Rye Park Wind Farm

The proposed Rye Park wind farm should be rejected on strategic grounds and because of a multiplicity of defects in the environmental assessment. Either of these alone is sufficient to reject the proposal. In combination they are overwhelming grounds for rejection. (See attachments)

I am pleased to have the opportunity to make a submission in response to the Rye Park Wind Farm Project Application.

See attachment

Please find attached my submission to the Rye Park Wind Farm Environmental Assessment and Application

To the NSW Planning Department
Re Rye Park Wind farm.
I am the author of the only Australian research accepted by the NH&MRC in it's most recent review of wind turbines and health AND a participant in the South Australian EPA's 2013 Waterloo wind farm noise study.
As NSW has adopted the SA wind farm noise guidelines, the ongoing problems at SA wind farms - particularly Waterloo and Hallett - should be treated as a cautionary tale.
The experience of residents living in the vicinity of the Waterloo wind farm is that the SA EPA wind farm noise guidelines are inadequate and in urgent need of review.
The current SA 2009 guidelines do not protect the residents from adverse effects from ILFN , vibration and audible noise. Sleep disturbance, Vibration and Distressing physical symptoms and sensations are common complaints despite the fact that the EPA has declared the wind farm compliant.
Under the current SA guidelines, disturbance and negative impacts are allowed to occur at a level which is unacceptable to the residents. Over time, residents have found themselves becoming more sensitive to the emissions rather than adapting.

Attachments provided with this submission support further research and review and updating of the guidelines and are the work of internationally recognized expert acousticians:
Dr Paul Schomer,
Dr Bruce Walker
Dr George Hessler
and Emeritus Professor Colin Hansen.
Their comments are specifically in relation to the SA guidelines and the SA EPA's Waterloo noise study and the message is clear. The current guidelines allow levels of sound emissions which cause ongoing significant impacts to the residents.
The recent UK DEFRA report by AECOM : Wind Farm Noise Complaint Methodology (in NANR 277 Defra April 2011) describes a rating system for wind farm noise impacts.
If assessed under the UK rating system, many Waterloo people are regularly experiencing a significant impact near a "compliant" wind farm .


There is no consideration in the SA guidelines (and therefore NSW guidelines) for:
ILFN;
quantifying the impact on residents;
noise monitoring inside dwellings;
separating night from day measurements;
and the overuse of averaging in the analysis ;
- all of which are known concerns in other jurisdictions.
eg UK and Denmark
These noise impact issues need to be addressed before planning approval is granted to any more wind farms in this country.

To do anything else can only be considered negligent.

The Waubra Foundation's submission is attached as a pdf. It has been sent separately to Minister Goward, the Minister for Planning in NSW. Could you please acknowledge receipt of this submission via email.

Thank you

Please see letter attached.

Director-General
NSW Department of Planning and Infrastructure
GPO Box 39
SYDNEY, NSW, 2001
[Date]

Re: Rye Park Wind Farm Project Application - Application Number 10-0223

Dear Sir

I am pleased to have the opportunity to make a submission in response to the Rye Park Wind Farm Project Application.

INTRODUCTION
I am Cheryl-Lea Field and I am a 9th generation australian, starting in this area when it was first settled by the Bush families. I am a concerned local, daughter and sister of my family that is directly affected

We have lived, and raised our family in the Yass/Rye Park area since the first free settlers and have worked within the Yass Shire, but live in Canberra and travel most weekends to Yass and Blakney Creek to help my parents on their farm.

The Farm is directly affected by this development and no consideration has been taken on the individual impact on the people living here, and the impact on the animals, the ability to super properties and the risk of fires and destroying virgin bushland.

My brother is also affected with his lovely property, which he has invested a lot of money and effort will be directly affected, with them being close to the fence. I don't want my nephews medically affected and financially affected by this development. I have read and watched a range of reviews of this type of development and do not think this meets any environmental improvement for the world. Just the opposite. These are also larger and stronger than others I have seen and this will just be worse. I have researched this extensively and have submitted below the relevant bits I strongly in which I strongly believe
I do not object to this Project.

THE PROJECT
The Rye Park wind development will involve the construction and operation of up to 126 wind turbines, together with accompanying structures, access tracks and electrical infrastructure above and below the ground. The turbines are planned to have a maximum height of 157 metres above ground level and would be located on a series of ridgelines running north to south from Rye Park to Yass.
The EA describes the location as exposed windy ridges, cleared grazing land, predominantly used for grazing sheep and cattle and has been cleared and grazed over many decades.
You could mention that a large part of the area is natural woodland and grassland, and it has been sympathetically cleared to retain a natural balance of wildlife and grazing. It has not been clearfelled and exposed as suggested.
The application has also been submitted without mentioning the exact turbines that will be used, the exact size of the turbines and therefore could not know the exact implications to the site and people living in the vicinity.

