Mod 4 - Increase turbine height and rotor diameter

Please see attached.

This submission is written to object to the proposed Modification 4 to Glen Innes Wind Farm.

The wind farm is proposed to be sighted in a scenic rural area of the New England Region of NSW. Modification 4 proposes a 27% increase in the scale of this project, yet no substantial mitigation measures are offered to offset this increase.

This close to a historic Glen Innes property "Waterloo Station, whose significant history played a large part in the development of this rich agricultural area.tres

To install large wind turbines would significantly detract from this historic area.

Furthermore, it is extremely questionable whether this project is economically viable, given the lack of any project construction activity in the 8 years since the project was first approved. There is no justification provided as to whether this project is required or economically viable. The proponent has offered no substantial evidence as to whether this project will progress following this Modification, given that this is now the fourth modification sought for the GIWF despite no substantial progress being made towards construction. It is therefore requested that the Department of Planning does not approve Modification 4 of the Glen Innes Wind Farm.
There is no substantial evidence to justify the need for the project, and the project should therefore be rejected

This submission strongly opposes the Glen Innes Wind Farm Modification 4 on the following grounds:

1. Need for the project
The Glen Innes Wind Farm project was first approved in October 2009. Construction has not commenced during the last 8 years since approval. The project only achieved "commencement" under Condition 1.5 of their Consolidated Development Consent by completing geotechnical investigations, which does not constitute construction. This was confirmed in an email from the Department of Planning 17th February 2017 (attached), where... the definition of "construction" under the project approval specifically excludes "geotechnical drilling". The project has therefore failed to start construction 8 years after first approval. Any demonstrated need for this windfarm of 25 turbines has diminished with the approval and commencement of construction of the White Rock windfarm (119 Turbines when completed) and the Sapphire wind farm (75 turbines when completed). In addition solar farms are planned for both the White Rock and Sapphire sites. The marginal contribution of the Glen Innes Wind Farm to this infrastructure is small and as is demonstrated below, comes with some serious problems.
The need for the project therefore may no longer be viable. Modification 4 proposes supplying 90 MW into the NSW grid and the environmental assessment completed by Environmental Property Services, does not adequately address the need for the project. The economics of additional expenditure on generation is doubtful with the operation of decentralised generation in the two wind farms currently under construction.
The electricity generated by the Glen Innes Wind Farm will have to be dispatched to customers on the Qld- NSW Interconnect or the 132 kV line which runs from Glen Innes to Inverell operated by TransGrid. No evidence has been provided which demonstrates that a Transmission Connection Agreement with TransGrid can be successfully negotiated. In the event a transmission connection agreement then there is no demonstrated need for the project, as there is no way of getting the electricity to customers - without additional expenditure on infrastructure.
The lack of any activity on this project has had knock on effects to the local area. At Waterloo Station, significant capital investments have been delayed pending the outcome of this proposal. The project is impacting on the primary land use of the local area, being primary production. If the project has failed to be constructed 8 years after approval, and is impacting other land uses in the area, the Department of Planning needs to act on withdrawing this approval entirely.

2. Visual impact
The study completed by Green Bean Design was detailed as a desktop study, with no site visit noted. The result is a visual assessment study which has clear deficiencies as outlined below. It is important to note that a 27% overall increase in the project scale is a significant change. The Environmental Assessment does not address this as a significant change, rather a minor amendment.
The Green Bean Design Report notes that "This VIA also included a visual assessment of an additional twelve residential dwellings identified between 3km and 3.6km from the approved GIWF Mod‐2 wind turbines". Visual impact assessment has not been accurately extended to 3.6 Km for the following reasons:
- Change does not appropriately account for Waterloo Station Homestead. The assessment does adequately assess the visual impacts on the homestead, which has a direct line of sight to the majority of wind turbines associated with the project. The mapping of visual impact in Figure 3 of the Green Bean Design report is inaccurate. The view from Waterloo Station Homestead will have view of greater than 6-10 turbines tips.
- Waterloo Station also has two other full time occupied residences, which are not mapped. Therefore Waterloo A, Waterloo B, and Waterloo C should be assessed, in accordance with other properties with multiple dwellings noted in the report.
- No wireframe model has been completed for the view from Waterloo Station despite being classified as a Level 1 viewer sensitivity rating. Waterloo Station Homestead will have views of both Glen Innes Wind Farm, and White Rock Wind Farm.
- Matheson Church: The views from this building has not been taken into account, despite having local significance to the community.
- Glen Innes Wind Farm Modification 2 listed visual impacts of the project as "Moderate to High". Despite a 27% increase in the scale of the project, the report lists the visual impact change as "Low". The project will have immense visual impacts, and combined with the impacts from White Rock Wind Farm and Sapphire Wind Farm, will have a significant impacts on the picturesque rural setting of the area.

