Currawarra Solar Farm

Solar farms should be installed on non productive land not on the two proposed properties Currawarra and Tarleigh in Deniliquin. Productive land should be recognized and protected for food and fibre production.
This is another case of our regional and rural community being ignored and forgotten but instead bullied to accept this proposal because it is a political feel good project.
Framers in our productive area when producing cereal crops they support at least nine local businesses. Will a solar farm be so supportive of our community? What will the solar farm produce and what will happen when it is obsolete in 20-25 years time?
Installing solar farms on productive land is very short sighted and NSW Government is not thinking long term and or preserving the farming communities that will produce future food and fibre.
I seriously object this proposal

My husband and I along with our son are third generation farmers in the Deniliquin area.
We strongly object to the Currawarra solar proposal in the Mayrung area.
This large area of land is highly productive country that has been specifically developed to grow food and contribute to feeding the people of Australia and abroad.
We must not forget that the Snowy Hydro scheme was built to not only drought proof this inland country but to sustain itself with food. Why on earth would anyone want to use this valuable land to house a solar industry which could so easily be developed a few kilometres to the north of this proposal. This land has substantial irrigation development on it. Why on earth would anyone want to destroy this infrastructure to then replace it with solar panels. It is hard to fathom.
Leave this land for what it can produce - food and fibre.

Whilst fully supporting the development of solar electricity I strongly object to productive agricultural land being used for this purpose. The land on which it is proposed to build a solar farm has had very significant investment in the form of tax payers money plus private investment in order for it to be a viable food producing farm. Other land which is not irrigable is by far a better choice of location for a solar farm. I believe that such land is available.

I don't believe this development should be allowed in an intensive,prime farming area with many domestic houses nearby. I am a great advocate for solar power but am totally opposed to the proposed location. I can personally think of many other locations which would be much more suitable, specifically north of the Yanco Creek on the Conargo Plains.

Solar development NOT on High-Grade Agricultural land
RE: Currawarra (750ha) and Tarleigh (250ha) solar development
Department of Planning and Environment NSW
Dear Sir/Madam
We write to you about the proposed commercial solar farm development located within the Murray Irrigation Limited (MIL) area that being the Currawarra and Tarleigh development (www.currawarra_solar).
Permission is sought to change/support legislation that Commercial solar farms should not occur on high-grade irrigated agricultural land.
Two public meetings have been held and the following concerns raised:
1. The proposed development is on `high-grade' agricultural land, with already established `high-tech' irrigation infrastructure.
RES (the solar company) have chosen land with some of the best soils and already established high tech irrigation country in our district. Current infrastructure that will be removed is 2 x lateral move sprinkler irrigators, 2 x 100+meg storage dams, 2 x deep bore, 4 x spear points. It does not make sense to construct this solar farm on sites already equipped with the infrastructure to produce food. It would be sensible to establish this development on `low-grade agricultural country' such as grazing country that has not had millions of tax paid dollars spent already establishing efficient, productive irrigation blocks . We believe the company has had limited consideration in researching alternate sites.
2. Proposed project is to be located in a high density farming area.
This is a big project of up to 1,000,000 panels, over 1000ha. Compare this to the Finley/Berrigan project that has already been submitted (www.majorprojects.planning.nsw.gov.au). This project of only 385ha has quoted 82 vehicle movements per day in and out of the site during construction. How many vehicles will be involved in this much larger proposed site? Landholders are concerned about the impacts of the vehicle load traffic movement during construction in the local area because
* school bus route
* congestion and wear and tear on the existing narrow road.
* The movement of farm machinery and stock will also be effected by excessive vehicle movement along the existing narrow roadway especially during harvest periods
3. Jobs will not be created in the long term
Solar Development will only create jobs short term during construction and then employ a possible two or three permanent employees.
In contrast there is a flow on effect created with continuing existing agriculture in the long term. For example in one year 1,000 ha x 5 tonne wheat @ 250 =$1,250,000 gross. Total tonnes of 1000 ha is 5000 tonne. The flow on jobs will include those from water delivery, grain delivery sites, agronomists etc supporting a minimum of 10 businesses in the local community. Will this development support our local businesses and community as effectively? In terms of jobs agriculture productivity has a greater output and produces sustainable jobs and certainty for our area and community.
4. Environment concerns
High security fencing bordering the proposed solar farm will have several environmental impacts including
* Restricts natural kangaroo flow through paths.
* Fire hazard control is limited
* Site will become a barren landscape restricting the existing bird life including the Superb Parrot. The green corridors linking neighbouring farms was developed with Greening Australia in the 1980's to preserve our indigenous flora and fauna. Farms and roadsides are used for seed collecting to establish a seed bank in our region. Currawarra is part of the local green corridor.
* The existing `Turkey nest' dams are currently good refuge for water birds as well as offering biodiversity for the smaller animals like frogs, reptiles and small water insects that support our bird life , but once removed this vital habitat will be gone.
* Noxious weed and pest control is a major concern.( eg Bathurst Burr, foxes and rabbits)
* Uncertainty of the health of our local environment
* How much water will the Solar Farm use? Water should be used in food production

