Orange Grove Solar Farm

Basis of Objection
Although not a local resident or landholder, I often visit and work on
an adjacent property (Orange Grove) owned by a friend of mine. I am
appalled that this facility has been proposed in this location for the
reasons set out below.
Land Use Planning
This valley is zoned RU1. The community's vision for this prime
agricultural land is set out in the Objectives of the RU1 zone. This
development is incompatible with these objectives as outlined below.
RU1 Objectives
Encourage sustainable primary industry production by maintaining and
enhancing the natural resource base.
The generation of electricity is not a primary industry. It is an
industrial process, which takes one natural resource, solar energy,
but depletes two others; the rich agricultural soil and the precious
ground water. This proposal is an industrial process on a large scale,
which rather than enhancing the natural resource base, degrades it and
therefore fails abysmally to meet this objective.
Encourage diversity in primary industry enterprises and systems
appropriate for the area
Although this land use could be argued to be a diversification of a
landholder's enterprise, it is not a diversification of primary
industry activities. Moreover, it simultaneously benefits only the
landholder on whose land the installation is located and prevents
similar diversification by most other landholders by consuming the
capacity of Transgrid's infrastructure to absorb local electricity
generation. Even if Transgrid had unlimited ability and appetite for
local electricity generation of this type, it could not be
contemplated surely that it be open to all landholders along the
Transgrid 132 KV line. This would result in this industrial land use
taking large swathes of a valley of highly productive agricultural
land, which would never be accepted on almost all environmental
criteria. Granting a rezoning that advantages one or two landholders
and excludes all others is an infringement on the basic rights of
landholders generally in the valley.
Minimize the fragmentation and alienation of resource lands.
This proposal and the even bigger Gunnedah Solar Farm proposed for a
nearby site, cumulatively contribute to, rather than minimize, the
fragmentation and alienation of this prime agricultural land.
Minimize conflict between land uses within this zone and land uses
within adjoining zones.
The two solar farms proposed for this vicinity are in conflict with
existing land uses and zoning. This conflict stems from their impact
on:
- - the soil on which they are sited;
- - the flood plain during times of flood;
- - the ambience and character of this iconic rural valley.
Provide for a range of ecologically sustainable agricultural and rural
land uses and development on broad acre rural lands.
This industrial proposal, whilst it may contribute to the broad
sustainability objectives of the state government, is not ecologically
sustainable by comparison with the traditional use of the land. Prime
agricultural land should not be alienated for an industrial purpose
however meritorious in the broader sense.
Protect significant agricultural resources (soil, water and
vegetation) in recognition of their value to Gunnedah's longer term
economic sustainability.
Rather than protect agricultural resources and recognize their value,
this industrial proposal alienates the land on which it would be
located. It locks up a significant area of land for 25 years and
degrades the soil, according to agronomist advice, over which it would
be located.
Conserve and enhance the quality of valuable environmental assets
including waterways riparian land wetlands and other surface and
groundwater resources remnant native vegetation and fauna movement
corridors as part of new development and land use.
The proposed development would be fully fenced in a way that would
stop the free movement of fauna. This fencing also would prevent the
free flow of surface water, especially at times of flood. The outcome
of the latter would be a negative impact on adjacent land resulting in
increased flood impact and the erosion of valuable agricultural soil.
Prohibited Land Uses
The RU1 land use zone prohibits industrial uses, which must include
the generation of electricity by any means. The proposed solar farm is
an industrial land use and therefore would require a change of zoning.
Such a change in zoning would be incompatible with the existing land
uses and the objectives of the existing zoning.
Biodiversity Impacts
The EIS states that the proposed site has few remnants of native
vegetation and consequently no habitats for native animals and this is
likely true. However, there is no mention of the solar farm's impact
on the rich agricultural soil. Healthy soils are full of organisms. It
is understood that the long term prognosis is not good for soils that
are constantly shaded by solar collectors. A facility that has this
effect on the soil should not be located on prime agricultural land.
Heritage
The EIS notes aboriginal heritage sites and recommends a management
regime for them. However, there is no mention of early European
settlement in the area. This is disappointing. A solar farm is not
consistent with the heritage landscape that remains basically intact
since early settlement.
Land Use
Soil
The EIS states that the soil will be managed so as to retain its
viability as an agricultural resource at the end of the project's
life. Soil agronomists doubt that this is a likely outcome after so
many years of shading. Soil is full of living organisms, most of which
will not survive. Solar farms should only be located on poor soils
were the degradation caused will not affect Australia's food
production.
Flood
A large fenced area in the path of a major flood will inevitable
affect surrounding properties. It is understood that Orange Grove Rd.
has gone underwater during major flood events. It is likely that the
effect of the solar farm will be to increase levels on adjacent lands
so that property that escaped inundation by past floods may not in
future.
Agriculture is a land use that is renewed by flooding. Electricity
generation is an essential service and, as such, should not be sited
on flood prone land. Essential community facilities such as Police
Stations, Courthouses, Schools and Hospitals are not built on flood
prone land and neither should utilities.
Compatibility with existing land uses
The proponent maintains that a solar farm is compatible with existing
land uses, which are predominantly grazing and some cropping on small
landholdings. Because the farms are small, the proposed solar arrays
will be close to homesteads. Indeed, one is only 100m metres from the
perimeter fence. Others are within eyeshot and every local resident
will drive past the facility because it straddles Orange Grove Rd. The
imposition of this industrial installation on the rural landscape
interferes with the right of the existing residents of the valley to
the peaceful enjoyment of their rural land and neighbourhood.
Weeds
The proposed solar installation will encompass 253Ha of land. It could
become a breeding ground for weeds if the site is not actively
managed. This will be labour intensive because the supporting
structure will prevent boom spraying. There is no guarantee that the
effort required to manage the weeds will lead to infestations with
negative consequences for adjacent properties.
Visual
Visual impact
The EIS seems to indicate that the only negative visual impact is from
a viewpoint at each homestead. This is not a valid assessment
criteria. Any sight of the proposed development from any part of a
property is intrusive, as is the sight of the installation when
passing down the Orange Grove Rd. The proponent should be required to
shield the entire site with vegetation.
There is a risk of glare, reflectivity and the intrusion of night
lighting. Perimeter planting would mitigate this.
It should be remembered that Orange Grove Rd. is a tourist route
between Lake Keepit and Gunnedah. An industrial installation is not
compatible with the scenic values sought by rural tourists
Transport
The Orange Grove Rd., near the proposed site, is not sealed.
Construction traffic will have a significant impact on the road.
However, if the facility were to become operational the impact of the
unsealed road on the solar collectors, it is assumed, would also be
significant. Dust will have a significant impact on the efficiency of
the collectors. The site straddles what is a relatively busy unsealed
road. One would have though site more remote from such a road would
have been a better proposition, requiring less maintenance and less
water usage.
Water
It must be assumed that the proposed facility will use significant
quantities of water during its operation. The use of ground water for
industry, not agriculture, is not the best use of a precious resource.
Hazards and Mitigation
A major hazard must be fire generated by parts of the proposed
installation such as substations and transmission lines. The local
landholders do not need another source of bushfire near their
properties.

