Pages tagged "Submission"
RE-Alliance submission for the NSW Renewables and Agriculture Review
Both the energy and agricultural industries, essential to our livelihoods in Australia, are facing a rapid pace of change and many intersecting challenges leading into the next decade.
In this context, we believe that the government has a responsibility to be an active leader in planning and expectation setting at a statewide and a local level.
We are pleased to see that the Discussion Paper demonstrates a thorough understanding of the emerging issues around hosting renewable energy projects on agricultural land.
Our submission outlines four key policy recommendations for the Commissioner to consider, and following this, comments on the discussion questions set out in the Paper.
We have been working in the Central West Orana Renewable Energy Zone (REZ) to understand community and landholder priorities and concerns.
Many of our comments in this submission draw on the conversations and experiences we’ve had as part of our work there.
Four Priority Recommendations
1. Urgent and direct investment in local REZ engagement
RE-Alliance has been working in the Central West Orana REZ to understand community and landholder priorities and concerns.
Often, we have played the role of engagement consultant and community educator due to the lack of information and sense of overwhelm among impacted landholders.
The regulatory framework for REZs is complicated. There are no drop-in centres or local officials to guide landholders and the community.
The Government website detailing the REZ system has little relevant information for locally impacted landholders and is difficult to navigate, containing many acronyms and dense concepts that are time-consuming to grasp.
Attempts to engage the community over the Central-West Orana Transmission Line by Transgrid and by EnergyCo have been poor. Information has not been timely, accessible or detailed.
We believe this lack of communication, transparency and on-the-ground personnel will, if left to continue, result in further distrust of the government, and erode the goodwill and support for renewable energy in the region.
RE-Alliance recommends the NSW government, as a matter of urgency, directly employ at least three well-qualified, full-time staff in every REZ, with a mix of relevant experience, such as agriculture, NSW planning processes, community development and community engagement.
We recommend these staff run REZ information centres to:
- provide accessible information about the development of the Renewable Energy Zone
- host regular information sessions in different parts of the REZ, tailored to different groups including landholders, small business owners and environmentalists
- Provide information for landholders, and where appropriate, provide referrals to professional services, about how to navigate contract negotiation with renewable energy developers
- Assist with local engagement on transmission planning
- provide information to local businesses on how to plan for and get the most out of REZ construction
- allow developers to display information on their projects in centralised locations
- engage the community to identify targets for community benefit programs.
- maintain up-to-date online information about each REZ including maps showing projects and timelines for development
- Provide a conduit for local views back to EnergyCo and relevant government departments.
2. Establish an independent, statutory authority like the Latrobe Valley Authority
Independent, statutory authorities to support local-led planning have been very successful in the Latrobe Valley in Victoria, as well as overseas.
The Latrobe Valley Authority employs around 40 experts in the region to coordinate local councils, industry and community groups to identify opportunities and priorities specific to their region.
The Authority was modelled on similar institutions in Germany.
An independent, statutory Authority like the Latrobe Valley Authority for each REZ would support people to become active participants in the transition, rather than subjects of it. It would provide visibility of, and access to decision-making processes and be an authoritative source of local information about the rollout of renewables in the region.
Civil society organisations have been increasingly vocal in their calls for more of these types of bodies in Australia.
The Next Economy, an organisation that has been strongly advocating for these types of institutions in Australia, explains that local statutory authorities have three main functions:
- The first responsibility of a transition authority is to facilitate long-term regional planning and coordination to reduce the negative impacts associated with the phase out of fossil fuels and to facilitate new economic opportunities.
- The second main role of a transition authority is to ensure that all stakeholders can meaningfully participate in decision making processes and in the design of new plans and programs to decarbonise the economy, and that they remain informed and able to participate as change unfolds over time.
- With a strong regional presence and working relationships across different sectors and levels of government, the third responsibility of the transition authority is to be across all aspects of the energy transition to enable the flow of information and to enable effective, timely and regionally appropriate investment and action.
There are many models and examples of such bodies overseas, and a small handful in Australia. On the question of whether regional, state or federal transition authorities should be established in Australia, participants in The Next Economy’s analysis preferred a state level body that could fund and ensure the coordination of regional offices, emphasising that while coordination is a key function of the authority, planning and decision-making must not be top-down.
The Hunter Jobs Alliance last year published a report calling for a Hunter Valley Authority, exploring a potential model for its establishment.
RE-Alliance recommends that the NSW continue to lead the country in its energy transition by establishing an independent, NSW Regional Transition Authority to coordinate local offices in each Renewable Energy Zone, taking on board the analysis from The Next Economy and the Hunter Jobs Alliance about what such a body should include, as well as lessons from the Latrobe Valley Authority.
3. Fund pilot projects and research into agrisolar
The NSW government can improve the compatibility of renewables with agricultural land by providing incentives for co-location—payments made to both farmers and developers using land in a way that produces energy and food at the same time.
There are some examples of co-location of agriculture and solar generation in Australia, as identified by the CEC Agrisolar guide.