5. Health implications are untested
Commercial solar is new to Australia and health implications are untested.
Leaking and aged panels, damaged equipment & batteries, chemicals could contaminate our waterways. Is this being created in haste to meet state and federal government targets?
In summary our local shire strategic plan suggests we are a `significant national food producer that needs to be recognised, celebrated and promoted".
This solar development does not support food productivity, but changes the landscape as we know it. Our area has always been a major food bowl for the nation. This will take away 1000ha of high valued irrigation country.
The NSW Renewable Energy Action Plan (www.resourcesandenergy.nsw.gov.au) states:
"The Central, Northern and Western regions of NSW have low population densities, abundant open space and high average global exposure, which are ideal for expanding the states large scale solar electricity industry".
The proposed Currawarra/Tarleigh development is been constructed in an inappropriate location and there are many uncertainties surrounding the project.
Look forward to hearing your response.

Yours sincerely
Pam Wetenhall
413 George St, Deniliquin NSW 2710

SUBMISSIONS SOLAR FARM PROJECTS ON PRIME AGRICULTURAL AND MIL FOOTPRINT LAND at Currawarra and Tarleigh.
THIS SHORT FORM SUBMISSION IS SOUGHT TO BE EXPANDED ON BUT IS FILED TO MEET THE UNWORKABLE DEADLINE FOR A FARMING COMMUNITY IN THE MIDDLE OF HARVEST

This submission refers to the draft Large Scale Solar energy Guideline currently on exhibition

1. A key assessment issue for such a project is LAND USE AND COMPATIBILITY
There is a fundamental question to be answered here. The NSW government in its own plans for the Riverina Murray seeks to ensure healthy production from the farming community. The Federal government seeks likewise to ensure that agricultural production is promoted.
The proposal to place a solar farm on prime irrigated land or land within the irrigation infrastructure is fundamentally flawed. The uses are simply not compatible. There is a limited irrigation footprint available to produce high-end crops and other farming enterprises upon such land. The sites chosen fall within that footprint.
I quote from the draft guidelines for Solar Development of the NSW government
" To encourage industry to undertake suitable site selection for solar proposals, including associated infrastructure, to reduce the likelihood and extent of land use conflict and environmental impacts"

