18 December 2020

RE-Alliance

RE-Alliance formerly known as the Australian Wind Alliance is a community based organisation of around 500 financial members, with an extensive online and social media following. Our members include landholders, farmers, small businesses, climate campaigners, environmentalists and members of the community. Our vision is helping to deliver a renewable energy transformation in Australia filled with sustainable, long-term community benefits for regional communities.

Key Points 

• We welcome the new objective in the draft guidelines, which is to make sure the Brolga population does not become more threatened, at the state-wide level, from the impacts of wind energy facilities.
• We commend the extensive research and field work by Dr Inka Veltheim that has informed the guidelines, as well as the work by other experts from Federation University, Melbourne University and the Department of Environment, Land, Water and Planning.
• Re-Alliance wants protection for breeding sites, more clarity for the community and industry with an improved future for Brolga. 
• We note that wind energy facilities have not been shown to be a “key threat to the Victorian Brolga population” and that “There is no evidence of Brolga collision mortalities from wind turbines.”
• We suggest that the current draft guidelines inaccurately portray the risk profile of wind farm facilities and associated infrastructure and fail to account for different stages of construction and operation.
  • We recommend separating construction and operation phases of wind farm facilities in the guidelines, and 
  • Assessing each activity associated with the wind energy facility separately
  • Having an evidence based flexible approach instead of the prohibition of wind farms and associated activity, while maintaining the objective of the guidelines.
• We suggest reviewing the Transitional Provision to accommodate projects that have already significantly progressed under the  2011 Interim Guidelines or additional arrangement, informed by the evidence.
• Brolga faces many risks and having guidelines only for wind farms may signal that the risks are greater than their impact. We recommend that the wind farm guidelines are used in conjunction with a larger package of policies and regulations that covers all major impacts to Brolga to reverse the historical decline of Brolga pre-wind energy.

Introduction

Thank you for the opportunity to provide feedback on the Draft Brolga Assessment and Mitigation Standards. Our submission is mainly based on a review of the underlying published literature and does not include supplementary field based evidence. Because of this we have provided comments more at a strategic level starting with risks then breeding/flocking habitat buffer,  Transition period followed by other general comments. 

Risks

The rationale for the guidelines states that they are in response to “concerns from the community about perceived impacts of wind farms on Brolgas.” We note that there’s been a concerted campaign in some quarters of the internet and the media that sensationalises impacts of wind farms (Diesendorf 2014). This campaign may translate to a perceived community concern which might be disconnected from evidence based impacts/non-impacts.

As stated in the Brolga Assessment and Mitigation Standards for Wind Energy Facilities Explanatory document notes, “There is no evidence of Brolga collision mortalities from wind turbines.” In addition the Explanatory document notes that “wind farm infrastructure has not been shown to be a key threat to the Victorian Brolga population.” There is no established evidence to infer that Wind farms can increase collision and mortality risk apart from using data from other species which may or may not be appropriate. The other risks identified are from the associated infrastructure which covers a wide range of activity that are not unique to wind farm developments.

Veltheim’s (2019) world-first research at Macarthur Wind Farm demonstrated that there is no link between wind turbines and Brolga disturbance. Veltheim found little discernible impact on Brolga from the wind farm facility in the pre-operation and operation stages(2019): 

“The increased movement distances may have been due to drainage of a wetland within the home range, or due to increasing home range as the chick gets older, rather than wind farm-related disturbance.”

I had a discussion with one farmer who has Brolga and wind turbines on his property and he said the risks outlined in the guidelines were overstated. For instance, Brolga disturbance from cars is unlikely in most instances when cars are simply driving past. Only unpredictable behaviours such as stopping near flocks are likely to impact the birds. While this is only anecdotal, it points to a need for better research.

Recommendation 1: Seek evidence from existing wind farms that coexist with Brolga such as Chepstowe and Waubra Wind Farms. This may show Brolga co-existing with operating wind farms and adaptive behaviour not captured by the research to date.