Co-location of solar and sheep have anecdotally increased the carrying capacity of grazing land by providing shade that is good for sheep and grass growth, but more research is needed to establish what settings can optimise this practice in Australian environments.
Likewise, intermittent shade provided by panels could be beneficial for some crops in some environments, however trials are needed to find workable models that can be replicated at scale with confidence.
There are currently no incentives for developers to trial co-location practices.
RE-Alliance recommends the NSW government support the agricultural sector by incentivising co-location and prioritising projects that trial innovative solar cropping and grazing methods. Such a program would see the NSW government reduce land use conflicts and facilitate innovation within the renewable energy and agriculture sectors.
4. Fund independent Land Use Officers to support host and neighbouring landholders with lease contracts
Landholders are often busy farmers and graziers, and are finding themselves having to deal with an increasing number of renewable energy developers seeking to secure lease contracts that will enable them to develop a project in the REZ.
Contractual leases for renewable energy projects are complex, with many land use considerations included. Landholders often require expert support to undertake this contract negotiation process, and legal experts with experience with these types of contracts are in high demand, often unable to take new clients.
This expertise is not just necessary for host landholders but also for neighbours. Even where they are not signing agreements with developers, neighbouring landholders also have to negotiate changes to insurance and other arrangements, for which professional assistance is also required.
Ideally, the NSW Large-Scale Solar Guidelines would be thorough and give landholders confidence they will be treated fairly. Our submission to the revised guidelines details some provisions we considered were missing.
When NSW’s Renewable Energy Action Plan was released, implementation of the Plan was supported by a network of renewable energy extension officers employed regionally, who provided information about local renewable energy opportunities, the planning system, and support available from the NSW Government. Unfortunately these positions were just short-term.
RE-Alliance recommends that the NSW Government fund a network of independent land use officers across regional NSW to provide assistance to both host and neighbouring landholders.
These officers would provide a range of advice to landholders, including about new transmission routes and renewable energy developments, and importantly, the range of impacts landholders must consider when entering into lease negotiations.
The officers could produce resources and be available to landholders via information sessions and a hotline for information and advice.
Submission to the Victorian REZ Development Plan Directions Paper
Download full submission in PDF
Introduction
RE-Alliance welcomes the Victorian government’s leadership in investing in Renewable Energy Zones and creating VicGrid. The Victorian government is correct to note that unacceptable delays in critical network investment threaten the security of the state’s electricity system and frustrate the timely decarbonisation of the state’s economy. The REZ Development Plan Directions Paper reflects the work needed to decarbonise Victoria's grid in line with AEMO’s most ambitious modelling.
We thank the government for centring community engagement and benefit-sharing as a key component of VicGrid and in the rollout of renewable energy zones.
Social licence at a local level for renewable projects is a critical pillar of the transition to clean energy. All new electricity infrastructure brings impacts for local communities. Engaging effectively and ensuring significant financial benefits accrue to impacted communities are essential first steps to securing social licence. In Victoria, we’ve seen ideological opponents to renewables leverage local frustrations towards wind farms in strategic ways so as to colour the policy environment and obstruct progress to a lower emissions future. While we consider much of this is behind us, we are wary of the potential for the much-needed large scale transmission projects to cause a similar type of obstruction to REZ rollouts across the eastern states.
Poor planning and holes in communication with project neighbours can have significant negative consequences, and even threaten the success of renewable energy zones. An example of how poorly this can play out can be seen recently in Germany, where interventions in the network have led to social licence issues and delays in meeting climate targets.
“The first thing that came to my mind when I saw the data in the ISP was Germany’s build-out of transmission infrastructure, and how it has drawn significant backlash. This backlash has made new German interconnection more expensive and badly delayed, and that has delayed the build-out of renewable energy and is impacting Germany’s ability to meet its climate targets”.
Over the last seven years, our organisation has been working in this intersection between renewable energy projects and local communities, assisting wind farms to build bridges with local communities through benefit and profit-sharing arrangements. This typically takes the form of community enhancement funds that provide grants to local community groups and neighbour payments schemes. However, we have seen a great variety of innovative models. In particular,
- RE-Alliance is currently facilitating a combined fund vehicle to bring together project-based wind farm community enhancement funds across the Moyne Shire
- Community members are able to co-invest in large wind farms at Sapphire, Coonooer Bridge and Kiata Wind Farms.
- Construction of a solar and battery-based mini-grid for residents around the Dundonnell Wind Farm.
- Simultaneous support for local business and project neighbours through a Neighbourhood Benefit Scheme. Residents around the Mortlake South Wind Farm receive gift cards that can be redeemed only at local outlets.
We hope the combined fund model we have developed which uses on-the-ground experience to enhance social licence at a local level is of interest to the government. We would be happy to discuss our work further with the Department. Our goal is to make sure the transition to renewables delivers meaningful opportunities for community enhancement to communities across regional Australia. This work will assist in creating the policy settings, the expectations and best-practice knowledge on how to deliver a just transition for regional communities.