It is simply illogical to say that the current owner of the land "will use the Water on other properties" within the footprint as a rationale for choosing such land as against dry land or rangeland properties. There was a clear limit set by the Commonwealth on the buy back of water in the district due to the devastating effects that recent buy back scheme has had on the whole community. This is "robbing Peter to pay Paul" on a large environmental scale.
By comparison on at least one of the proposed sites "Currawarra", if one continues down the road next to the power lines around ten minutes there is available open rangeland country; not part of the MIL irrigation district, that can be developed.
Under the heading Land Use and Resources the EIS for this project states that the land is located within a " rural area: ... with predominantly broad scale agricultural land uses". What it seems to miss is that this property has a main irrigation channel running smack bang through the middle of it, has had vast improvements over many years and with different owners to its irrigation infrastructure; including recently one of the new expensive "flume gate" systems paid for under the PINOP scheme PART TAXPAYER FUNDED. We are told in the report that " the suspension of cropping for the life of the solar farm would represent a potential impact on only a small percentage of local and regional production and would be potentially offset by increased productivity at other properties held in the locality by the landowner" " the proposal would not affect unique or significant agricultural land"
I submit that every piece of irrigated land within the MIL footprint is UNIQUE and SIGNIFICANT. This property has and is able to grow food for Australia and the world. It is able not only to grow "Barley and sheep grazing" as per the EIS but has done in the past and can grow rice and other high value crops.
I also query the landholder's claim of small tonnage from this property when comparative tonnage on neighbouring land is vastly higher. There has been no proper investigation of the purported facts upon which this EIS stands
SOCIO ECONOMIC ASSESMENT
The whole area of the MIL footprint has been affected by the millennium drought and the MDBP with the consequential buy back of water. Why is it proposed to add further to the "holey cheese effect"? Why not have a win win and build a solar farm with access to the same power grid down the road on dry land country or elsewhere on dry land country? Why take away more prime land that can be irrigated? There is simply NO guarantee the current owner will use the water on another property or will not sell and move on as indeed the company seeking to develop has as its stated intention, i.e. to develop sell and move on. Who then is responsible?
PUBLIC INTEREST
What are the DIRECT REGIONAL BENEFITS of shutting down a prime irrigation property? There might be some jobs available during development. However in comparison a food producing property is shut down for up to 30 years. Add up that amount of rice barley wheat canola etc. The solar farm is not going to power the town of Deniliquin or provide cheap electricity for the residents. It will produce energy that will be sold benefiting only the seller of same on an immediate basis. I am not against and in fact am all for alternative energy and in particular SOLAR energy. However when we have VAST amounts of non-irrigated land available and on the "grid" the whole EIS seems based upon a conflict of public interest
One only has to look at the major and devastating affect on small rural communities of the MDBP and or the millennium drought to know that the more properties that are shut down and turned into dry land runs the greater the impact on the whole of the community
AREAS OF CONSTRAINT
This land is important agricultural land that is proposed to be in effect shut down for 30 years. 30 years is a long time to manage the devastating effect of another closure of two properties to significant food production
LOCAL CONSIDERATIONS
There simply was NO consultation prior to submitting the plan. The first many local landholders heard was upon reading this in the local paper. Had they been consulted earlier then no doubt many might have suggested alternate sites close to the grid but not on the MIL footprint
ENVIRONMENTAL CONSIDERATIONS
It is expected the solar "farm" "would operate for 30 years and when ceases farm infrastructure soil condition and vegetation cover within the project would be reinstated in consultation with the landowner and consistent with land use requirements" What does that mean? Who will (a) own the "solar" farm in 30 years and (b) own the farm in 30 years? The company seeking to secure approval, RES Australia Pty Ltd has already publicly stated that its intention is to sell the solar farm within a few short years of developing it (b) Will the current owners still own the land in 30 Years? Who will honour this arrangement???
There will be vegetation clearing with "offsets" Who will be responsible for the Offsets? The report documents the proposed removal of a significant number of "hollow bearing trees" and remnant vegetation. The proposed " offset planting is in flood affected land and simply will not survive any wet year
THE SUPERB PARROT
Quoting from the EIS " the threatened Superb Parrot.. was recorded at several locations within and adjacent to the proposal site" "Additional surveys would be conducted prior to the completion of the Submission Report and project approval between September and December to confirm the use of the development envelope as a breeding resource. If confirmed in an area that cannot be avoided impact calculations would be undertaken and used to update the "BOS" (balance of systems) and "BAR" (Bio Diversity Report) such that this species is appropriately offset" No subsequent survey has been provided
Indeed if one has been done who did it? Curiously there are several superb parrot habitats on near properties and this EIS simply seeks to bulldoze the remaining remnant trees and hollow trees that provide prime breeding habitat. Again why not use other land without this risk??
How does one " appropriately offset" a breeding zone of the Superb Parrot. Who is and will be responsible for such appropriate offset?
Finally the draft guidelines provide that engagement with the local community should be genuine inclusive and honest and the local community should be involved early BEFORE site selection.
That simply has not happened here
Further lengthy submissions will be provided


Yours faithfully
Robyn Wheeler
East Wandook
Deniliquin NSW

The decision to provide Australia with irrigation schemes was driven by a desire for self-sufficiency, the wisdom of which was demonstrated, soon after the plans were adopted, with the outbreak of World War 1.
I am horrified by the way the clever thinking and hard work of our ancestors is now being trampled on by a mad, subsidy-driven scramble to cover land that has been developed to make the best use of our irrigation facilities with solar collectors which could easily be located on non-irrigated land.
It is no mere accident of fate that the land which the solar power company proposes covering with solar panels is well endowed with sunlight; plants are solar collectors (and scavengers of atmospheric carbon dioxide) too.
Please reject any planned solar farms where they impact on our very necessary ability to feed ourselves. Australia has plenty of land which is unsuitable for horticulture.
If we must have solar farms, they should be located there.