Suitability of Site for Proposed Use
The selection of this site seems to be based on the advantages offered
by the proximity of Transgrid's 132KV transmission line rather than
good land use and planning principles. The site is prime agricultural
land and it should not be alienated and degraded by an industrial land
use that should be sited on poorer ground that is not flood prone.

See attached

See attached

I fully support the Orange Grove solar project as i believe it puts our
region on a path to sustainable electricity production while creating
local employment.
The employment created is important as we need to diversify our local
employment base to become less reliant on Agriculture and Mining as
our major employers.
The project appears to be in the right spot, away from the effects of
flooding and close to the Electricity Infrastructure required.

I am a strong believer in renewable energy.This solar farm would be a
good for our town & district.The solar farm would create work &clean
power.

SOLAR IS THE WAY OF THE FUTURE AND WE MUST EMBRACE IT. WE NEED CLEAN
ENERGY TO HELP WITH CLIMATE CHANGE WHICH EFFECTS EVERYONE. IT WILL
ALSO HELP WITH EMPLOYMENT IN OUR LOCAL AREA.

My family has a large agricultural enterprise in North West NSW. I would
like to object to the proposed Orange Grove Solar Farm utilising
productive land for generating electricity.

The issue of food security mean that productive farming lands need to
be kept out of bounds for uses such as generation of electricity.
Power plants should be located on non-productive land.