STRATEGIC JUSTIFICATION
It has been estimated that there would need to be a wind turbine erected every day until 2020 for Australia to reach its greenhouse emissions target relying on wind energy!
The use of very rare, high rainfall, productive country in NSW for "wind farms" is an outrage.
The only way this project can be viable is to apply for the supply of power to the ACT who are hoping to achieve 90% renewable energy by 2020.
Why should those in the adjoining NSW country areas pay the price for this?
Why should our valuable grazing land, rare natural environment and quality of life suffer so that Canberrans can feel good when they turn on their airconditioners and heaters.
The application say on page 16 that according to a document called `NSW wind farm greenhouse gas savings tool' the Rye Park Wind Farm will reduce greenhouse gas emissions by around 1,153,000 tonnes CO2e per annum equivalent to taking 314,000 cares off our roads. How about some information on how much omission will be created in the building and operation of the project. the steel that will need to be manufactured and shipped to Australia, the manufacture of the fibreglass blades, the massive amount of oil that will need to be used in each turbine, the approx 80 tonnes of cement that will be poured into each hole to hold them up and the trucks to get it there, the material and machinery to build the access roads, the 700 kg of rare earth that is used in each turbine (mined in China and killing the miners due to the 1 kg radioactive waste per 700kg) and the thousands of truck trips that will be needed to transport the material to the site.

CONSIDERATION OF ALTERNATIVE SITES
No project of this size would be allowed to the east of us as it would then place it in the Sydney Water Catchment area and would be seen to be a risk to the cleanliness of Sydney's water.
If wind turbines are safe, quiet and nice to look at why are they not building them close to the larger cities. Less infrastructure would be needed in the way of power lines, less fuel would be needed to travel to the construction site, closer to qualified staff etc. The outskirts of Canberra is windy, so is Goulburn, and of course Sydney nearly always has a breeze coming off the ocean.

PLANNING
The application will be determined by the NSW Department of Planning and Infrastructure, and governed by the NSW Environmental Planning and Assessment Act 1979.
Local councils are not the consent authority and ther is no oblication to comply with relevant Development Control Plans.
Epuron have completely ignored the Draft NSW Planning Guidelines - Wind Farms - December 2011, particularly in relation to the procedure for homes within 2kms of turbines.

CONSULTATION
This is a big one. As most of you will know there has been a gross inadequacy of consultation with those living in the project area, as well as in local villages and towns.
You will need to write about your experiences with consultation, or lack of it, any requests that have been ignored, how you heard about the project etc.
The application refers to a report named `Community Attitudes to Wind Farms in NSW' (page 18) that was done in 2010. It states that there was overall support for wind farms, with 85% of the population supporting wind in NSW, and 79% supporting a wind farm being built 10km from their residence.
You could mention this does not support the attitude you are finding in your own area, and where are the figures supporting Rye Park, Yass, Dalton and Boorowa residents wanting turbines built less than 5kms from their homes.
The application also mentions "an information `Open House' day held in Rye Park in July 2012"
Is this adequate Community Consultation when Epuron have been in the area planning this project for many years.
The recent information day held by Epuron in Rye Park on Wednesday 21st May, during business hours, was not advertised in Boorowa or Rye Park, and only a few select people were invited. It was also held after the application was submitted to Dept Planning.

COMMUNITY BENEFITS
The proposed buyer from Trustpower has been heard to say that the amount of money being expected in the community fund ($130,000 pa) will not be viable. It will also need to be shared between 3 local councils, Boorowa, Upper Lachlan and Yass.
There will not be local jobs long term. Even the construction phase will not use local companies as they will not be able to be competitive. Gullen Range used Divals, a large Goulburn company, for earth moving etc. The Suzlon workers, who have the maintenance contract for the Lake George turbines, live in Goulburn not Bungendore. Any other trades people will need to put in quotes, and in the business world it is usually only the large corporate companies that can be competitive on such a large scale.
Families will suffer increased insurance costs, or become uninsurable, if turbines are within 1 km of homes or boundaries as fire fighters will not offer aerial water bombing support in the case of fire. Also heavy machinery operators will not enter the fire area without aerial support.
Will proposed hosts be able to get public liability insurance, likewise for neighbours with development so close to their homes and boundaries.