I am concerned regarding the development of 2 solar farms near Deniliquin; Tarleigh Park and Currawarra.
My concerns include;
The creation of solar farms on farm land that comprises numerous paddock trees that provide habitat to a range of species. These being in a region of heavily cleared and highly modified landscapes. Providing offsets after the removal of these trees dose not maintain the same quantum of species specific habitat as any offset already exists and therefore is already providing these ecosystem services.
As there are many large scale solar farms proposed for the region I am concerned that the grid will be oversupplied in specific regions as the grid has limitations as to where the energy (as fed in by renewable sources) can be used. I am concerned the rapid roll-out of solar farms will impact on the domestic and small business that have or intend to install solar systems. Is there plan in place to ensure that house-hold and small business grid connected systems are not restricted from remaining grid connected or penalised in terms of costs of connection and or reduction in feed in tariffs?
If not, these developments should not proceed until regional long term plans for how the grid system can receive generated electricity and how it will be distributed are made public for community consultation. These plans should also demonstrate how the the grid will receive and distribute electricity in a cost effective manor.

- Site is prime irrigation agricultural land, with irrigation infrastructure that should continue to be utilised for irrigation farming.
-This project will take away major food growing opportunities for the southern Riverina;
- what are the strategic impacts on the loss of agricultural production area for the region?
- l am concerned about the visual pollution & amenity impacts of a solar farm in this area, it will change the landscape significantly
- where are the State Guidelines on solar farms and shouldn't this project wait until they are finalised;
- the exhibition period for this project should be extended to allow for key community & agricultural community groups to have input;
- why not select a site further north where the visual landscape from the road is less and the value of agricultural land is less & there isn't the invested irrigation infrastructure

SUBMISSIONS ON SOLAR FARM PROJECTS ON PRIME AGRICULTURAL AND MIL FOOTPRINT LAND at Currawarra and Tarleigh.
THIS SHORT FORM SUBMISSION IS SOUGHT TO BE EXPANDED ON BUT IS FILED TO MEET THE UNWORKABLE DEADLINE FOR A FARMING COMMUNITY IN THE MIDDLE OF HARVEST AND PRE CHRISTMAS
THE COMPANY HAS HAD YEARS TO PREPARE AND THE TIMING IS CLEARLY DESIGNED TO MINIMISE OBJECTIVE OPPORTUNITY TO OBJECT

This submission refers to the draft Large Scale Solar energy Guideline currently on exhibition

