Mod 6 - Stage 2 Turbine Changes

I object to the proposed Stage 2 Mod. for the White Rock Windfarm for the
following reasons : TRANSPORT *Increased tower/blade size (
weight/length ) will place additional stress on road surface condition
and roadside tree/ vegetation removal. NOISE *Increased blade sweep
area is likely to increase audible noise levels. HEALTH * Current low
frequency noise standards for windfarms are totally inadeqate. *
Credible recent research indicates LF Noise can impact on personal
well being. *The Australian Administrative Tribunal ( AAT - Dec 2017)
held that ` noise annoyance ` by wind turbine generated LFN and IFN is
a ` plausible pathway to disease' based on association between noise
annoyance and some diseases. The AAT also stated that wind turbine
noise standards ( LFN and IFN ) are currently irrelevant and unfit for
purpose. ENVIRONMENT * With rotor swept area increasing by up to 100 %
( 22,000 sq.m - 2.2 ha circular area ) and increased turbulence /
vortex suction , together with increased height, the potential for
bird / bat strike is enormous and poses an unacceptable risk. *
Research shows that soil evaporation downwind of turbines ( up to 10
km ) can be as much as 10 cm p.a. If there is a doubling of the rotor
area there will most likely be an increase in evaporation levels.
BUSHFIRE / AERIAL *A 33% increase in blade tip height and associated
rotor length increase ( 150 m to 200 m ) poses unacceptable risk for
aerial proximity ( fire control / agricultural spraying ) due to
excessive height and air turbulence. VISUAL The report by Green Bean
Design lacks robustness in numerous areas and falls short of best
practice standards , particularly with montaging and wireframes. The
following are a few instances which need full consideration in any
final assessment. * GBD indicates that there will be a reduction of 8
in visible turbines / blades and an increase of 11 in visible turbines
/blades. This would seem to indicate a nett disadvantage to visually
impacted residents. However, * 7.3 states some residents will have
increased visual impact but a greater number will have less impact.
Compare to the above. Is this a case of the greatest good for the the
greatest number - not exactly "non- discrimination" when compared to
the currently approved Stage 2! *7.4 Night Lighting : The impact of
night lighting needs full consideration should CASA condition night
lighting at a future date. *8.3 Landscape Character : The reference to
`low density settlement" may be asssisting in describing some of the
existing landscape characteristics but it is to be hoped that the
assessing parties do not take a small surrounding population size as a
criteria in their decision making as appears to have occurred with the
Crudine Ridge project. The reference to the nearby Sapphire and Glen
Innes windfarms helping to form a `renewable energy hub' and creating
a "windfarm / renewable" landscape character is appalling and seems to
imply that since the area is now `trashed' , well so what ? Did the
local residents ask for this landscape character change ?
Photomontages and Wireframe representations: The photomontages and
wireframe representation fall well below acceptable standards and are
misleading , giving little more than a general view of a typical
windfarm. They do not allow an impacted viewer any sense of the
magnitude and scale of what will result. Note the following . The
montage spread range extends up to 100 degrees . The wireframe spread
range extends up to 160 degrees The horizontal field of vision of the
human eye is about 60 degrees and cannot take in the scale of the
montages and wireframes without scanning horizontally .Current
international best practice for montages / wireframes can generate
reliable / verifiable images. This has not occurred in this report by
GBD. I reference the following for your information : David Watson (
Landscape architect ) www. davidwatson.info/via-exprience.php A
viewing of his profile / curriculum / verifiable montages will
demonstrate the standard that should have applied with regard to these
photomontages. A number of wireframe images ( eg.WF3,WF4,WF14, etc )
appear to indicate that some Stage 2 ( Mod ) turbines ( purple ) in
the foreground / middle ground appear to be smaller than the large
turbines shown in the back ground, resulting in confusion of size and
scale and generally giving rise to a wasted exercise. ENERGY The
present electrical energy supply chain is in an almost unworkable
situation with regard to stability / reliability and consumer pricing.
Much of this is due to renewable energy supplies. Increased turbine
size will likely result in increased output ( when the wind happens to
be blowing ) which will further tend to destabilise the grid and
supply system. The above information and arguments are some of the
reasons for a total rejection of the White Rock Stage 2 Modification
application.

