West Wyalong Solar Farm

I refer to your electronic mail of 8 February 2019 to the Environment
Protection Authority (EPA) requesting our comments on the
Environmental Impact Statement for the proposed West Wyalong Solar
Farm.

The EPA has responsibilities for pollution control and environmental
management for scheduled activities under the Protection of the
Environment Operations Act 1997. Based on the information provided the
proposed development is not a scheduled activity under the Protection
of the Environment Operations Act 1997 and the solar farm does not
require an Environment Protection Licence. Under the Protection of the
Environment Operations Act 1997 Bland Shire Council will be the
Appropriate Regulatory Authority for pollution control and
environmental management issues for this proposal should it be
approved.

On this basis the EPA has no further comments to make in relation to
this proposal and requires no further consultation in relation to this
application.

If you have any further enquiries about this matter please contact me
by telephoning 02 6969 0700.

The connections group provided the response below.

Please note Lightsource is currently completing their compliance
studies for their application to connect.
While there is currently capacity (limited) and may require network
augmentation, due to the Open Access framework of the National
Electricity Rules (NER) there is the risk that this capacity be
limited further should Lightsource have to consider the impacts of
additional projects committing prior to this application completing.

As for my comments, just the usual one on ensuring that the connection
is not tied to ongoing conditions of the project and is treated
separately for ongoing maintenance, management and operation.

I refer to the submission of the Notice of Exhibition dated 13 February
2019 for the above development to Fire & Rescue NSW (FRNSW) for agency
input. Aspects of the proponent's Environmental Impact Statement have
been reviewed and the following comments and recommendations are
submitted for consideration.

Large scale solar farm developments are usually located within NSW
Rural Fire Services' (RFS) fire districts. Notwithstanding, in the
event of either a significant fire event or hazardous material
incident (hazmat), FRNSW will be responded to either assist the RFS or
to fulfill the role of the designated hazmat combat agency.

It is FRNSW experience that small and large-scale photovoltaic
installations present unique electrical hazard risks to our personnel
when fulfilling their emergency duties. It is highlighted that the
Fire and Rescue NSW Act 1989 (the Act) imposes specific statutory
functions and duties upon the Commissioner of FRNSW. Section 6 of the
Act requires the Commissioner to take all practicable measures for
preventing and extinguishing fires and protecting and saving life and
property within a FRNSW fire district. Section 6 of the Act also
requires the Commissioner to protect and save life and property
endangered by hazmat incidents and for confining a hazmat incident and
for rendering the hazmat site safe.

In addition, the Work Health and Safety (WHS) Act 2011 (and its
subordinate Regulation) classify FRNSW as a person (entity) conducting
a business or undertaking (PCBU). Clauses 34 and 35 of the WHS
Regulation impose specific obligations upon a PCBU to identify hazards
and manage risks at workplaces. A site involved in fire or hazmat
incident is deemed to be a FRNSW place of work.

Due to the electrical and fire hazards associated with large scale
photovoltaic installations and the potential risk to the health and
safety of firefighters, both FRNSW and the NSW Rural Fire Service must
be able to implement effective and appropriate risk control measures
when managing an emergency incident at the proposed site.

In the event of a fire or hazardous material incident, it is important
that first responders have ready access to information which enables
effective hazard control measures to be quickly implemented. Without
limiting the scope of the emergency response plan (ERP) requirements
of Clause 43 of the Work Health and Safety Regulation 2000 (the
Regulation), the following matters are recommended to be addressed:

1. That a comprehensive ERP is developed for the site.

2. That the ERP specifically addresses foreseeable on-site and
off-site fire events and other emergency incidents (such as fires
involving solar panel arrays, battery energy storage systems,
bushfires in the immediate vicinity) or potential hazmat incidents.

3. That the ERP details the appropriate risk control measures that
would need to be implemented to safely mitigate potential risks to the
health and safety of firefighters and other first responders
(including electrical hazards).

Such measures will include the level of personal protective clothing
required to be worn, the minimum level of respiratory protection
required, decontamination procedures to be instigated, minimum
evacuation zone distances and a safe method of shutting down and
isolating the photovoltaic system (either in its entirety or
partially, as determined by risk assessment).

4. Other risk control measures that may need to be implemented in a
fire emergency (due to any unique hazards specific to the site) should
also be included in the ERP.

5. That two copies of the ERP (detailed in recommendation 1 above) be
stored in a prominent `Emergency Information Cabinet' located in a
position directly adjacent to the site's main entry point/s.

6. Once constructed and prior to operation, that the operator of the
facility contacts the relevant local emergency management committee
(LEMC). The LEMC is a committee established by Section 28 of the State
Emergency and Rescue Management Act 1989. LEMCs are required to be
established so that emergency services organisations and other
government and non-government agencies can proactively develop
comprehensive inter agency local emergency procedures for significant
hazardous sites within their local government area. The contact
details of members of the LEMC can be obtained from the relevant local
council.

7. As a Condition of Consent that a Fire Safety Study (FSS) be
prepared for the site and submitted to FRNSW for review and
determination. The FSS should be developed in consultation with and to
the satisfaction of FRNSW.

For further information please contact the Fire Safety Infrastructure
Liaison Unit, referencing FRNSW file number BFS19/545. Please ensure
that all correspondence in relation to this matter is submitted
electronically to [email protected].

Thanks for the referral.
I've looked at the documents and there are no State Heritage concerns
in relation to the proposed development.
DPE does not need to refer this project, including any future
modifications, to the Heritage Council (i.e Heritage Division of OEH),
however other Divisions of OEH may respond separately in relation to
Aboriginal Cultural Heritage or biodiversity.

Bland Shire Council is fully supportive the Lightsource BP West Wyalong
Solar Farm project and we have attached our submission.

Comments attached.

Comments attached

Comments attached

Comments attached

Comments attached