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Offshore Wind Framework Submission

24th February 2020

Submission to Offshore Clean Energy Infrastructure Regulatory Framework Discussion Paper

Please direct any enquiries to:


Andrew Bray

National Coordinator, Australian Wind Alliance

0434 769 463

[email protected]

About AWA

The Australian Wind Alliance (AWA) is a community advocacy group. Our members include farmers, wind workers, local businesses and community supporters. We are independent of the wind industry. Our mission is to stand up for wind power, to build prosperous communities and lower emissions.


AWA is well connected with on-the-ground issues at many wind farm projects and is in a unique position to help find solutions. We see great potential for offshore wind to deliver the same benefits for Australia and for regional communities as onshore wind has over the last 30 years.

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SA Noise Guidelines Review 2019 Submission

Response to South Australian Environment Protection Authority Draft for consultation, Wind farm environmental noise guidelines 2019 

About AWA

The Australian Wind Alliance is a community advocacy group for wind energy with members across the country, who are a mix of farmers, wind workers, local businesses and community members. We advocate for greater uptake of wind energy to deliver economic benefits to regional Australia and clean up Australia’s energy supply. We represent a community voice of support for wind which is distinct from that of industry.


The Australian Wind Alliance welcomes the opportunity to respond to the EPA’s draft wind farm noise guidelines. 

We acknowledge the need for periodic review of the guidelines. Updated World Health Organisation guidelines and the need to keep up with current development practices, such as staged wind farm developments, warrant regular revisions to ensure the guidelines remain appropriate to balance the need for new wind farms and the benefits they bring for local communities with protection of amenity for nearby residents. 

Wind’s strong record in South Australia

We note that since the last review of the guidelines in 2013, up to twenty wind farms have operated continuously in South Australia, with a very low level of complaints about noise. The National Wind Farm Commissioner commenced complaint handling in 2016 and publishes detailed data on those complaints in his Annual Reports. In the 2017 report, he notes one complaint for a South Australian wind farm for the year, without specifying whether or not it was for noise. In the 2018 report, there is not a single complaint for a South Australian wind farm, in regard to noise or any other matter. We can take two things from this: firstly, that South Australian wind farms are successfully operating within the framework set down in the existing guidelines and secondly, that this framework is adequately protecting the amenity of residents living around them. 

The AWA has many members throughout the country who host wind farms on their properties and live short distances, sometimes only a few hundred metres, away from multiple turbines. Their experience supports this record and can be summed up by saying that while they can hear the turbines outside and sometimes even inside their homes, the noise they can hear doesn’t trouble them. 

While there has been significant public correspondence in relation to the proposed Crystal Brook Energy Park, especially in regard to noise, the concerns expressed in much of this correspondence are not warranted when you look at the successful record of South Australian wind farms. As the draft guidelines state: “noise criteria recommended in the guidelines are among the strictest in the world.“ (p4). This should give the Authority pause when considering introducing new provisions or strengthening existing provisions in a framework that has already demonstrating itself as effective and robust.

2.6 Note on infrasound and low frequency noise 

We welcome the Authority’s clear guidance on low frequency noise and infrasound outlined in section 2.6 and expanded on in section 4.7. The EPA’s 2013 study comparing infrasound from wind farms with infrasound found in other environments demonstrated clearly that while wind turbines generated low frequency noise it was at levels that were common in many other safe living and working environments and did not pose any danger to human health. This clarification in the guidelines will be important as long as some pockets of public discussion continue to posit the unproven idea that infrasound from wind farms can be a danger to human health. 

4.6 Tonality, 4.7 Annoying Characteristics

The guidelines specify a 5dB(A) penalty where tonality is shown to be a characteristic of wind farms noise and is audible at a relevant receiver, taking into account the influence of the background. 

Similarly Section 4.7, stipulates that “annoying characteristics that are not fundamental to a typical well-maintained wind farm must be rectified.” 

These are both reasonable measures that ensure wind farm machinery is kept in proper working order to minimise output of tonal and other noise and as such we support their continued presence in the guidelines.

