help screen certain vantage points. NEOEN has expressed a willingness to do this work (i.e. to plant and maintain vegetative screening at its own cost at all dwellings within 2.5km of a turbine), and subject to an appropriate Landscaping and Screening Plan can be conditioned and then implemented at the time of construction. General Clarifications Hydrogen Production Facility – does not form part of the proposal.

Heysen Trail – NEON does not anticipate the closure or re-routing of the Heysen Trail

(except near CB27 for a distance of less than 200m) during construction of the development. Appropriate (temporary) signage and fencing will be installed to discourage movement off the trail into the construction area.

Lightning Strikes – wind turbines are susceptible to lightning strikes; however their design includes earthing equipment to dissipate excess energy from a strike safely. NEOEN has advised that only four fires have been attributed to wind turbines across Australia – an insignificant number against the number of installed machines.

Cable installation in Rural Landscape Protection Zone – underground cabling is proposed within the zone, parallel to the existing above ground water pipeline. Any native vegetation impacts – due to existing site conditions - are expected to be minimal. Underground cabling is exempted by regulation for crown developments.

Applicant’s consultation process – prior to the lodgement of their application, NEOEN has outlined the consultation process undertaken with key stakeholders and the local community. (refer to second response document). This is not a statutory requirement, but outlines the level of engagement since early 2017.

Fire Management – the SA Country Fire Service has previously advised that aircraft alone cannot put out bushfires. SACFS firefighters and fire appliances for the vast majority of instances are the primary and only method of controlling bushfires. A dynamic risk assessment will always be undertaken prior to any aerial firefighting aircraft being deployed, based on a consideration of weather conditions, fire behaviour, obstructions, visibility, assets at risk and an aircraft’s performance parameters. Following the Waterloo Windfarm Fire in 2017, the SACFS conducted a review into the application of aerial firefighting resources. Their recommendations included a comprehensive Bushfire Emergency Response Plan (proponent), requiring the pausing

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or braking of turbines, the better marking of meteorological masts, and the adoption of preventative strategies and predetermined notification procedures to dispatchers. NEOEN has committed to a range of measures to assist ground-based firefighting efforts, from the construction of access roads with passing bays, reduction of fuel loads and on-site fire-fighting equipment and trained personnel. A Bushfire and Emergency Services Plan – developed in consultation with the SACFS – is recommended.

Solar Panel glare – this is not considered to be an issue with modern solar farms, which deploy single-axis tracking systems, and panels + coatings that absorb rather than reflect light (2% reflectivity). DPTI Transport’s advice (taking into account the setbacks proposed to main roads) does not consider the solar farm would be a source of driver distraction. NEOEN has offered to provide additional landscaped buffers if needed.

Construction impacts – NEOEN acknowledges the important role Crystal Brook will play

in the development, being a local source of employment, accommodation, community interaction and business support. In addition, due to the proximity of other nearby centres and townships, such as Port Pirie, Gladstone, Laura and Georgetown, both the benefits and pressures that may arise during the construction phase will be distributed more evenly across the region (and provide a significant economic boost). NEON has also committed to an $80,000 annual community fund for local initiatives.

Flight training and aerial agriculture – refer second response document. No flight training areas were identified within the vicinity of the CBEP. A small number of turbines are located on existing cropping land (under the control of a host landowner), and as such any impacts are considered to be low to negligible on current operations. DPTI-Planning commissioned separate investigations into potential aerial spraying impacts for the CERES windfarm proposal on Yorke Peninsula in 2013, with virtually all of the 197 turbines situated on high value, continuously cropped land, and subject to appropriate management and flight assessment requirements for low altitude work, aerial agriculture applications could still occur (noting that the majority of chemical, pest and fertiliser applications are made from ground mounted rigs).

This position was supported by AEROTECH, the sole commercial aerial operator in the region at the time, whilst a management plan was also adopted to enable turbines to be switched off and blades repositioned when such works were required.