Both the Gunnedah Solar Farm (proposed by Photon) and the Orange Grove
Sun Farm (proposed by Overland) alienate large areas of productive
agricultural land that has been used for grazing and dryland cropping
for well over one hundred years. The soils are classified as highly
productive and are amongst the most productive agricultural land in
NSW. Food production and food security are emerging issues for this
century, and this productive land should be strictly protected from
industrial land uses.

I support this development on the basis that we need more solar energy
farms and this is a well suited site for a solar farm.
* Fossil fuels are contributing to climate change and I am a farmer
that is directly being effected by climate change, it is important
that we move away from fossil fuels to renewable energy, this proposal
will have a direct impact on reducing the use of fossil fuels and I
fully support this.
* The position of this solar farm will have minimal impact on the
local environment and will have a nett positive impact on Australia's
environment.
* The solar farm will provide opportunities for local employment for
maintenance and hopefully the initital building of the solar farm.
* Generally the site chosen appears to have minimum visual impact to
the wider community. Solar farms aren't that visually ugly anyway in
my opinion, particularly if compared to other energy producing sites
such as open cut coal mines or coal fired power generators.
* There is no sound pollution and no particulate pollution with a
solar farm.
This project is in the right place to generate clean renewable energy
and will overall have a positive impact for the local community. I
fully support the application.

Dear DPE,

I lodge this submission to object to the proposal, by Overland, for
the development of the Orange Grove Sun Farm in Gunnedah. I have
family and friends in the area, so can see firsthand what impact such
a proposal will have on the community, and farming surrounds.

Looking ahead 50 years, I am concerned that continuing to approve Sun
Farming in 'prime agricultural belts' across rural Australia, without
proper trialling of current LIVE initiatives, is not beneficial to
regional communities, in this particular instance, the very
agriculturally abundant, Gunnedah.


My key concerns are as follows:

1/ Approved Sun Farms - performance (ROI/negative impact): looking at
Overland, they are currently seeking approvals on multiple large areas
of land across Australia. Overland also appear to have completed their
Queensland development (Hughenden Sun Farm), my expectation is that
the initial 'benefits &/or negative impacts' of this LIVE project are
being reviewed in tandem with other proposals being put forward across
the country.
As an Australian Tax Payer (& proud citizen), my expectation is that
Planning bodies are 'trialing this Sun Farm concept' before approving
more, as there would need to be much evidence that many Australians
are benefiting from these privatised projects, a large proportion of
which appear to be benefiting offshore organisations.

2/ Environmental impact: given the proposal is covering a wide expanse
of land in close proximity to a key Gunnedah river (Namoi), there are
flood concerns, which need to be adequately addressed. On top of this,
fire hazards and other key environmental impacts need to be fully
substantiated.

3/ Wildlife impact: significant wildlife exists in the Gunnedah
region, including the proposed area. I am concerned that such a large
project would have knock-on effects for the many animal, bird, water
and plant life in this area.
To note, the koala population is considered to be the largest koala
colony in the state, west of the Great Dividing Range.

4/ Loss of key 'food producing' agricultural land: given not enough
trialling has been completed for Sun Farming in Australia, continuing
to take prime agricultural land for such projects, is short sighted.
As a citizen, my expectation is that our government demand more R&D by
energy companies (local/foreign) with regards to clean energy
production, I do not understand why a country with more 'sunny days'
than most, and significant amounts of non-arable land, cannot use
non-arable land for 'sun activated' clean energy production. Using
excess space on current grids in prime agricultural belts, is not the
long term answer.

5/ Local economic benefit: Overland claim that their proposal benefits
the local economy. However, there seems no adequate information
currently available to substantiate this. Looking at one area where
one would feel the local economy would benefit, supplying local area
with a small amount of energy, does not appear to be the case, as the
electricity generated will not be received locally, instead go onto
the national grid. This could not be considered long term local
economic benefit.

An agricultural area's local economy, such as Gunnedah, benefits
primarily from activities such as farming and tourism. Take farming as
a basic starting point for resource requirements, it requires local
resources to work the land, to transport goods, & to sell goods.
Subsequently, much of the Gunnedah community benefit with employment
supply.