LANDSCAPE AND VISUAL IMPACTS
Another big one. It is hard to visualise how big these things will be, but if you look at one of your eucalypts which is about 20m high and visualise a wind turbine that is 157m high next to it you might be able to get a feel for them.
If you have had photo montages done you will need to mention how inadequate and misleading they are in relation to the perspective they give. They are not done with full blue sky backgrounds.
You also need to mention if you have not been offered montages, particularly if you are close to turbines.
Is your house on the project maps? Maps not clear enough to get a true indication of turbine sites.
Turbines are generally located on the top of hills which make them more clearly visible over long distances.
Rural landholders hold a deep sense of ownership of their outlook and wish to preserve their rural amenity and lifestyle, and have generally paid a great deal for that privilege.

CUMULATIVE IMPACTS
The adjoining Bango wind project has 120 turbines proposed and Rugby has 52 proposed.
No consideration is being given by Epuron as these are "currently in the planning stage and are not yet approved".
The Rye Park, Yass, Dalton and Boorowa areas will be surrounded by hundreds of turbines, and it is our belief that if one project is approved there will be no reason for the adjoining projects to be knocked back, as the Rye Park project area has a greater concentration of people, natural environment and endangered species that the others.

NOISE
The reality is that modelling by the developer cannot be proved until the wind farm is operational, by which time it becomes a costly exercise to either turn off or remove the offending turbines. In some cases property acquisition has resulted or residents continue to suffer.
The SA 2003 (and 2009) noise guidelines used in wind farm development do not require measurement of infrasound and there is no requirement for measuring noise of any type inside a residence. These measurements should be mandatory and maximum allowable levels set.
The allowable background noise measurement is too high at night, In rural areas background noise at night is often below 20 dBA.
The Rye Park, Boorowa, Dalton and Yass are all in valleys and as we know with the way fog settles, we will also have the sound taking the same path.
You will hear the turbines, and you need to ask for reassurance that the project will meet the legislative requirements and you will not have your peace and quiet impacted.
The application admits on page 21 that "minor excedances were predicted in the initial layout".
The application also states on page 22 "Blasting impact has been assessed and found to be acceptable" Since when has blasting been acceptable in any rural setting.
Again the cumulative impacts of so many turbines in this project, and in addition to the other planned projects, needs to be taken into consideration.
There will also be noise from power lines and the 3 collection and sub stations.
Note: One of the sound monitoring devices that was set up was in a very noisy position where vehicles, birds, dogs barking and tractors moving past were common. Surely this would distort the base line and void against comparison.

ECOLOGY
Are you concerned about the environmental impact of this development.
Have you been involved with Landcare projects, Superb Parrot habitat regeneration, revegetation of remnant vegetation areas. Think about the millions of dollars that has been spent on these things in this area.
The impact on bird life that hundreds of turbines will have, the erosion risk to our landscape, creeks and rivers. The impact the erosion will have on Yass, Boorowa, Dalton and Rye Park water supplies.
The application identified "eleven vegetation types", "four threatened flora species and one EEC were identified with potential for impact", "nine species of threateded birds and three species of threatened microbats were recorded during surveys", (page 22). Along with the 99 different species of bird identified.
Isn't this significant enough to warrant ceasing all development of the project?
How can Epuron justify building wind turbines to save the earth when they are destroying this unique part of the environment?
Access roads are noted as needing to be 5 - 6 metres wide, wider on bends. Some of the roads on the access route are only about 4 metres wide, which means all the old trees and remnant vegetation along these roads will need to be cleared to make way for the trucks and machinery.

CULTURAL HERITAGE
Full consideration needs to be given to the local Aboriginal communities as well as the history of European settlers.
This is a known Aboriginal settlement area and still has an active community in the area, highlighted by the fact that they identified at least four groups in the area.
The application does not give enough consideration to their history.

LAND MANAGEMENT
The application plays down the impact the project will have on land management. 5 - 6 metre wide access roads, a hectare of land dug up for the construction of each turbine, the destructive access to the tops of the hills, the huge amount of drainage systems that will need to be put in place to decrease the impact of erosion. Cutting properties into smaller portions will certainly impact on the productivity of these farms.
Those with smaller properties neighbouring turbines will also be impacted because their animals will not utilise the part of the farm closest to the noise and traffic.
Water courses will be disrupted with the strong possibility that storms will cause erosion, which will cause muddiness in dams and streams. New drainage systems may even divert water from existing catchments and stop stock water dams from filling.
Massive amount of water will be needed, placing a greater burden on already stretched water supplies in the area. Have permissions been sought and water licences been granted for getting water from Burrinjuck Dam. The application also mentions getting water from the Yass reservoir but have not yet got permission for this (page 23). How can it be considered to use an already stretched town water supply for a private development of this magnitude.