3. DISCUSSION It is considered the additional information provided in the second response document generally satisfies the issues raised about the proposal by submissions on the application and by the Panel. However, potential impacts to existing telecommunications services will need to be satisfactorily resolved. Whilst no objection has been raised by either Broadcast Australia or the ABC, any approval recommendation would need to be accompanied by appropriate pre-construction monitoring and post-construction remedial works (if required) at the full cost of the applicant. The majority of issues raised relate to the windfarm component and the potential impacts on the subject site, surrounding landowners and the community of Crystal Brook and the wider region (including the Beetaloo Valley). The issue of most concern is the visual impact on the surrounding landscape and the amenity of residents and visitors, especially due to the substantial height of the turbines and the grouped nature of the turbine layout. Potential interference with telecommunications services and suitable site access arrangements were also key issues that needed to be adequately addressed. The most contentious issue relates to the actual and perceived impacts of ‘infra-sound’ (i.e. low level inaudible noise emissions, including amplitude modulation) on the health of

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residents living near operating windfarms. This is an area of research that has been investigated by the scientific community, health bodies and governments for the past 10 years. Whilst no conclusive evidence has demonstrated such a link, it is recognised there is a need for further research on this matter and continual review of guidelines and policies related to windfarm noise standards. The EPA remains the environmental regulator for such developments in South Australia, and has assessed many similar projects and undertaken its own research (and is mindful of both interstate guidelines, overseas developments and academic / government peer reviewed research). It is also constantly reviewing its own guidelines and techniques. Broader issues include the implications for tourism (especially the Southern Flinders Ranges) and the cumulative effect of numerous windfarms developments in the Mid North Region. These are problematic issues for a planning authority, where the land use guidance allows for certain forms of development to be established. From a strategic planning perspective, many representors suggested the setback policies in development plans needed to be reviewed, due to the increasing height and generation capacity of turbines being proposed and approved since windfarm policies were incorporated into all development plans. The planning framework is currently being reviewed as part of the Planning, Development and Infrastructure Act 2016, but the policies at time of lodgement – based on a previous and comprehensive policy review which considered many issues (from visibility to hazard mitigation) – are still considered to be appropriate for the assessment (noting that the crown development process must have regard to but is not bound by them). The application and supporting documentation demonstrate the windfarm component is located within a suitable zone and achieves the required setback distances from non-associated dwellings and the township of Crystal Brook. In addition, the nature of the rural landscape and ‘Desired Character’ of the adjoining Rural Landscape Protection Zone - Policy Area 12 provides a visual buffer to the natural landscape values of the Southern Flinders Ranges to the north, which Policy Area 11 policies seek to protect. It should be noted there are no prescribed setbacks from adjacent zones. The application was submitted to the Department within the timeframe specified by the Crown sponsorship and provides a sufficient level of information on the relevant issues to enable an assessment of the proposal. An error with the location of one of the proposed turbines (i.e. within the Rural Landscape Protection Zone) has been corrected to ensure all turbines are within the Primary Production Zone. The layout plans provided in the application are considered to be detailed conceptual designs that would be subject to final designs being provided, if the application is approved. Standard approach for large energy generation and storage proposals, where refinement of the layout (including access tracks and other ancillary infrastructure) occurs due to geotechnical testing, landowner negotiations and further environmental surveys. An allowance of 100 metres for turbine positioning is considered acceptable, as has been adopted for other windfarms. Final detailed design usually undertaken in conjunction with the preparation of CEMP to ensure localised impacts are suitably minimised and mitigated, including the identification of protection and buffer zones.

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4. CONCLUSION The proposed ‘Crystal Brook Energy Park’ proposal is generally in accordance with the policies of the local Development Plan that provide for the establishment of renewable energy facilities in appropriate location – with the windfarm, solar and battery components within the Primary Industry Zone. If no further information is required, and all relevant assessment matters have been considered, this planning report can be endorsed by the State Commission Assessment Panel pursuant to Section 49 (7e) of the Development Act 1993, and a formal recommendation with appropriate conditions provided to the Minister for Planning for his further review and decision.

Lee Webb SENIOR SPECIALIST (ENVIRONMENTAL) PLANNER CROWN AND MAJOR DEVELOPMENTS PLANNING AND LAND USE SERVICES (DPTI)

neoen australia pty ltd windfarm, solar farm and …...1 scap agenda item 3.1.1 1 april 2019 neoen...

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