6/ Community segregation: only one farmer appears to benefit from this
proposal, with surrounding farms having to suffer with the effects,
eg, noise during construction phase (once LIVE, who knows?).
In a regional town, where community is key, the socio-economic
effects, must be considered.

7/ Impact on rural character: this region is known as a significant
area of agricultural significance (80% of the surrounding shire area
devoted to farming), & beauty. To place solar panels across large
expanses of land, not far from the town, would impact the 'look and
feel' of the area.

8/ Financial loss for surrounding farmers: this project appears to
financially benefit very few, so taking just the surrounding farms
into account, should they wish to not view the solar panels and sell
their properties, there would no doubt be much financial loss.
For those people who have brought small plots of land for hobby farms,
and wish to diversify into tourism / farmstays, then financial loss
inevitable.

9/ Tourism impact: Gunnedah is continuing to become a key regional NSW
tourist destination, with many citysiders (eg from Sydney) and
overseas visitors wishing to visit, for its beautiful natural
surrounds.
Sun Farming, with the unnatural look that solar panels give, the
effect on what is currently an appealing rural and agricultural
landscape, will soon impact this 'local' revenue stream (tourism)

10/ Government subsidies for Sun Farms vs more beneficial rural
initiatives: this proposal requires Australian Government
subsidisation. However, there are many rural communities which have a
significant number of projects that need support, for example in
Gunnedah, the Gunnedah Urban Landcare Group, seeks local support, and
it is one such organisation amongst many, championing support that
results in community benefits (eg employment) 'STAYING LOCAL'.

Please take into consideration the points above, and understand why I,
and so many, object to the Orange Grove Sun Farm going ahead.

I would like to submit an objection to the Orange Grove Solar farm as I
believe they have not fully assessed the flood risks.

The 2003 SMEC study shows that the planned location of the solar farm
experiences floods and the perimeter security fence will potentially
redirect floodwaters flow and will adversely affect the neighbouring
properties


I dont think the Orange Grove Solar Farm EIS is sufficient. The 1955
and 1984 SMEC studies show that flood waters passed through the Orange
Grove Sun Farm site. The proposed solar farm site would be flooded if
waters of similar depths happened again.

I believe they need to do more extensive studies about flood flows and
levels as required by the Draft Floodplain Management Plan for the
Upper Namoi Valley Floodplain.

I hereby strenuously object to this application.
The haphazard, opportunistic, short-sighted and disrespectful way in
which this application and its proposal has been made is not to be
tolerated.

Just because it is a "renewable" resource and targets are to be met,
the government is at risk of allowing this and other solar operations
to get away with coal seam gas strategies!

Do not allow this company, and others like them to get away with
destroying our prime agricultural land in order to save themselves the
dollars it would cost them to place these farms in uninhabited, and
barren landscapes. There are plenty of these in Australia, let's face
it folks and sun is available all over central and Northern Australia
EQUALLY.
No need to ruin our food producing areas, no need to disrespect and
desecrate the sacred indigenous area of the Kilamaroi people, no need
to take more habitat away from Koalas as their numbers are declining
already.
In particular please look at the plight of R1 relative to this
application and the intolerable distance of the project. There are two
large scale solar farm proposals in process, one on each side of this
property, an active cattle farm with residents, who have contributed
to this land and community for six generations.
Please re-read the original documents from the World Health
Organisation this company has the nerve to reference, and this
incredible lack of local and community participation in this
'community' development.There are many articles written in Namoi
Independent Newspaper of the Orange Grove Roads community distress
already without this company creating more. Please tell Overland that
theirs is a destructive approach and say "No."
Please lead our renewable energy future in a sustainable way, that
does not "Rob Peter to Pay Paul" just so that the government can meet
its targets and cover up the destruction to our prime land, indigenous
history, habitat and soil and water future. A solar farm can not be
built on a flood zoned area.

So far this company has not demonstrated respectful timely
consultation with landowners, community members and other
stakeholders. I object to the location of this solar farm, to the
impact of this farm on our natural resources, our national food
production, and the people, animals and natural environment.
Please make the company re-think its location and implementation so
that it pays for the costs of establishment and ongoing sustainability
rather than the locals, the environment, our water safety and our
capacity to produce food as we go forth into a time where water, food
and clean air are going to be in short supply.
The company are disrespectful in their approach and are cutting costs
at our (the people of Australia's) expense in order to reap the
profits in the endeavour, and if you as our gate keepers allow this to
go ahead in the place and in the way that it is proposed then so are
you.
Many thanks for taking my objection into account.