5/3/2018 Dear Sir/ Madam, I am writing to OBJECT to the proposed
modifications for the stage 2 at White Rock Wind Farm. The proposed
modifications are a disgrace and this should NOT BE RUBBER STAMPED BY
THE DPE. The modifications * increase turbine height from 150m
(previously approved) to 200m * increase blade length from 55m to 85m
(i.e. more than double rotor swept area) * add 4 additional properties
(2,000 hectares) to the project area Surely the DPE can recognise that
these are significant increases/ changes and that they should be
brought back before a PAC meeting. I find in incredible disconcerting
that a major developer such as Goldwind can say in their submission
"The visual impact of the modification has been assessed as
acceptable" and "The noise impact of the modified project has been
assessed as acceptable." And the DPE pulls out its rubber stamp and
goes "OK"... Wind Turbines get approval by the Pac and then the
proppant's start their push for modifications. The previous approval
for white rock was for Epuron. Goldwind needs to be held to account
before a PAC. Take this back through the assessment process. These
changes WILL IMPACT significantly on this community and the DPE needs
to take these impacts seriously and not sweep this communities
concerns aside Regards Sue Lane 0448824722

Response to Modification 6 - White Rock Wind Farm 6 March 2018 Waterloo
Station Pastoral Company Pty. Ltd. as trustee for The Waterloo
Pastoral Trust ACN 079002396 ABN 19278426006 This submission strongly
opposes White Rock Wind Farm Modification 6, particularly in regard to
visual amenity and noise. The study completed by Green Bean Design is
clearly a desktop study, with no site visit noted. As a result the
visual assessment study which has clear deficiencies. It is unclear on
how a visual assessment, which proposes a 50 metre increase in turbine
height, can be assessed without visiting the area, particularly
following the commencement of construction of Stage 1 of the White
Rock Wind Farm. This casts serious doubt on the adequacy of the
assessment. It is important to note that a 33% overall increase in the
max tip height is a significant change. The Environmental Assessment
does not address this as a significant change, rather a low to medium
impact. The project proposes a significant increase in turbine size
across the project, in a rural setting. The wind farm will be highly
visible and will further spoil the natural beauty of an area dominated
by agricultural pursuits. The modification is proposed purely on
economic grounds with no actual regard for the significant
environmental impact that this project will have on the local area.
Noise is a significant issue in the Matheson Valley with the
construction and now operation of the White Rock Wind Farm Stage 1. 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 the proposed
modification.