Flinders University paper on Amplitude Modulation (AM)

We note, however, a recently published paper by Hansen et al, “Prevalence of wind farm amplitude modulation at long-range residential locations”, which posits high levels of ‘tonal amplitude modulation’ around a single wind farm. While the Authority may be urged to alter these guidelines to respond to the paper, we would argue that it contains a number of shortcomings that raise serious questions about its reliability and should not be considered in the Authority’s review of these guidelines.

The paper takes a method developed by the Institute of Acoustics in the UK (IOA) to detect and classify AM and modifies it. The modifications described by the paper effectively “lower the bar” on the classification of AM, resulting in seven times the number of noise samples being classified as AM. 

Of the samples classified as AM in the paper, 18% do not contain AM in comparison with 1% for the standard IOA method. The modifications have resulted in it being an unreliable method of detecting AM.   

The methodology in the paper has not been devised based on listening tests, which would have enabled the audibility and severity of the AM to be tested against the methodology. Rather the effectiveness of the methodology is assessed against a pattern on a graph. It is not clear how this pattern relates to audibility or severity of the AM, particularly given that the levels of noise in many of the samples are either just audible or below the threshold of perception to humans. Notwithstanding the lack of listening tests, the paper uses emotive language such as “reliably detect the most annoying features of AM when AM is present”, when it is not known if a particular AM scenario is annoying or indeed audible. 

The paper’s reliance on a theoretical model rather than listening tests is pertinent to this review as sections 4.6 - 4.8 of the guidelines all stipulate audibility at the receiver, which has not been demonstrated by the paper.

The paper is a study of one particular turbine model at one wind farm, which began construction in 2008. The technology of current turbine models has changed since this wind farm was constructed and therefore the findings of the paper cannot be applied in a blanket nature to other wind farms or to proposed wind farms. 

Finally, the paper shows that with the wind farm not operating (0% power) an average modulation depth of approximately 7.0 is recorded. With the wind farm operating, a marginal increase in the average modulation depth to 7.8 is recorded. This result either demonstrates that the modulation associated with the turbines is not significant or that the methodology cannot be relied upon. 



Andrew Bray
National Coordinator
0434 769 463
[email protected]


VIC emission reduction targets - AWA Submission

The VIC government recently invited the public to make submissions on their emissions reduction targets.

Thank you to all of you who used your voice for stronger targets, ambitious climate action, and more jobs and investment in wind energy for Victoria.

Together, AWA members lodged 50 submissions!

Below is the AWA's submission to the consultation process.

Submission for Victoria’s first interim Emissions Reduction Targets

About AWA

AWA is a community advocacy group. Our members include farmers, wind workers, local businesses and community supporters. We are independent of the wind industry. Our mission is to stand up for wind power for to build prosperous communities and lower emissions.

AWA is well connected with on-the-ground issues at many wind farm projects and is in a unique position to help find solutions.


The Australian Wind Alliance recommends that Victoria set emissions targets based on a carbon budget that provides a greater than a 50% chance of limiting warming to 1.5°C. A more ambitious target would translate to less emissions, more jobs and lower power prices according to the Independent Expert Panel: Interim Emissions Reduction Targets for Victoria (2021-2030) Final Report (Combet Report).

Opportunities for Victoria from Strong Targets

The Combet Report looks at opportunities to decarbonise Victoria in line with the Paris Agreement of limiting warming to “well below 2°C” and “pursuing efforts to limit the temperature increase to 1.5°C”. The report describes the serious consequences for the state if global heating is not held to this 1.5°C limit, as well as the importance of playing our part in tackling global heating. Australia is one of the highest per-capita emitters in the developed world. Amongst Australian states, Victoria has the highest-emitting electricity sector. The only thing stopping us moving on the road to zero emissions has been politics. We’ve got the technology, we’ve got the public support all we need is to get on with the job. The Combet Report shows it can be done.

The expert panel found that early action on climate change is cheaper than waiting and there are many opportunities in Victoria to keep the state in line with the Paris Climate Agreement. In addition, it found that wholesale electricity prices will fall with the increase in renewable energy. 

