My objection relates to protection of this special country area and its environment

Project is not appropriate for this area .The environmental and social impacts will have devastating impacts on this wonderful natural area. Similarly the aesthetics of this project will be detrimental.

Nundle is a beautiful rural community and a windfarm will ruin the ambience of the area, it will be noisy, it will kill birds and it will make life noisy for the residents.

I object to the proposal to install a wind farm at Nundle (Hills of Gold Wind Farm) because I believe that it is important that we preserve places of great beauty in Australia and that the area of Nundle is not the place to put an ugly windfarm. This windfarm will destroy the charm of this village and will become an eyesore to the community. I object strongly to this windfarm also to protect the bird life which is abundant around this town. Nundle is of great significance to the tourists who love to stop on road trips and see the natural beauty and serenity of the township. This will be taken away by the installation of these ugly and imposing turbines. I would like this town and the beauty and charm to be preserved at all costs. Thank you for reading my submission.
Kim Bergin

1. From the outset, I am not an opponent of renewable energy but believe such proposals should be located in appropriate locations. In relation to the site proposed for this project I have grave concerns for strategically important biodiversity of the region, the environment, endangered species, water catchment area, heritage and visual amenity.

2. Old growth trees which are habitat for a number of endangered species including Koalas will be impacted by this project. The main property owner and proponent preempting an approval by the NSW Government, has already cleared many trees along sites proposed for turbines harming the precious biodiversity. When the project is expired there has been no proposals by the proponent for subsurface remediation or bond retained to remediate the area, so the large concrete and steel pads and indeed redundant turbines are retained in the earth and the precious native vegetation and wildlife habitat gone forever. This needs to be addressed now, not in 30 years time and several owners/operators later.

3. There are impacts on tributaries that flow into either the Peel or Barnard rivers such as contamination and erosion, impacts on heritage - Black Snake Mine and impacts on visual amenity. There should be sensible sighting of large-scale renewable projects, not large expanses of renewables on ridge lines, particularly as beautiful as those at Hanging Rock and Nundle.

4. The project is unlikely to realise the economic bounty promised to the Hanging Rock and Nundle communities, construction workers and contractors are likely to be FIFO, not sighted locally and the projects annual Community Enhancement Fund of $2,500 x 70 turbines will be shared between at least three local government areas.

5. In summary I believe the applicant has not addressed the impacts on the Nundle and Hanging Rock communities during construction and operation; biodiversity considerations; native flora and fauna; the environment generally; the need for removal of large quantities of native vegetation; the large quantity of water for construction of the concrete turbine pads given the relative scarcity of the resource; bird and bat strike by the turbine blades during operation; visual amenity; heritage - destruction of the Black Snake Gold Mine; safety of proposed roads in the vicinity of the Devils elbow; access of vehicles through private properties; impacts on water catchments - Peel and Barnard rivers and McDivitts creek; the paltry figure proposed for the Community Enhancement Fund per turbine over three local government areas; the number of jobs promised during construction and operation; community support for the project. I believe the project has adverse impacts on the land of high biodiversity significance, heritage and tourism that ultimately requires the protection of aesthetic values and includes land identified as critical habitat under the Biodiversity Conservation Act, 2016 and the project should be rejected.

A wind farm will be a scar on the face of the earth of this beautiful area. The developer has lied saying that it will not proceed if there was community objection, but it wants to go ahead anyway regardless of community objection. The land in the area is sensitive.
Wind farms generally kill the birdlife and the noise they make is dangerous to humans.

Key objections

While currently not a full-time resident of Nundle township, I am a landholder and ratepayer, and therefore a key community stakeholder and interested party in the proposed Hills Of Gold Windfarm.

I object to the proposed development, though I wish it to be noted that I am an active supporter of and for, renewal clean energy production and believe that we must rapidly move to suitable energy sources, including solar and wind, if we are to protect and ensure the longevity of our planet and ecosystem for the future.

There are five key areas of impact to which my objections relate – biodiversity, Aboriginal cultural heritage, social and economic considerations and traffic and transport. I have outlined my key points of feedback under each point below.

