The selection criteria for a potential proposed project site may be based on a wide range of factors, including the available wind or solar resources, proximity to existing transmission infrastructure, the potential for securing landowner arrangements and other approved development in the area. It should also include the likelihood or, conversely, the degree of difficulty of engaging with the community and gaining community support.
Current transmission infrastructure was originally planned, designed and built many years ago based on the location and availability of the then existing energy resources (such as coal, gas and hydro), which, at that time, did not envisage the significant shift to large-scale renewable resources such as wind and solar energy. These relatively new resources are often optimally (in all other respects) best located in different geographies and often well away from existing grid infrastructure.
Prospecting developers are not generally restricted in initiating a new project on a particular site and almost always pursue sites that are very close to existing transmission infrastructure. Developments often commence by prospectors initiating discussions with adjoining landowners at a transmission optimal site to seek their agreement to host the project. However, because existing transmission infrastructure is often located near communities, lifestyle dwellings and primary producers, prospective and developed wind and solar farms are more likely to be located in areas that will cause friction with neighbours and communities.
AEMO’s Integrated System Plan (ISP) provides a detailed roadmap for the transition of the electricity grid. However, there is no corresponding plan for electricity generation that details the preferred location, type and scale for proposed generation plants. The Renewable Energy Zones (REZs) being pursued by some states go part way to address the location dimension of a generation plan but may not specify the type and scale of the asset. Further, there are no guarantees that a prospector-developed project site within a REZ area will actually be developed into a generation asset within a required timeframe or at all. Meanwhile, the prospector will likely still have control of the land.
Similar to the mining industry, the offshore electricity infrastructure legislation, recently passed in the Federal Parliament, requires the Minister to first declare an offshore area to be suitable for offshore electricity infrastructure projects, which includes offshore wind farms and other renewable energy generation infrastructure. In deciding whether an area is suitable for development, the Minister will consider the potential impacts of such activities on other industries, the environment, the electricity generation capacity, and the potential demand for such projects in state and territory planning.
Potential proponents may then, via a competitive process, apply for a ‘feasibility’ licence to undertake exploratory and scoping work. Once feasibility work is completed, the licence holder can apply for a ‘commercial’ licence, which permits the licence holder to construct, install, operate, maintain, and decommission commercial scale offshore renewable energy generation projects (such as wind farms).
All things being well, the proponent is then issued with an operation license to build, operate and decommission the project. But if the proponent fails to meet key milestones in, say, the feasibility stage, they may well lose their right to the site and have their license terminated – making way for another proponent to step in.
The Commissioner’s experience to date indicates that there is a much higher likelihood of community issues and concerns to contend with when a proposed or operating project is located near or amongst more populated areas. Often, the more populated areas correlate with accessibility to transmission infrastructure, however, they can also result in a very large number of neighbours who will ultimately reside in close proximity to multiple turbines or solar arrays.
Further, there may be multiple proposed (and/or existing) projects in a given area, with the potential for residents to be ‘surrounded’ by projects – if such projects were to proceed. These scenarios could lead to a range of compounding issues for residents, including construction impacts, impacts from noise, visual amenity and potential economic disparity or loss. There is also the possibility that large-scale projects may be proposed adjacent to environmentally sensitive areas, such as designated areas of high value habitat, National Parks or World Heritage Areas.
Impacts may be further compounded if project construction timeframes overlap, placing enormous pressure on local resources and infrastructure, in addition to the usual annoyances such as construction noise, traffic, road damage and dust. There can also be other severe cumulative effects during the construction of more than one project in a specific locality, such as placing enormous pressures on roads, resources (such as gravel), meal providers, accommodation and skilled tradespersons.
Based on our complaint handling experiences, we have found that locating wind turbines on the top of hills or ridges, while optimum for capturing the wind resource, can have greater impacts on visual amenity, and may lead to specific noise and shadow flicker scenarios for residents in the valley beneath and may have other associated impacts on the community. Access roads for hill and ridge wind farms can also be obtrusive and significantly damage and constrain the remaining available farming land in the area.
Conversely, there appear to be minimal issues raised to date about wind farms that are located on large land holdings or on flat or slight to moderate undulating land and sites that are well away from neighbours and towns (noting comments made earlier regarding landowner and neighbour agreements in subsections 1 and 2 of this Appendix).
Similarly, solar farms are best suited on flat ground, where the surrounding topography is also on minimal undulation. Such siting can avoid visual impacts, including glare, glint and view impacts on prospective neighbours.
Route options for long distance, high voltage transmission lines should also take into consideration impacts on landholders, neighbours and community. Where possible, existing easements should be used (including uprate options) or, if a greenfield route, selecting routes well away from more highly populated areas and smaller landholdings.
Location, capacity and availability of accessible transmission lines remains a significant challenge for the renewable energy industry. A number of more recently completed projects have discovered, upon connection to the grid, that there is insufficient available capacity in the existing transmission line for the project’s generational output to be delivered – resulting in significant curtailment of the generation asset. A number of large-scale solar projects have experienced this situation, as these projects tend to be in more remote locations in order to capture the optimal solar resource.
Again, it may be prudent for developers to engage early with AEMO and transmission operators to ensure that the planned project’s output can be fully accommodated and taken into consideration for AEMO’s Integrated System Plan. But fundamentally, there needs to be an integrated approach to grid and generation planning and mechanisms to execute on that combined plan in a coordinated way.