PROPERTY VALUES
I am concerned many people will have large negative impacts on their property values. this will affect their livelihood and even cause banks to reassess their solvency. My family rely on these values to support the employment of many local people.
Who is going to want to buy our properties when they are in close proximity to and surrounded by wind turbines? It will greatly reduce the competition by purchasers, resulting in lower values.
Will councils suffer rate decreases because of lower land values over large council areas, particularly when there are several proposals in place alongside each other?
as I said above -will we be able to renew mortgages with our lending institutions, or get loans for improvements when our property and earning ability is negatively impacted.

ENVIRONMENTAL MANAGEMENT
Epuron have not done adequate planning to ensure the project will be compliant. Plans not included in the application are Traffice and Transport, Erosion & Sediment Control, Landscape Management, Loil & Water, Chemical and Fuel Storage, Fire Management, Rail Safety Management, Waste Gerneration and Disposal etc.
Epuron think it is ok to put in a significant development application without fully planning the project.
They do not even know yet which model of turbine they will be using.
Is this acceptable to you?

ADDITIONAL ISSUES
Page 24 - "A detailed geotechnical assessment would be conducted oned the turbine locations have been finalised to determine the ground conditions and stability at each turbine site."
- "An Environmental Management Plan would be developed in accordance with the Best Practice Guidelines for Wind Energy Projects and the project consent conditions to ensure that issues such as erosion, weed control, air quality and drainaged are appropriately addressed."
This means that even though they have produced maps showing turbine locations they have not even decided exactly where they will be yet.
This means that concerns about the environment have not yet been fully identified and mitigation measures planned.
This means that unless the NSW Dept of Planning identify an issue and mention it in the `project consent conditions' they will not bother doing any more than they have to.

You also need to remember that Epuron have put in the application but if approved will then on sell the project to another company to build and operate. What assurances will we have that all conditions placed on Epuron will be followed by the new company.

We are left hanging with various developments being proposed surrounding us. There are not time limits for an end to these developments. Already very difficult to make long term plans concerning our personal lives, and improvements to our property.

Page 24 of the application states "The project is not predicted to have any significant adverse environmental impacts on the site or its surrounds, geology or soils as the overall surface disturbance is relatively small in size and manner."

This pretty much sums up the insignificance to our area and our lives that Epuron think this massive project will have, and how much intelligence we don't have that we won't notice!

Please see attached reasons for opposing the Rye Park Wind FArm

I object to the further development of the Wind Farm as its construction and operation will degrade the environment around my family property as the closest turbines will be only 1.6kms from our house. I am concerned about the impact on the health of my horses and cattle due to media reports of the impact of turbines on chickens and other reports regarding ill health in horses.
The increased traffic during construction together with the movement of the turbines may contribute to the death of native animals and birds.
Transport movements will introduce weeds to the area around our property which we will then have to control, adding costs to our farming.

Director-General
NSW Department of Planning and Infrastructure
GPO Box 39
SYDNEY, NSW, 2001

4 July 2014

Re: Rye Park Wind Farm Project Application - Application Number 10-0223

Dear Sir / Ma'am,

Thank you for the opportunity to make this submission in response to the Rye Park Wind Farm Project Application.

INTRODUCTION

My husband and I have lived in Rye Park since 2010. We purchased our home because it is a unique lifestyle property of 3 acres surrounded by larger farms which guarantees our privacy and secures our peaceful, pastoral outlook to the nearby ridges.

Unknown to us when we purchased was that a large wind farm was planned for Rye Park and that 10 wind turbines were to be sited in our precious outlook within a 2.1 to 3 kilometre range.

Our property looks up to the ridgelines and no amount of screening will restore our current outlook once the wind farm is constructed. Using Epuron's Zone of Visual Influence descriptors our future outlook to the wind farm would be defined as one of `high visibility.'

All 10 turbines in our immediate outlook are to be sited on property owned by absentee landlords who are not part of our Rye Park community. Of great annoyance to us is that our lifestyle as permanent full time residents of Rye Park will be degraded for the financial benefit of landowners who have no intention of being part of our community.

My husband and I are both members of the Rye Park Wind Farm Community Consultative Committee. At a recent committee meeting we were dismayed to learn of the minimalist contribution the mooted purchaser of the proposed wind farm - Trustpower - is prepared to input to the Rye Park community. There is a pervading sense of intended exploitation by a foreign owned company with little benefit to most in the Rye Park community should the wind farm be approved.