SUBMISSION IN RELATION TO MODICATION REQUEST NO. 6 BY THE WHITEROCK WIND
FARM THIS SUBMISSION SPECIFICALLY OBJECTS TO THE CONSTRUCTION OF
TURBINE # 84, 85, 86, 137. The owner of the property where turbines
84, 85, 86, and 137 are located has lodged objections to the
construction of wind turbines elsewhere in the vicinity on the basis
set out in this submission. It is therefore incumbent upon the
department to apply a uniform assessment approach in their
consideration of the approval of the turbines currently being assessed
for their own property under MOD 6 of the WRWF. How is it possible for
someone to object to the construction of turbines on neighbouring
properties whilst consenting to the construction of turbines on their
own property of a much larger size with the subsequently larger
associated impacts? At the very least, the department should dismiss
the objections (and those of other related parties) or apply the same
judgements and processes to the current application seeking consent
for WRWF MOD 6. White rock Wind Farm Modification 6 requests approval
for turbines including 84, 85, 86, and 137: - Increasing the rotor tip
height to 200m, - Increasing the turbine blade length to 170m
diameter, - Increasing the width of the access tracks to 12mtrs, and -
Changing the location of some turbine sites. Whiterock Wind Farm
Modification 6 Request should not be approved for the following
reasons: Visual Impact 1. The Visual Impact Report without genuine
discussions with each affected resident (which has not occurred)
within the 5klm boundary cannot yield valid conclusions about the
visual impacts on each property. 2. The Modification 6 request by WRWF
seeks consent for: - A hub height increase of 41 metres from 89m to
130m - a 46% increase. - A rotor diameter increase of 48 metres from
122m to 170m - a 40% increase. - A tip height increase of 30 metres
from 150m to 200m - a 33% increase. - A sweep area increase of 10740
sq metres from 11960 sq metres to 22700 sq metres - a 90% increase.
This is a significant increase in visual impact and will have a
substantial impact on residences within 5klm. How can WRWF conclude
that this substantial area/visual increase is not a significant
change, but rather a minor amendment? 3. The WRWF Modification 6
request will have Immense Additional Visual Impacts, and when combined
with the visual impacts from the much larger SWF wind farm, will have
a significant impact on the picturesque rural setting of the local
area. WRWF management is very aware that one of the main reasons for
the strong opposition to the wind farm by the local community and
residents within close proximity is the significant adverse visual
impact caused by the turbines - this gets much worse with Modification
6. 4. The report offers no conclusive measures to remedy the high
visual impact that the wind turbines will have on residences within
5klms of the WRWF. The measures put forward previously by the WRWF to
remedy the adverse visual impacts for residences from the wind
turbines, and approved by the Department, was "additional tree
plantings". Additional tree planting is not a practical option to
mitigate the adverse visual impact. It would appear that the
Department and residences within 5klms of the wind turbines have been
misled in the past. 5. The Visual Assessment does not adequately
address the cumulative visual impacts arising from the adjacent GIWF
and SWF on residences in close proximity to the WRWF. 6. The report
offers no genuine mitigation measures for the high visual impact that
the wind turbines will have on at least 59 dwellings within 5klm of
the Wind Farm. The wind turbines are in complete contrast to the
surrounding countryside and environment. 7. The Environmental
Assessment ignores the residential rights.of properties in close
proximity to the WRWF all of which have a "Moderate" or "High" visual
impact. Residential rights must be taken into account. 8. Also the
WRWF and SWF are currently under construction and they are having a
significant visual impact in the area. The cumulative impacts of the
WRWF and SWF must be addressed. Noise 9. The Noise Assessment does not
account for the cumulative noise impacts from the two wind farms in
the area viz: WRWF and SWF. As construction of the WRWF Mod 6 has not
commenced the noise assessment must now account for the cumulative
impact of the other two wind farms in the area. 10. Noise, as well as
visual impact, is now a significant issue in the Matheson Valley with
the construction and now partial operation of the WRWF. It is
understood that the level of protests from residents has increased
marketably since operations have commenced to the point that WRWF has
now offered compensation to some residences for their noise/visual
impact concerns. This shows above anything else that noise/visual
impact is a significant issue for residences in close proximity to
wind farms and this will only get worse with the compounded effect of
the WRWF Mod 6. 11. The NSW Wind Farm guidelines require that Wind
Farm proponents must undertake a comprehensive and genuine community
consultation and engagement process. The applicant must demonstrate in
the environment assessment that effective consultation has occurred
prior to the lodgement of the application and that issues raised as a
result have been addressed in the Assessment. Without this being
adequately demonstrated, the application will not be accepted. GIWF
have not consulted residences in close proximity to the WRWF in
relation to this modification request. Accordingly, the Department has
no option but to refuse the modification request. Other 12. Any need
for the WRWF Mod 6 turbines has substantially diminished with the
approval and commencement of construction of the 70 turbine White Rock
Wind Farm and 75 turbine Sapphire Wind Farm. In addition, solar farms
are planned for both the WRWF and SWF. 13. The increase in access
track width will cause additional environmental damage and wildlife
habitat fragmentation resulting in increased risk to animal and bird
life - especially threatened species. 14. There is no doubt that the
development of the wind farm will have a significant negative effect
on property values. 15. The WRWF does not have the support of the Glen
Innes Severn Council as the Development Approval does not comply with
the Council's DCP for Wind Farms. 16. The Modification 6 request does
not comply with the requirements of the December 2011 NSW Planning
Guidelines Wind Farms, in particular the 2klm setback and community
consultation. 17. The WRWF does not have strong community support.
This is also evidenced by the number of objections to the GIWF. These
objectors must surely have the same complaints against the WRWF Mod 6?
18. This modification request has not been prepared and assessed
against all of the requirements of the NSW Planning Guidelines Wind
Farms 2011. Such a comparison will highlight serious deficiencies in
the Environment Assessment.

White rock Wind Farm Modification 6 requests approval for turbines
including 84, 85, 86, and 137:
- Increasing the rotor tip height to 200m,
- Increasing the turbine blade length to 170m diameter,
- Increasing the width of the access tracks to 12mtrs, and
- Changing the location of some turbine sites.