Optimising site locations
There may be opportunities to select and prioritise projects in the current pipeline based on an increased likelihood of acceptance of the project by the surrounding community. With the increase in development and construction costs, the ongoing grid connection/capacity issues and the declining value of large-scale generation certificates, not all projects in the development pipeline are expected to go ahead. There is an opportunity to select projects that meet other key parameters, including economic and regional development goals, while also selecting sites that are optimal from a community impact perspective.
Recent state and territory government initiatives, such as the identification of Renewable Energy Zones (REZs) in New South Wales, Queensland and Victoria, as well as the VRET Program (Victoria), Reverse Auction Program (ACT) and Renewables 400 (Queensland) have enabled governments to become more proactively involved in selecting projects that are located in more optimal areas. These programs also provide a level of oversight to help mandate community engagement programs to ensure minimal or no cumulative effects occur from neighbouring projects. Upgrades to the grid system at a national level may also provide opportunities to explore new locations for renewable projects, such as Project Energy Connect and VNI West.
REZs may need to contend with the issue of cumulative effects as developers concentrate their efforts in the REZ geography to leverage the transmission hub that is to be established. REZ administrators have the opportunity to license or select developers/projects that are most likely to achieve community acceptance as well as minimise cumulative effect issues as an unintended consequence of a REZ.
Given that existing projects have most likely already selected sites for their location, management and selection of appropriate new sites from remaining site options may become more difficult. A more ‘top-down’ approach to selecting proposed projects, together with appropriate long-term planning and deployment of the transmission grid, should assist greatly in managing this challenge going forward.
8.2.1 State/territory and local governments should consider assessing proposed wind, solar and storage energy projects on a wider range of criteria (including the ability for power output to be transmitted and consumed, the suitability of a location from a community impact perspective and the degree of community support) and then prioritising projects for approval or progression accordingly. ‘Reverse auction’ feed-in tariff schemes, such as the schemes deployed by the ACT, Queensland and Victorian governments, and Renewable Energy Zones, are examples of how governments can prioritise and incentivise projects to be developed in preferred locations. These schemes can also promote and motivate best practice community engagement by proponents. Visual amenity guidelines such as the Wind Energy Visual Assessment Bulletin for State Significant Wind Energy Development introduced in New South Wales in 2016 can also restrict development in more populated areas, including assessing the acceptability of multiple wind farms in a given location.
8.2.2 State and local governments may also consider other criteria in assessing and prioritising wind and solar energy projects, including economic development and the ability to both support regional and industry development through improved local electricity supply and infrastructure in regional communities. Appropriate zoning for renewable energy development and overlays for clarifying where it would be appropriate or not appropriate to build and operate projects should also be considered.
8.2.3 Prospecting for new wind, solar or storage development sites could be subject to an ‘approval (or license) to prospect’ requirement issued by the responsible authority before formal prospecting commences. Similar to the recent Offshore Electricity Infrastructure legislation, the approval to prospect a specified potential site would be granted on a range of criteria, including the suitability of the proposed site, alignment with the State’s renewable energy zone strategy, transmission capacity/availability as well as the credentials of the developer and key personnel. See also Recommendation 1.2.10.
8.2.4 As part of the assessment suggested in Recommendation 8.2.1, the responsible authority should have processes in place to obtain and verify clear evidence of the developer’s consultations with affected landowners and residents and be able to assess the likelihood of strong community support for the project.
8.2.5 Once an approved project has materially commenced construction, the responsible authority may need to check other pending or approved projects in the area that are yet to commence construction to ensure any compounding effects on residents, including noise, shadow flicker and visual amenity, have been properly considered in those applications/permits. If necessary and where reasonable, the responsible authority should also have the ability to require a modification to the approved planning permit and layout of those projects that have yet to be approved or have not already materially commenced construction. Background noise level assessments should exclude any noise contribution from a neighbouring operating wind farm for the purposes of applying the noise standard.
8.2.6 State governments should publish and maintain a map of all operating and proposed wind, solar and storage projects, including the location of the project, location of wind turbines or solar arrays, the status of the project (proposed, permitted, in construction or operating) as well as information about the project’s design, including number and size/rating of wind turbines, solar arrays or storage units and information about the proponent. This can be assisted by having appropriate links to the project website.
8.2.7 State governments, in conjunction with the appropriate Australian Government departments/agencies and the Australian Energy Market Operator (AEMO), should review current and planned transmission infrastructure to ensure it allows for new large-scale renewable generation facilities to be connected in the most optimal locations for renewable resources. AEMO’s Integrated System Plan has identified a number of potential renewable energy zones that provides insight and direction for long-term transmission planning. The resulting new and/or augmented transmission infrastructure needs to be planned, built and commissioned in a timely manner. If state government REZ programs are executed well, they should address this recommendation along with the major backbone grid deployments currently in plan.
8.2.8 State/territory governments should consider licensing arrangements and declared areas for onshore generation projects – along similar lines as has been recently legislated for offshore generation development. Prospectors and developers should have time limits for achieving milestones and should not have the ability to control an undeveloped, declared generation project site ad infinitum.
8.2.9 Transmission easements required for actionable projects under AEMO’s Integrated System Plan should be acquired well ahead of time.
8.2.10 There may be opportunities for regulators to clearly outline specific guidance and expectations for project prospectors to comply with in relation to site selection for projects that are likely to impact nearby environmentally sensitive areas.