1. Large Scale Solar Energy may be alleged to be essential but not at the expense of removing fully developed high grade state of the art irrigation land that has been paid for in part by the public purse and developed over generations. The proposed Sites at Tarleigh and Currawarra are in the MIL footprint which was designed and built to drought proof Australia. Irrigation is critical for Australian Food And Fibre production. Even more so when market gardens are being gobbled up by the "Urban Sprawl". Our Prime Ministers have referred to the Riverina and the North East irrigation areas of Victoria as the " food bowl of asia". Our rice is exported to 60 countries around the World. And yet we are supposed to accept removal of highly productive Irrigation Land when there is SO much other land available in this vast land of ours. It is incongruous.
2. LAND USE CONFLICT
This use of land is in DIRECT conflict with its history; its National and State Government development Plans and indeed the Current NSW Government forward plans for the Riverina Murray District. Certainly the Currawarra property in the past has grown Rice, been a dairy farm and produced food and stock.
The proposed developments are allegedly, according to the EIS, only taking a small percentage of irrigated land out of production. However;
(A) That statistic does not take into account that both properties are fully developed with state of the art MIL infrastructure and improvements including "flume gates" paid for by the Taxpayer!
(B) Small percentages might seem nothing to a bureaucrat but as we have seen in the MDBP, the so called numbers and statistics did not match up with real life and the effect on local communities and the flow on effect in rural towns schools etc.
(C ) The alleged " tonnage" of production on these properties in the EIS bears no resemblance to neighbouring properties and is not based upon any returns that have been produced in the EIS. It is laughable that a report could be so transparently wrong on such an issue. Just go and look next door. It comes down to management.
3 SOCIO ECONOMIC ASSESMENT
The Powell Jenson Gibson report in 1985 " the Economic Impact of Irrigated Agriculture in NSW" indicated that the impact is around a five fold multiplier effect on the National Economy of Farm gate gross production. 1000 hectares of Irrigated land in the areas of Currawarra and Tarleigh is able to produce at least 800K to 1 Million of farm gate product per annum if one compares similar properties in the area. This is a loss not only to the local community but to the nation. The Solar Farm does not produce anything other than electricity without (save initial labour IF using local people and alleged 4 or 5 staff ongoing) any comparative farm gate production. There is NO comparative study provided in the EIS.
In fact, other irrigators will have to PAY MORE for the infrastructure. In 30 years time when the alleged decommissioning occurs are these properties then expecting to be turned back into irrigated farms whilst OTHER IRRIGATORS have carried the COST BURDEN of maintaining the systems?? Who will actually own the farm? Will the current owners still own it? Will the SOLAR FARM be owned by the same company who has already publicly stated it will develop and then sell within a few short years? WHO will be responsible? The idea of any RESPONSIBILITY in this EIS is a FARCE.
It is alleged that the current owner will use " water" on another property. What if the current owner has already sold the water (and the EIS is silent on that issue)? Then, like many irrigators who sold water to survive the Millenium Drought (and were to use the money for water efficiency projects), the current owner must buy water in on a needs basis. It is NOT that simple as transferring water and this EIS may be fundamentally misleading the public on this issue.
In any event, there IS NO GURANTEE that the owner will use the water on another property or not sell and move on. The "other property" referred to in the EIS. Query why is it not at maximum production in any event???
4 PUBLIC INTEREST
School Children going by on their school bus each day (four bus loads of children every day ) past Currawarra are going to get the wrong message. They are going to know that big business and big money mean more than their little farms and producing food for Australia. Are we teaching them to aspire to one of the so called 4 or 5 jobs for both Solar Projects in running these places when they leave school?? Are we giving them a positive message about the future or irrigated farming in the MIL district??? Or are we telling them that there is no future in producing food.
In Japan and in Europe farmers are revered. That is because they STARVED during the World Wars. We are teaching our children to have no PRIDE in what we do. To be a farmer is to be a second rate citizen.
The energy produced by this Solar Farm is going to the National Grid and not into the local community.
The National Grid will not want to buy excess solar energy from those small farm panels (such as ourselves) in the district.
5. AREAS OF CONSTRAINT
This land is prime irrigated agricultural land that is to be shut down for 30 years. The reality is it will be shut down forever. 30 years is a long time to manage the devastating effect of another closure of two properties with access to irrigation and able to make significant food production. This won't be for 30 years the panels will be replaced and this land will never be reverted back to farming country. That is in DIRECT Conflict with the whole reason for putting irrigation infrastructure and building MIL area
6. LOCAL CONSIDERATIONS
There was NO consultation or discussion as to the proposed location prior to submitting the plan. As locals we could have suggested far better locations that would not have destroyed prime irrigation land. The lack of consultation is in direct conflict with the NSW draft guidelines on Large Scale Solar Projects.

When " consultation" later happened it was set up under a " divide and conquer" plan where the company had tables set up so that as an individual you were picked off by those well versed in "spin". There was no collective presentation and therefore hard to know what "spin" was "spun" to each individual. This is not cricket. The examples already mentioned in this submission of the "spin" re productivity of these properties and water use is a prime example of misleading behaviour.
"Tarleigh" sits below an elevated residence on the next property who looks out at present on to a beautiful farming property. This will be replaced to a view of glaring SOLAR PANELS. Again no amount of screening will resolve this issue and further see comments on screening trees below. Again why NOT BUILD THESE FARMS ON NON CONFLICTED USE LAND
7. ENVIRONMENTAL CONSIDERATIONS
There is no mention in the EIS of Kangaroo flow and movement. The proposed security fence around the properties will prevent such flow and cause trapping and altered movement on other properties surrounding the areas.