The report notes that renewable energy can play the biggest role in reducing emissions and that wholesale prices will be cheaper in the future if we move away from fossil fuels:

  • “Electricity generation has the potential to provide a larger volume of lower-cost emissions reduction than other sectors of the economy” (p 68). 
  • “Renewables providing 67.6% of total electricity generation in 2030...Wholesale electricity prices in 2030 of $79.4 compared with an average wholesale price of $90.5/MWh in 2018” (p 72).

Recent research published in Energy Policy confirms the reduction in power prices with more wind energy generation, concluding in Australia that “each extra gigawatt of wind capacity decreases the wholesale electricity price by 11 AUD/MWh”. Another report from SGS Economics and Planning notes that decarbonising our economy “would save the Australian economy $549 billion over the next decade while at the same time providing a number of social and environmental benefits”.

Rural communities are particular beneficiaries with jobs and investment as documented by the  Australian Wind Alliance report Building Stronger Communities: wind's growing role in regional Australia. Wind farm construction has delivered jobs and investment boost of $5 billion to regional Australia in the last two decades.

A key finding of Combet Report is the central role renewables, especially wind energy, will play in reaching zero emissions.

Victoria’s emissions by sector in 2016

Figure 1. Victoria’s emissions by sector in 2016 showing that electricity generation is the largest source of Victoria’s emissions (p 61).

Solar and wind are already the cheapest forms of new energy generation even when additional costs are included for energy storage (p 69).

Around 8,000 megawatts of new wind farm projects are currently committed or proposed to be built in Victoria, making wind energy the largest pipeline of new electricity capacity. Wind energy is ready to replace fossil fuel generation playing an impart role in the decarbonisation of Victoria's economy. A more ambitious target means more wind and solar, more action on climate change, more jobs and lower power prices.

Existing and potential new electricity generation capacity – Victoria

Figure 2. Existing and potential new electricity generation capacity – Victoria showing that wind has the largest share (p 71).

AWA Recommendations 

The Combet Report sets a new benchmark in what is possible, however, we find that the recommendations fall short. The Australian Wind Alliance is calling for Victoria to adopt targets based on 1.5°C emissions budget which the Combet Report shows is achievable for Victoria. 

The report notes that an interim target of 43% below 2005 levels by 2025 and 67% for 2030 would be inline  for 1.5°C carbon budget which is based on a 50% chance of limiting warming to 1.5°C. A 50% chance is too much of a gamble. A more ambitious target is required to meet the challenge of a fair emissions budget that will leave a safe climate.

Norway and Uruguay will be zero emissions by 2030 and Finland will be at zero emissions by 2035. This is the type of ambition that we need to stay within a 1.5°C carbon budget for Victoria. The upcoming UN 2019 Climate Summit's theme is ‘A Race We Can Win. A Race We Must Win’ we have little time to act and now is the time to be bold.

Having 1.5°C emissions target would make sure that a safe climate is more likely reached while the emissions reductions are more inline with the Paris Agreement which is “well below” 2°C and pursue efforts of limiting warming to 1.5°C. Making these targets would also be inline with the commitments that Victorian Government has taken the Paris Pledge for Action and signed the Climate Leadership Declaration for limiting warming to 1.5°C.

IPCN hearing into Crookwell 3

The AWA has been continuing to fight for the Crookwell 3 wind farm after the Department of Planning and Environment (DPE) recommended against the project in early May and referred it to the Independent Planning Commission NSW (IPCN).

We believe that the DPE’s decision did not accurately reflect the benefits which the Crookwell 3 wind farm would bring, both to the local community and to the state of NSW, and that the IPCN should approve the project.

Crookwell 2 Wind Farm

Support for Crookwell 3

Many locals, farmers, community members and businesses who benefited from the Crookwell 2 wind farm were eager to support the next stage of the wind farm at Crookwell 3. We canvassed, supported and encouraged them to use their voice in support of the project.

On 6 June both Andrew Bray (National Coordinator of AWA), and Charlie Prell (AWA’s NSW Organiser) spoke at a public hearing called by the IPCN into the Crookwell 3 project.