Breeding and Flocking Habitat Buffer 

Current DELWP guidelines use a precautionary approach in the breeding habitat buffer design. As stated in the Explanatory document p.9 The Brolga Technical Reference Group did not have consensus on the additional 300m disturbance buffer which when combined with the 600m foraging area buffer making a 900m buffer. The impact is assumed and doesn’t consider mitigation measures that may remove risks and population impact. In addition, the breeding habitat buffer design doesn’t consider the different risk profiles of separate activities; the short term construction phase and lower risk long term operation phase.

The buffer for the Brolga no-go flocking areas shouldn't be fixed and should allow adjustments, based on evidence. In addition, some existing wind farms, associated infrastructure and transmission infrastructure (that wind farms need to connect to) appear to be within the prohibited area in Figure 5 of the Draft Brolga Assessment and Mitigation Standards (Standards).

Recommendation 2. To have some flexibility regarding the buffer based on each activity related to Wind farm and associated infrastructure and different risk profile of each. For example, based on timing of construction or measure being taken (time and frequency of driving, undergrounding lines etc). Risk should be assessed on each element of a wind farm’s infrastructure against the objective of the guidelines. The test for mitigation measures could be that they meet the objective of no additional threat to Brolga. This would result in more flexibility in wind farm location, clarity on Brolga location and avoid the need for compensation plans.

Recommendation 3. To modify the Draft Brolga Assessment and Mitigation Standards (Standards) to consider the different phases of construction and operation. When the two phases are separated out in the guidelines it can better capture potential disturbance during the construction phase that wouldn't exist in normal wind farm operation. This could allow, for instance, construction to occur within the proposed breeding habitat buffer outside of breeding season or for different breeding/flocking habitat buffers to apply for different phases.

Transition period

Some projects have progressed significantly and there is uncertainty around timing of the new guidelines and the change in regime. The transitional provision may not capture these projects.

Recommendation 4: We suggest reviewing the Transitional Provision to accommodate projects that have already significantly progressed under the  2011 Interim Guidelines or additional arrangement, informed by the evidence. 

Other comments 

Wind farms and associated infrastructure are far from the main risk to Brolga. As Veltheim’s research shows, 79% the Brolga’s shallow marshes habitat for Brolga has been lost.

One fear of creating a wind farm Brolga guidelines in isolation to other impacts that it signals that wind farms is/will be a bigger impact than what it is in reality.  Veltheim 2019 states, “The main threats to this wetland bird include habitat loss, chick predation and collisions with power lines and fences.” And adds that wind farms “may” be another threat.

Dr. Barry Kentish highlights water regimes and climate change in a 2012 submission regarding Inquiry into Rural Drainage in Victoria. He writes:

The recent decline in Victoria’s Brolga population is attributed to inappropriate land management. The future survival of this threatened population of unique birds is totally dependent on the long term security of specific water regimes for breeding sites. Inappropriate modification of wetlands through ill considered direct or indirect action, such as drainage and changes in water flow, will lead to the local extinction of breeding birds.

And continues:

Climate change is affecting the water cycle in rural environments substantially influencing and altering management of agricultural systems in Victoria.

We recommend that the wind farm guidelines are used in conjunction with a larger package of policies, regulations that covers all major impacts to Brolga. This would ensure that the objective of the guidelines are met and that the decline of Brolga can be reversed. As the South West Victoria Brolga Research Project website states, “The wind energy industry has not contributed to its historic decline in numbers.”

The majority of Brolga habitat is on private land, having wind farms provide an incentive to maintain the current Brolga habitat that may otherwise be drained.

Re-Alliance wants protection for breeding sites, more clarity for the community and industry with an improved future for Brolga. With a plan to combat the key drivers of Brolgas decline, which has not been wind energy, then the decline of Brogla in Victoria can be reversed.