The EIS states
"It is expected the solar "farm".. "would operate for 30 years and when ceases farm infrastructure soil condition and vegetation cover within the project would be reinstated in consultation with the landowner and consistent with land use requirements"
The company RES cannot make such a statement when they have publicly stated they will SELL these Developments in a few short years.
It is unlikely these Developments would be dismantled in any event. It is more likely that the panels will be replaced.
There is a history of "offsets" not actually happening E.g. with tree removal. WHO will Police the so-called " OFFSETS"??
Already the so-called " boundary screening trees" are not planned to be even PLANTED until the SOLAR FARM IS BUILT!! Trees take a long time to have any shade or screening value. One might ask WHY that is left until LAST?? Will a new owner of the Solar Farm WATER the young trees??? It is all talk and no action on the environmental scale. Screening should be a FIRST requirement not LAST

THE SUPERB PARROT

Hollow trees are planned to be removed from this property. Such trees are critical for birds and marsupials
Quoting from the EIS " the threatened Superb Parrot.. was recorded at several locations within and adjacent to the proposal site" "Additional surveys would be conducted prior to the completion of the Submission Report and project approval between September and December to confirm the use of the development envelope as a breeding resource. If confirmed in an area that cannot be avoided impact calculations would be undertaken and used to update the "BOS" (balance of systems) and "BAR" (Bio Diversity Report) such that this species is appropriately offset"
No subsequent survey has been provided
HOW DOES ONE "OFFSET" a SUPERB PARROT???.
HOW DOES ONE "OFFSET" a SUPERB PARROT's BREEDING GROUND???.
This is just hyperbole and humbug!

Andrew Hermiston
East Wandook
Deniliquin NSW

Firstly, I am a supporter of alternative energy and solar is but one form that needs exploiting in Australia. The proposal to turn this productive irrigation land into a solar farm is not of benefit to the community nor to Australia's ability to efficiently produce food in a diminishing amount of viable available land. This farm I am lead to believe has already had a lot of Government money spend on upgrading its irrigation system to produce food more efficiently and it seems a waste to now abandon all this investment by both public and private money. Murray Irrigation has also spent both shareholders and public money improving water delivery to this and neighbouring sites. There is many more areas close by and to the north where a solar farm would have minimal impact on highly productive land. This proposal has no inbuilt restoration of the land after the proposed thirty year life span, are we to assume that more public money will be spent removing the panels and supporting infrastructure or is this to become a derelict unproductive piece of landscape.To summarize it is wrong and I object to placing a solar farm at this location.

Local Land Services provides consideration to, and comment in respect of, the zone of the land and native vegetation clearing. For our agency's purpose, the land is considered to be regulated land subject to authorisation for removal of native vegetation under the Local Land Services Act 2013.

The EIS includes the below, as noted:
* The land proposed for SSD 8437 is freehold and zoned RU1 - Primary Production.
* The development proposed is deemed State Significant Development, a major project for NSW.
* LLS has reviewed the EIS with particular regard to the clearing/removal of native vegetation.
* Vegetation clearing is to be offset, consistent with a Biodiversity Offset Strategy included in the BAR.
* A Biodiversity Offset Plan (BOP) will be developed and implemented as part of the proposal. The offset will be managed in perpetuity, and established subject to consent conditions within 2 years of construction.
LLS response:
Clearing provisions under the Local Land Services Act 2013, section 60O states;
For the purposes of this Part, the clearing of native vegetation in a regulated rural area is authorised under other legislation in any of the following cases:
(a) The clearing was authorised by (i) a development consent under Part 4 of the Environmental Planning and Assessment Act 1979, or
(ii) a State significant infrastructure approval under Part 5.1 of that Act

The Solar Farm proposal, including vegetation clearing, is being assessed under Part 4 of the EP&A Act. The potential impacts on native vegetation are discussed in section 8.1 of the report and accordingly as the EIS gives consideration for such clearing, LLS does not provide any additional consent as an agency. The EIS addresses matters with respect to vegetation clearing, offsetting and biodiversity requirements and authorises activities via the Planning legislation pathway.

Local Land Services has no further comment in respect to matters under Part 5 of the Local Land Services Act 2013.

Please see attached submission addressing electricity security and pricing.

Objection in attached file

See below attached Currawarra Solar Farm submission.

Please refer to the attached submission

See attached letter

See attached.

See attached.

See attached.