LANDSCAPE AND VISUAL IMPACTS

Epuron have provided a photomontage for our property (receptor 24) which is grossly inadequate and misleading in the perspective it provides. The image provided is not a realistic representation of the size of the future wind turbines and markedly minimises the visual impact the turbines will have on our outlook. When Epuron were challenged at a Community Consultative Committee meeting regarding this their representative was unable to defend the integrity of the photomontage and other participants at the meeting were genuinely shocked when I presented an alternative depiction of how the turbines will more realistically look. This image has been forwarded previously to both the Department of Planning and Infrastructure and the Minister's office.

The turbines are located on the top of hills to our north and north east which makes them more clearly visible from our property. As we look up to them from our front verandah there is no relief provided by topography, vegetation or buildings. Our home will clearly view the entire turbine structure from ground to tip of blade. No amount of screening will improve our outlook once the wind farm is constructed.

While our immediate neighbours all own 500 + acreage we own only 3 acres and we will not be able to escape the visual presence of these wind turbines until we enter our home and close the doors.

Epuron have not made any consideration for smaller lifestyle properties such as ours which are surrounded by larger properties resulting in a more open outlook and consequent higher visual impact.

Should the Rye Park wind farm proceed as planned our visual amenity will be irreversibly degraded.

NOISE

The reality is that modelling by the developer cannot be proved until the wind farm is operational, which is of concern when the allowable background noise measurement is already contentious. In rural areas background noise at night is often below 20 dBA.

Even during the day our location is very quiet to the extent that my husband and I were enjoying our morning coffee on our verandah when we both heard an unfamiliar noise. We eventually established that what we were hearing was the carpenter using his staple gun on a house being constructed 3 kilometres from our house. One of the reasons we live here is for this peace and quiet. You do not have to be an acoustician to deduce that industrial wind turbines taller than the Sydney Harbour Bridge and located less than 3 kilometres from our home will be very noisy when the prevalent north easterly breezes blow in our direction during the summer nights. Are we expected to close all our windows and doors to try and block out the noise of the wind turbines and then have to cool our house with an air conditioner instead of taking the natural advantage of the cooling north easterlies?

Epuron have not admitted that we will suffer noise disturbance from the wind turbines but the Bango wind farm representative has told us that we will certainly hear the wind turbines as we are located closer than 3 kilometres from them. How are we mean't to cope with sleep deprivation ensuing from the noise of these turbines?

As already stated our property is unique because it is surrounded by much larger holdings which are all pastoral. Consequently we do not have any buildings from neighbours or natural topography or vegetation which could deflect the noise from the turbines. How are we to have quiet enjoyment of our home if the allowable background noise measurement exceeds requirements and what actions will the proponent take to mitigate our degraded lifestyle when this occurs?

ECOLOGY

We are concerned about the environmental impact of this development.

The application identified "eleven vegetation types", "four threatened flora species and one EEC was identified with potential for impact", "nine species of threatened birds and three species of threatened microbats were recorded during surveys", (page 22). Along with the 99 different species of bird identified.

Isn't this significant enough to warrant ceasing all development of the project?

PROPERTY VALUES

The NSW Valuer General Preliminary Assessment of the Impact of Wind Farms on Surrounding Land Values in Australia report indicated that lifestyle properties such as ours were more likely to decrease in value because of proximity to wind farms than larger holdings. We have had first hand experience of property devaluation...and this is before the wind farm is even built.

12 months ago my husband and I approached our bank for refinancing. It was the same bank and the same branch which provided our mortgage for our property at Rye Park two years earlier. Because we were refinancing the bank undertook another valuation on our property. The result was that our property had reduced in value by $30,000 in the two year period while local properties not close to the wind farm were rising in value. The only difference between the two valuations was that this time the bank took into consideration the proximity of our property to the proposed wind farm.

This is clearly indicative that should we want to sell our property, it is very likely that we are going to suffer substantial loss of value because of close proximity to wind turbines. Of great concern, is that Epuron does not offer any mitigating strategies to compensate non host landowners for property devaluation because of proximity to their proposed wind farm when there is increasing evidence that devaluation is a reality.

ENVIRONMENTAL MANAGEMENT

Epuron have failed to undertake adequate planning to ensure the project will be compliant. Plans not included in the application are Traffic and Transport, Erosion & Sediment Control, Landscape Management, Soil & Water, Chemical and Fuel Storage, Fire Management, Rail Safety Management, Waste Generation and Disposal.

Additionally, the model of turbine has not been decided nor the exact locations of these turbines. Consequently, concerns about the environment have not yet been fully identified/addressed nor mitigation measures definitively planned.

It is unprofessional for Epuron to submit a State Significant Development application without fully and meticulously planning the project. This does not inspire confidence for members of the Rye Park community in an industrial project that is going to alter our visual landscape forever and significantly devalue our primary asset - the family home.

BDLG Submission. See attached.

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