Summary of Recommendations
RE-Alliance makes the following recommendations in regard to how VicGrid engages with local communities:
- embed consideration of social licence in REZ Development Plans
- establish a benefit and coordination framework;
- create a new engagement and benefit guide;
- establish REZ coordinators;
- recognise the critical role of Traditional Owners in the process; and
- ensure VicGrid communicates the energy transition to the community.
Submission to the Tasmanian Government on the Draft Renewable Energy Coordination Framework
Download full PDF of Submission
Summary of Recommendations
- An auction process for Tasmania could be valuable to coordinate development geographically and over time, set standards for the best community outcomes and enable coordination of community benefits.
- Tasmania should adopt best practices in terms of biodiversity protection.
The Government should consider aligning community benefit programs with existing social policies, such as those identified in Council strategic plans. - RE-Alliance supports the need for a review of the Environmental Management and Pollution Control Act 1994 to determine whether projects such as large scale solar farms, transmission lines, pumped hydro and hydrogen should be listed as activities requiring EPA Tasmania assessment.
- RE-Alliance supports the establishment of a coordinator role. The role’s mandate should be clearly specified.
REZ planning should prioritise social licence by stipulating best practice community engagement and delivering effective benefit sharing mechanisms. - Re-Alliance would support further investigation by jurisdictions on how benefit-sharing programs for transmission projects can be managed given the current focus on economic efficiency within the Regulatory Investment Test for Transmission (RIT-T) based on the NEO.
RE-Alliance recommends that the Government provides legal and technical support for the coordinated community benefit fund in each REZ. - RE-Alliance recommends that the Government provide legal and technical support for renewable community co-ownership, co-investment and community ownership.
- RE-Alliance recommends that the Government provide support for a collaborative approach between scheme providers by creating a social licence working group in Government tasked with investigating opportunities in planning, construction, and operational phases.
- RE-Alliance recommends that Traditional Owners are recognised as key stakeholders to be consulted during the development and benefit sharing process.
- RE-Alliance recommends that the Tasmanian Government draws on the experience and resources created by other jurisdictions to create a Community Engagement and Benefit Sharing Guide outlining best practice for the Tasmanian context, referring to other relevant frameworks as necessary.
- RE-Alliance recommends that the Tasmanian Government establish the role of community educator to help communicate and articulate why the REZ is important for social, environmental and economic reasons. This function could be incorporated in the Renewable Energy Coordinator role.
Submission for the Victorian Changes to the Regulation of Wind Farm Noise
25th February 2021
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 benefits for regional communities.
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Submission re the Draft Brolga Assessment and Mitigation Standards
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.
Submission Consultation Paper on the Second VRET Auction
October 2020, 2020
The Australian Wind Alliance (AWA) 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, and members of the community, including many neighbours to existing wind farms. The Wind Alliance encourages best practice community engagement and benefit sharing as keys to maximising benefits to regional Australia and lowering Australia’s carbon emissions.
Read moreSubmission - ESB REZ Planning rule change
Renewable Energy Zones Planning Discussion Paper
Responding to http://www.coagenergycouncil.gov.au/publications/energy-security-board-renewable-energy-zones-planning-consultation
8 September 2020
About Australian Wind Alliance
The Australian Wind Alliance (AWA) 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, and members of the community, including many neighbours to existing wind farms. The Wind Alliance encourages best practice community engagement and benefit sharing as keys to maximising benefits to regional Australia and lowering Australia’s carbon emissions.
Read moreSubmission to NSW DPIE - Uungula Wind Farm
Wednesday, 8th July 2020
The Australian Wind Alliance (AWA) is a community based organisation of around 500 financial members, with an extensive supporter, online and social media following. Our members include farmers, small businesses and members of the community. The Wind Alliance encourages best practice community engagement and benefit sharing as keys to maximising benefits to regional Australia and lowering Australia’s carbon emissions.
Read moreSubmission - Technology Investment Roadmap
21 June 2020
Submitted to consultation process for Australia's Technology Investment Roadmap
Introduction
The Australian Wind Alliance (AWA) 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, and members of the community, including many neighbours to existing wind farms. The Wind Alliance encourages best practice community engagement and benefit sharing as keys to maximising benefits to regional Australia and lowering Australia’s carbon emissions.
Australia is a carbon-intensive economy that has been left ill-prepared to adapt to the zero carbon world that will be required by mid-century at the latest if we are to avoid catastrophic climate change. After years of inaction on climate change, the challenge we face to rapidly restructure our economy is massive. Any climate policy instrument on the table in 2020 must start by acknowledging the size of this task and responding with the appropriate level of urgency. This must be reflected in a single-minded focus only on those solutions that will contribute the adequate level of emissions reduction in the time frame required. False solutions that see existing carbon-emitting technologies extended and avoid doing our utmost to drive adoption of carbon-reducing technologies lead us down the wrong path.
Read moreSubmission - Rye Park Wind Farm Mod 1
3rd June 2020