In addition I have made some comments on stakeholder consultation.

Biodiversity impact
- Key areas of concern relate to potential impact on the 18 bird species and 33 animal candidate species, specifically the wedge-tailed eagle, nankeen kestrel and multiple species of bats.
- I do not believe adequate consideration of impacts to bird and animal habitat, either during construction or operation phases has been fully considered, in particular impact risk. Of the research that has been conducted the outcomes are not acceptable. Few, or in some instances no, mitigating actions been put in place to ameliorate or lessen these impacts.
- In particular the eagle and kestrel are synonymous with the region’s visual landscape and a key asset. 0.98 impacts for kestrels and 5.86 impacts for eagles every year are simply unacceptable. Over the lifespan of the project this will decimate these vital and majestic bird populations.

Aboriginal cultural heritage impact
- As per the research conducted and consultation with indigenous community members, there are multiple sites of cultural heritage within the area of the project
- The project should not progress unless it has the full support of relevant elders and indigenous community groups, in particular those who have moral and cultural links to, and therefore ownership of, the land

Social and economic impact
- Key areas of concern relate to the lack of full consideration of potential impact to the natural beauty and historic significance of the region
- While case studies of previous wind farm projects have been utilized as mechanism to outline positives of like projects, Nundle is unique
- Specifically, it has a significant and proven reputation as a town that is able to attract and retain tourism and temporary and permanent residents (including a growing arts and culture community), creating a rich and vibrant socially viable and sustaining community
- People are primarily drawn to the area for reasons that relate to its natural environment, visual beauty (in particular the hills) and its uniquely regional attributes. These aspects that make it unique will be impacted by the project both during construction and operation phases. These are attributes that cannot be mitigated for, nor can be compensated for

Traffic and transport impact
- While there are general concerns on the impact to the town on the chosen transport route, I wish to specifically address my comments to impacts that relate to the proposed alternative transport route through Nundle
- This route potentially impacts the current vacant land, which I own, which is under planning phase for development
- In particular there are two major concerns:
(1) Firstly, the proposed removal of two ornamental flowering trees adjacent to the property (corner of Innes and Gill streets) – this stand of trees are a unique flora asset to the town and feature on many promotional images. They are subject to a protection caveat that ensures their longevity. They are a key reason why the land was purchased and are a key feature of the proposed future development for the land
(2) Secondly, the route will impact the land itself and future potential residents / visitors (a) visually, especially during 18 -24 months of construction phase (b) physically, through the proposed use of the land (corner of Innes and Gill streets) by the project for a permanent easement to allow for transport and blade overhang.
- Both of these impacts significantly limit the development options and timing of development for this land, having an adverse impact on both the attractiveness of the land and its surrounds and therefore diluting the rationale for and value of, the proposed dwellings and land usage and flow on benefits to the community

Stakeholder consultation
- While project documentation summarizes key aspects of community and stakeholder consultation for the project and a consultation hub has been established for a period in Nundle township, no, or limited efforts were proactively made to consult with me.
- As a ratepayer and non-residential community member, more effort should have been made to ensure that proactive consultation was extended to all parties.
- That said, I do acknowledge the subsequent advice and information provided to me, upon request, from both the Tamworth Regional Council and Someva Renewals Community Development Manager.

I strongly object to the proposed Hills of Gold wind development for the following reasons:

• The project has been “sold” to Engie long before the completion of the approval process. This brings into question the validity of the approval process and the Department of Planning, Industry and Development (DPIE). It appears, as with other wind developments, that the project is a done deal and is merely ticking boxes to satisfy requirements.
• Nundle is one of the most beautiful landscapes in NSW and it is an historic town. This development will destroy this landscape for decades. We should be preserving the country that is left undeveloped.
• I have had anecdotal discussions with a group of caravan travellers. They have said that if this project is approved they will remove Nundle from their annual list of places that they visit.
• It appears that the only support for this project is with the property owner who will benefit financially through payments for the turbines located on his property.
• One must only read the headings of the EIS to see the multitude of potential areas of impact. This indicates that there is too much potential for damage to the environment and for the people living in the area to allow this project to be approved. Even if only some of these areas are impacted it adds up very quickly to an unacceptable level.
• I have read the list of complaints that have been made by the community concerning the Crudine Ridge wind development. These complaints concern road use during the construction phase and consistently report contractors behaving badly (speeding) and heavy vehicles damaging property and fencing on access roads. Hills of Gold is a much larger development and will have a bigger impact.