Charlie, a farmer who hosts some of the Crookwell 2 wind turbines on his property, and an organiser at AWA, warned that if the IPCN followed the recommendation to reject Crookwell 3 they “are not only affecting the few around the wind farm but compromising the future of this area to become a truly sustainable and vibrant community.”

Jobs and community investment at risk

The civil construction component of the Crookwell 2 project alone delivered more than $12 million into local businesses and $14.5 million across the Capital region. Crookwell 3 is slated to provide a similar slew of investment into the area, including at least 100 jobs during construction and 10 full-time jobs servicing the turbines post construction.

Several local companies lodged their strong support for the project, including both Coopers and Divalls Earthmoving businesses, who both sub-contracted on the Crookwell 2 project and employed 45 workers across 18 months. Both companies’ submissions noted that “jobs of this scale are not commonplace.”

Not only are these jobs at risk, but at least 13 farming households and the wider community would miss out on around $500,000 a year, paid through rent, neighbour agreements, community benefits and infrastructure improvements. The majority of neighbours of the Crookwell 3 wind farm have actually endorsed the project and signed agreements with the developer that allow them to share in the benefits it brings to the Crookwell region.

In the midst of one of the worst droughts in 400 years for NSW farmers, new, drought-proof income like hosting wind turbines can be a life-saver for farmers in this rural area.

In his presentation to the IPCN, Charlie espoused the benefits of wind farms for farmers amidst the harsh economic conditions of drought and spoke out about the realities of mental health in regional farming communities as a result of lengthy dry periods.

Clean energy in ageing, coal-powered state

The DPE’s suggestion that NSW does not need more renewable energy is misguided, as the state is currently the most carbon-intensive in the country, and also at high risk of climate damage.

NSW’s ageing coal-burning power station fleet is rapidly winding down. Renewable energy projects such as Crookwell 3 are badly needed to ensure NSW has a reliable source of clean energy on hand to replace it.

The AWA supports this project due to the boon of environmental, economic and community contributions it would bring, and will continue to encourage stakeholders to be vocal in their support for Crookwell 3.

The IPCN decision on the project and whether to reject or approve the recommendation from the DPE is expected in the coming weeks.

You can access AWA’s two full presentations at the IPCN public hearing on Crookwell 3 here


There are so many reasons that the Australian Renewable Energy Agency, or ARENA, should have a bigger and stronger role in building Australia's clean energy future. But instead, the government wants to cut $1.3 billion from this successful organisation, dropping early stage clean energy developers off a cliff and cutting Australia off from the clean investment boom that's going on around the world.

You can have a look at the kind of things ARENA have been doing here.


We've just made a submission to the Senate Inquiry looking at this plan, which is below.

In the meantime, contact Labor leader, Bill Shorten and Shadow Treasurer Chris Bowen and ask them to save ARENA!

You can contact them at [email protected] and [email protected]


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Senate hearing appearance for Australian Wind Alliance

Madigan_at_inquiry_The_Standard.jpgAustralian Wind Alliance national coordinator Andrew Bray fronted the Senate Select Committee on Wind Turbines public hearing in Canberra this week and challenged the committee to be constructive, not destructive.

He was joined on the day by Crookwell farmer, Charlie Prell and Goulburn engineer, John De Groote to speak up for local farmers and businesses.

This is what he told committee chairman Senator John Madigan, and Senators Anne Urquhart, Bob Day, Chris Back, Matt Canavan, David Leyonhjelm, and Nick Xenophon:

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AWA Senate Inquiry submission

Submission to the Senate Wind Inquiry

Here's the full thing and here's the exec summary:

The Australian Wind Alliance is a not-for-profit, community-based advocacy group to promote wind power. We have over 450 financial members and over 10,000 online supporters. Our members are predominantly farmers, wind workers, community members and local businesses. We support wind power because of the benefits it brings to the health of regional economies and to Australia’s economy and to the environment through the provision of inexpensive clean energy.

We note that over 300 individual submissions to the Review supportive of wind energy were submitted by our members and supporters. This submission both reinforces and offers complementary information to these submissions.

Wind farms have been operating in Australia since 1987. In  2013, wind power supplied over a quarter of Australia’s renewable energy and 4% of total electricity demand.


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