3. Heritage
With reference to the Wind Energy Assessment - Visual Assessment Bulletin (December 2016. Table 5, (Page 30) of the Viewer Sensitivity Level Classification classes - Any buildings, historic rural homesteads/ residences on the State or local Government Heritage are classed as a Level 1 viewer sensitivity rating. While noting that the property has "Local Heritage Listing". the Green Bean Design report fails to detail that Waterloo Station has been recorded and approved on the National Trust of Australia Register since 11/2/1974, of which a copy of the register listing is attached.
The assessment provides the following inadequate assessment of the Waterloo Station Homestead, and mitigation measures.
The dwelling is located around 770 metres north of the Gwydir Highway corridor within a parkland type setting. Mature tree planting flanks the driveway access from Waterloo Road and is scattered to the west and north of the dwelling. Views south east toward the approved GIWF Mod‐2 (and proposed Mod‐4) wind turbines are generally open and extend to wind turbines around 7 kilometers from the dwelling. Whilst there is some potential for visual mitigation through tree planting, this would have a likely undesired effect of foreshortening views and indirectly impacting the heritage values associated with the property.
In reading the above, the report offers no conclusive mitigation measures for the high visual impact that the wind turbines will have on Waterloo Station. The wind turbines are in complete contrast to the historic character generated by the homestead, shearing shed, shearers quarters and the Matheson church.

4. Noise
The noise assessment does not account for any cumulative impacts from the other two wind farms which are currently under construction in the area. Two wind farms, Sapphire and White Rock have been approved in the area and are under construction. As Glen Innes Windfarm has failed to commence construction, the noise assessment must account for the cumulative impacts of other developments in the area.
Noise is a significant issue in the Matheson Valley with the construction and now operation of the White Rock Wind Farm. It is understood that the level of protests from residents has increased markedly since operations have commenced to the point that White Rock Wind Farm has now offered compensation to some residents for the noise. This shows above anything else that noise is a significant issue and will get worse with the compounded effect of Glen Innes Wind Farm.

The Gien Innes Wind Farm project was approved in 2009 yet commencement by definition has not occurred thus voiding the original approval.
Since 2009 Two (2) other companies have proceeded with construction of 194 turbines therefore the need for so small a number (18) for Glen Innes Windfarm clearly has far less significance than when originally approved
Why cause the visual impact to National Heritage listed properties(eg) Waterloo Station and adjacent sites unnecessarily
Noise is also a concern as no assessment could have been done on the cumulative noise effects as additional stations have been constructed and will further impact on noise in the Mateson Valley already subject to compensation claims from residents
We are frequent visitors to the New England area having once lived in Inverell and we object to the approval of Thi project

The building of the Glen Innes Wind Farm would cause unnecessary impact on the heritage value of this area and unnecessary impact both visually and auditorily in the Matheson Valley area in which there are National Heritage properties.
This would alter our attitude to the frequent visits we make to the area since we once lived in Inverell

The EIS is in breach of the Environmental Planning and Assessment Regulation 2000. It needs to be withdrawn, revised and re-exhibited.

This submission is written to object to the proposed Modification 4 to Glen Innes Wind Farm.

The wind farm is proposed to be sighted in a scenic rural area of the New England Region of NSW. Modification 4 proposes a 27% increase in the scale of this project, yet no substantial mitigation measures are offered to offset this increase.

Furthermore, it is extremely questionable whether this project is economically viable, given the lack of any project construction activity in the 8 years since the project was first approved. There is no justification provided as to whether this project is required or economically viable. The proponent has offered no substantial evidence as to whether this project will progress following this Modification, given that this is now the fourth modification sought for the GIWF despite no substantial progress being made towards construction. It is therefore requested that the Department of Planning does not approve Modification 4 of the Glen Innes Wind Farm.