Also, traffic impacts along the proposed transport route through Muswellbrook LGA along Wybong, Kayuga and Dartbrook Roads. These roads are not suitable for oversize and long loads. These roads are also very busy during shift change with mine workers using these roads when oversize loads are expected to be using these minor roads. Even with significant modifications the roads are not suitable. A condition should be imposed that the ENGIE contribute to road network upgrades within the Muswellbrook Shire LGA transport route. From my review of the ENGIE engagement register no consultation has occurred with Muswellbrook Shire Council and this is a concern.

This community has been outspoken and very clear. They do not want this development. The approval process and the DPIE should listen and NOT approve the Hills of Gold development. I find it deeply concerning that this project has been progressed and those who will be affected are being ignored.

Overall, there is absolutely nothing that can be said about this project that is positive. Turbines cannot be hidden. They are too large. We don’t know enough about the impact of the sound of the turbines on the health and wellbeing of people or animals. The payments that are being offered to compensate neighbouring landowners are laughable. Property values will and do decrease by a significant amount.

Submission to NSW Government Planning, Industry and Environment in response to Hill of Gold (SSD-9679) Notice of Exhibition.

I submit this response both on behalf of myself and our Family Farming operations trading as CJ and MC Eagles.

We object to the planning submission due the land category of the development site being unsuitable to support a Project of this size and scale.

The EIS Appendix O Soils and Water Assessment, would indicate that almost the Entire Project Area Land is assessed as Very Low to Extremely Low Capability Land (F4-2).  Very Low and Extremely Low Capability Land is highly susceptible to severe erosion and degradation.  This category Land should be left “undisturbed” and there should be no (extreme) or minimal (very low) disturbance of native vegetation.  Why is an area with such Low Land capability even being considered for a Project of this scale and impact? This is extremely serious.

Disturbance of this Category of Land will make the area highly susceptible to Erosion, Mudslides and Landslides. There are residents living on the Creeks below the steep escarpment leading up to the proposed development site.

Worse still, each Turbine is 230M tall. These will most likely be the tallest Wind Farm Turbines in Australia.

For comparison, there are only 5 buildings in Sydney CBD greater in height than each Turbine. The Crown Tower (271M), Chifley Tower (244M), Citigroup Centre (243M), Deutsche Bank (240M) and Greenland Centre (237M) are higher.  These buildings are largely at Sea Level. In NSW the Mt Piper (Elevation 946M) and Bayswater (Elevation 210M) Power station Chimneys are 250M and so higher.  Essentially these Turbines will be the 8th Tallest structures in NSW. Well, technically, they will be the 8th through to the 78th Tallest structures in NSW, given there are 70 of these Turbines.

In very simple terms, this Project is planning to build 70 of the 8th Tallest Man made structure in NSW on land that is categorised as Land that should be left “undisturbed” and there should be no (extreme) or minimal (very low) disturbance of native vegetation

As a former Senior Engineer and having Directed many major constructions in my former career, I am horrified that any organization would even consider a construction of this scale, on Lands that can in no way support the scale and enormity of this development. Their own Soils EIS is damning for this Project.

As background:

In Appendix O, P 312, of the Soils and Water Assessment, the Table 16-3 Land and Soil Capability (LSC) Scheme Classification (OEH, 2012) shows ratings used to understand the capability of land uses with LSC Class ratings 1-8, with 8 being extremely low capability land.