The owner of the property where turbines 84, 85, 86, and 137 are
located has lodged objections to the construction of wind turbines
elsewhere in the vicinity on the basis set out in this submission. It
is therefore incumbent upon the department to apply a uniform
assessment approach in their consideration of the approval of the
turbines currently seeking approval on their own property under MOD 6
of the WRWF. I object to the construction of turbines on neighboring
properties when being disagreeable to the construction of the same
turbines as (GIWF).
As a landowner attached to the Glen Innes Windfarm (GIWF) and upon
which land GIWF turbines will be located, I ask that the department
treat all GIWF landowners on an equal basis in relation to turbines as
those permitted to landowners on Whiterock Windfarm Mod 6.

See attached submission

I am opposed to the modifications to the White Rock wind farm on the
grounds that approval was given originally on turbines of a lesser
size in height and blade sweep area. The proposed increase is
significant and will greatly impact on the local residents. I believe
if approval is given on certain criteria then that should stand. An
increase of this magnitude cannot be considered a modification.

Elizabeth Tomlinson

To Where m It May Concern

I hereby object to the application by Gold Wind Pty Limited to be he
modifications proposed to the Windfarm project

In particular I object to the placement of turbines 84, 85,86 and 137.

It is on official department records that the Furracabad Valley is a
unique and beautiful area of argricultural land, the preservation of
such should be maintained at all costs. It's ambiance should be
preserved for future generations to enjoy.
I believed be a winfarm of this magnitude, and associated
infrastructure is totally out of the question for an area such as
this.
I also note that landholders are yet to approve this application
Yours sincerely
Julie Sheedy

We purchased our property two (2) years ago. At the time we were told
that there would be no wind farms near our place or home. We now find
that stage 1 of the wind farm is 5 kilometers away and we hear the
noise at night and in the early morning.

Now, totally unknow to us until Monday 5 March 2018 when White Rock
Wind Farm representatives visited us, we now find that stage 2 of the
wind farm is proposed to go ahead with an additional 48 turbines. Of
these, 3 turbines will only be 2 kilometers away from our home and by
White Rock's people will expose us to considerable noise and they will
be visible - being an ugly sight on our beautiful landscape.

We have also been told by the real estate agents in Glen Innes that
our land value will drop considerably due to the closeness of the
turbines. We are also concerned because we are one family of only two
who live permanently in the location.

We are not against wind farms but these 3 proposed turbines are too
close to our home and will destroy our quality of life. We ask that
these 3 turbines be moved further away from us.

We would like you to call us to discuss our problems on our home
phone: 02 6732 6047.

Regards
Robert and Rosemary Clissold

I refer to your request for an Airservices assessment of a modification
request for White Rock Wind Farm.

Airspace Procedures

With respect to procedures designed by Airservices in accordance with
ICAO PANS-OPS and Document 9905, at a maximum height of 1596m (5237ft)
AHD the wind farm will not affect any sector or circling altitude, nor
any instrument approach or departure procedure at Glen Innes or
Inverell Airport.

Note that procedures not designed by Airservices at Glen Innes or
Inverell Airport were not considered in this assessment

Communications/Navigation/Surveillance (CNS) Facilities

This proposal for the White Rock Wind Farm will not adversely impact
the performance of any Airservices Precision/Non-Precision Nav Aids,
Anemometers, HF/VHF/UHF Comms, A-SMGCS, Radar, PRM, ADS-B, WAM or
Satellite/Links.

Council's primary focus in relation to the White Rock Mod 6 proposal
relates to the potential requirement from CASA for flashing navigation
lights on the turbines.

This issue is currently being debated in relation to the Sapphire wind
farm and it is understood that the surrounding community are not happy
with the situation and the CASA requirement. The other concern is that
of the potential cumulative visual impact if all wind farms in this
locality have this requirement.
It is also understood that a solution being investigated includes a
form of radar perimeter that is tripped, and the flashing lights go
on, only if a plane flies within a certain distance of the winds
farms. If a solution such as this can be found Council believes this
to be an acceptable outcome for the broader community.

Given the current concerns with the Sapphire Wind farm and the
flashing night lighting, Council believes that this matter should be
resolved/assessed up-front as part of the approval process.

Council would be happy to be involved in further discussions in
respect to this matter.

Please see attached advice.

Objection attached

Please see my attached submission on the deficiencies of the Visual
Impact Assessment.

Please find attached my submission

See attached advice.

See attached advice.

Please find attached an objection to the proposed modification to the
White Rock Wind Farm

See attached advice.

See attached Advice