There is no substantial evidence to justify the need for the project, and the project should therefore be rejected.

Visual Impact Assessment:

The report fails to adequately address the criteria of the Wind Energy Assessment - Visual Assessment Bulletin (December 2016), despite claiming to have assessed against these. A strong example of this is the very poor assessment carried out on Waterloo Station. The report lists the visual impact as "High", yet limited options for mitigation are offered. Waterloo Station will be significantly impacted by this proposal, as it will have direct views of the majority of the wind turbines.

Need for the project:

The project has failed to commence 8 years following first approval. The latest modification offers no substantial justification for the project. The project is proposed to be built in an area where 2 far more substantial windfarms have commenced construction. The impact of this change to the local context of the project has not been adequately addressed.
The latest Modification to this project offers limited justification as to why a 27% increase in a project with limited economic justification, yet high environmental impact can be approved.

I do not want a wind farm in this location.

The historical landscape will be altered by building a wind farm.

This submission objects to Modification 4 of the Glen Innes Wind Farm. In the 8 years since the Minister's approval, this project has failed to proceed based on these important milestones:

No wind turbines have been ordered,
No construction has commenced,
No Power Supply Agreements have been entered into.

This seriously flawed project is impacting on the investment decisions of local landholders who are carrying out successful primary production operations. The project has been kept live through various modifications, and very limited activity on site (geotechnical drilling). We are now presented with a very poor environmental assessment which does not adequately assess the modification or the impact of the project. The environmental assessment has failed to assess the need for the project, the environmental impacts such as visual and noise, and most importantly has not adequately addressed the requirements of the Wind Energy - Visual Assessment Bulletin (Dec 2016). The project has not been able to viably commence construction despite being approved 8 years ago. The NSW Department of Planning should take a account of the relative weakness of this project in comparison to the impact it is having on local primary production enterprises. If the project does not have the merit to construct construction within the first 8 years of the project approval, modification 4 should be rejected and the project approval should be withdrawn. Deborah Anderson

This submission is written to object to the proposed Modification 4 to Glen Innes Wind Farm.

The wind farm is proposed to be sighted in a scenic rural area of the New England Region of NSW. Modification 4 proposes a 27% increase in the scale of this project, yet no substantial mitigation measures are offered to offset this increase.

Furthermore, it is extremely questionable whether this project is economically viable, given the lack of any project construction activity in the 8 years since the project was first approved. There is no justification provided as to whether this project is required or economically viable. The proponent has offered no substantial evidence as to whether this project will progress following this Modification, given that this is now the fourth modification sought for the GIWF despite no substantial progress being made towards construction. It is therefore requested that the Department of Planning does not approve Modification 4 of the Glen Innes Wind Farm.

There is no substantial evidence to justify the need for the project, and the project should therefore be rejected.

I am writing to indicate my strong opposition to Modification 4 of the Glen Innes Wind Farm which will result in the construction of more wind towers in the Matheson valley. I am particularly opposed to the modification to the existing plan which will make for greater visual pollution with the installation of the proposed wind towers.

I am a strong supporter of Australian heritage and own a heritage listed property. I am also a frequent visitor to the Matheson valley return because of the natural beauty of this rural environment and because of the Australian agricultural heritage that is very much part of the Glen Innes district. I strongly believe that there should be preservation of districts like the Matheson Valley for future generations.

You will be aware that White Rock Wind Farm has now constructed a large number of wind turbines in the Matheson valley. These were approved after the turbines proposed by Glen Innes Wind Farm. These towers are particularly unsightly and the fact that they are there reduces or eliminates the need for more. The proponents of Glen Innes Wind Farm had their chance to construct this project and could not complete. I do not believe that the visual amenity of the area should not be impacted by further wind turbine construction.

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Please see attached submission.

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As frequent visitors to Waterloo Station, one of the earliest settled properties in the Glen Innes district, my husband and I object to the Glen Innes Wind Farm on four grounds:
1. it will spoil an area of outstanding natural beauty, and have a negative visible impact on a valuable and historically significant landscape
2. potentially decimate wildlife
3. cause a noise nuisance for residents, and
4. negatively impact on an emerging tourism industry