I wish to state my objection to this proposed solar farm.

I object to the lack of consultation with local farmers. This project
needs to be halted and farmers concerns need to be listened to. There
needs to be greater consultation with local and especially adjoining
land owners. Please do not proceed without further consideration of
the impacts on the local community and environment.

Further consideration of the impact on the local Koala population also
needs to be considered.

I support solar energy.

This solar farm is not situated in a major floodway and is in a
relatively isolated area and should not impact many people.

My only concerns are that Orange Grove Road will struggle with the
extra traffic during the construction period. The bitumen is only
fragile and narrow , the dirt will be a major dust hazard for local
traffic in both directions. It would be a good gesture by Overland to
the local community to allocate some substantial funds to the road if
their application is successful

TO WHOM IT MAY CONCERN,

I am making this objection as a concerned former member of the
community of Gunnedah. I also have with ties to a family who own the
R1 property on Orange Grove Rd and I have made frequent visits to R1
over the past 30 years.

My concerns in regard to this submission are primarily based on the
following issues:
- more development on prime agricultural land in Australia when food
is becoming an insecurity - we have more appropriate available land
space to use for these solar farms
- the proximity and cumulative impacts on animal welfare on R1 (both
the native koala population and the farm animals) from 2 solar farms
possibly to be developed on either side of R1
- Ecological concerns - including wind erosion from soil impacting
from solar farming effecting farm soil and rendering it unsuitable for
farming.
- The disrespectful and inappropriate level of consultation with
adjoining landowners.

I am moved by the debate and arguments of objection made by
ecologists, local indigenous people, local landowners and farmers in
regards to their concern for the bulldozer effect of large sun farms
in this country. See quote below:

`We urge the scientific community to embrace this research area and
work across disciplines, including plant-soil ecology, terrestrial
biogeochemistry and atmospheric science, to ensure we are on the path
to truly sustainable energy provision.
Dr Alona Armstrong is a faculty fellow in energy at Lancaster
Environment Centre, Lancaster University

Thank you for your time and hearing these concerns.

I object to the Orange Grove Solar farm on the basis that there are
unmitigated flood risks as a result of the project which have not
adequately been addressed by the proponent.

Because the Orange Grove Sun Farm site is affected by flooding, much
more work and investigation needs to be done with respect to flows,
increases in flood levels and changes to velocities. This is required
by the Draft Floodplain Management Plan for the Upper Namoi Valley
Floodplain.

This letter objects to Orange Grove solar because it is obviously
conflicting with existing agricultural operations . Farmers with crops
and livestock cannot compete to hundreds of construction equipment
with vibration , noise and dust such as R1 which the design does not
consider. Nor can they compete with a company that doesn't consider
drainage important in a flood zone (this particular area is well known
as flood zone) and builds a mesh fence to obstruct flow in a flood .
The water run off from panels onto close land may be contaminated and
soil changes with the weed herbicides will create less productive soil
in Australia . Farmers are not compensated unless the government makes
changes with large boundary barriers for environmental safety.

I am very familiar with the area proposed in this development called R1.
I feel overwhelmingly disappointed by the proposed development and the
lack of care for community and residents that will be impacted by the
scale of development. Particularly so close to one house and along the
boundary which will significantly impact their ability to run their
livestock and sustain their livelihood through farming. It is
disappointing that such prime agricultural land is being proposed to
be built on.
I object to Orange Grove solar because it is obviously conflicting
with existing agricultural operations . Farmers with crops and
livestock cannot compete to hundreds of construction equipment with
vibration , noise and dust such as R1 which the design does not
consider.
Farmers are not compensated unless the government makes changes with
large boundary barriers for environmental safety.

Not enough transparency or consultation with those directly affected by
the project.

I don't believe that the company has done either of the following: made
sure of- Suitability of the site with respect to potential land use
conflicts with existing and future surrounding land uses; and

Paying particular attention to cumulative impacts and compatibility of
the development with evidence it has been developed in consultation
with affected landowners.

These are the basic requirements and this project has fluffed and
falsified details to get their project through.

It's disgusting and shameful. I feel sad as an Australian.