The EIS catalogues the following:

• north and west facing slopes of the Project ridgeline as the LSC rating of 8 – 8 being extremely low capability land with “limitations so severe that the land is incapable of sustaining any land use apart from nature conservation. There should be no disturbance of native vegetation”.
• western portion of the Project is a mixture of LSC 8 and 7 – 7 being very low capability land, with “severe limitations that restrict most land uses and generally cannot be overcome. On-site and off-site impacts of land management practices can be extremely severe if limitations are not managed. There should be minimal disturbance of native vegetation”.
• South eastern corner of Project is predominantly rated at LSC 6 and 7 – 6 being low capability land with “very high limitations for high impact land uses. Land use restricted to low impact land uses such as grazing, forestry and nature conservation. Careful management of limitations is required to prevent severe land and environmental degradation”.
• eastern ridgeline of the Project has a mixture of LSC ratings of 3,4 & 6- having moderate to severe limitations. The Figure of this section is believed to align to the area of Morrisons Gap Rd and Shearers Road. The Figure clearly shows only a LSC 6 rating for that area with no pockets of 3&4 (moderate and high) at all. This is an inaccurate statement in the EIS according to their own data as seen in Figure 16-2.

The Figure 16-2 in Appendix O shows the entire classification scheme of LSC capability of land to be developed under this Project. The data in the map shows that the entire Transmission line will be built on land rated at an LSC 8 - “limitations so severe that the land is incapable of sustaining any land use apart from nature conservation. There should be no disturbance of native vegetation”.


THE DATA WITHIN THE EIS, AS SHOWN IN THE LAND AND SOIL CAPABILITY TABLE CONFIRMS THAT THE ENTIRE PROJECT AREA – DEVELOPMENT FOOTPRINT AND TRANSMISSION ROUTES – CANNOT PROCEED.

EVERY CATEGORY OF LSC FOR ALL PARTS OF THE PROJECT CLASSIFIES THE SOIL AND LAND AS HAVING “SEVERE – VERY HIGH LIMITATIONS” TO NATIVE VEGETATION AND SOIL DISTURBANCE.

THE LAND USE IS RESTRICTED TO GRAZING AND NATURE CONSERVATION ONLY.
THESE CLASSES OF LAND HAVE EXTREME ERODIBILITY AND LAND SUBJECT TO SEVERE WIND EROSION WHEN CULTIVATED OR LEFT EXPOSED.

If the soil and land as seen in the LSC assessment cannot take cultivation by a plough, it most certainly cannot be subject to major construction, road building, heavy vehicle and machinery impact, deep digging and extraction to name just a few of the impact on the soils and land. Please note that each turbine requires a “Gravity Foundation in which an area is excavated suitable to support the burying of a “pedestal”design of concrete and reinforced steel….these are typically 3-5 m deep and 25 m in diameter” (EIS P 42).

The risks of erosion leading to landslides is extremely high and given the topography of the Development Footprint area, with cliff faces and slopes from the ridgeline, the outcomes of any landslide could be catastrophic. ON THIS BASIS A WIND FARM CANNOT BE CONSTRUCTED AT THIS SITE.

In the EIS P 320 under Mitigation Measures has as its first point, to address potential impacts to soils and water, the following:

“Preparation of a detailed Soil and Water Management Plan (SWMP) prior to construction commencing. The SWMP should be prepared by a suitably qualified person, such as a soil conservationist.”

What sort of a Project could be approved when the EIS itself proclaims it has not undertaken any sort of assessment by a suitably qualified expert on the impacts on the soil and water and their management. Given what its desktop data on the Land and Soil Capability alone is telling it, it is an abrogation of responsibility to not have conducted any proper expert assessment.

We object to this Project on the basis that the land use classification assessed under the Land and Soil Capability (LSC) Scheme Classification (OEH, 2012) shows the site to be totally unsuitable for construction of a wind farm, being suitable for grazing and nature conservation only.

This is the last place on Earth that you should clear and build 70 of the 8th tallest man made towers in NSW. Doing so is complete folly and will place the entire local community at risk.

This Project should be rejected and a more suitable site found.

I have always enjoyed visiting Nundle & Hanging Rock for the tranquility & peacefulness. The views of the unspoilt countryside are spectacular.
Green energy at the price of destruction of the beautiful green environment should not be allowed
Nundle/ Hanging Rock is not the place for a wind farm.
Preservation of the environment should be paramount.
I OBJECT to the proposed wind farm.