Gunnedah Solar Farm

I wish to object to the proposed Solar Farm on Orange Grove Gunnedah
based on the following:
The area concerned is a large floodplain
Any infrastructure will divert large quantities of water to other
properties and have an impact not imaginable by any EIS.
The proposed fence around the Solar Farm is a major concern,being a
considerable structure against flood flow.
The EIS does not consider any rural fencing,gates windmills,tanks or
sheds.
The admission by the proponent on page 74 & 75 of their EIS of not
having "complete data" is irresponsible.
Any information given in the EIS should be ignored based on this
admission.
Construction across any floodplain is not sound engineering.

I am not against solar farms but I would like to submit two(2) objections
to this particular project (SSD 8658 Gunnedah Solar Farm):
1) It is in a flood area with insufficient study into possible
flooding in this particular area
2) The proposed chain fencing. This could divert the flow of water
onto neighbouring properties

Concerning proposed (SSD 8658) Solar Farm on "Myalla", Orange Grove Road,
Gunnedah.
I am not against solar farms but I have some concerns regarding this
proposed project.
1). It is possible for 3 rivers to flood concurrently causing major
flooding in this area.
2) Building a chain wire fence on a floodplain is equivalent to
building a brick wall. Debris builds up on these fences and water will
be diverted causing consequent problems to neighbours.

I object to the Solar Farm because I'm not convinced that the flood
modelling is representative of what will happen in a flood. My farm is
located slightly upstream and to the south of the Namoi River. The
Solar Farm is located on the floodway, and water will have to divert
around it. Our farm has numerous billabongs on it, which all feed into
Carroll Creek, from the Namoi River above us. A major obstacle in the
floodway could potentially change the depth of water flowing through
Carroll Creek, which could cause inundation in our home. This has
never happened yet since the house has been built. Because of the
cross flow of water between the Namoi River and Mooki River via
Carroll Creek, it is particularly important that the flood modelling
include a time when both the Namoi and Mooki River systems are in full
flood, which I don't beleive this study has done.

Whilst supportive of solar farms in general, the location proposed for
this one appears risky because:
(a) the flood mappings shown in the documentation are not reflective
of actual high-water events over the last 50 years. This comment is
based on our personal observations of flood residue on land between
the proposed solar site and Gunnedah which is shown as being "dry" in
the Probable Maximum Depth diagrams;
(b) we have concerns that fencing around the proposed location may
cause increased flood heights in nearby properties, which could
directly impact our land, buildings, and livestock; and
(c) the land being used for the proposed solar farm is arable, and
there are many lower-grade, high-ground areas around Gunnedah that
would appear more suited to re-use for such a purpose.
We would request that an independent flood height assessment be
undertaken, which considers the same historic high-water data as used
for the design of the bridges on the B56 / Tamworth Road just east of
Gunnedah.

RE APPLICATION NUMBER 8658
GUNNEDAH SOLAR FARM
PHOTON ENERGY
I am writing to express my concerns regarding the proposed solar farm
located at 765 Orange Grove Road.

Areas of Concern:
Flood Impacts
Visual Impact
Use of Land
Alternative site


I have several issues with the proposed development. Of primary
concern is the impact the project will have on flooding. As indicated
in the Environmental Impact Statement submitted for public display by
Photon Energy the solar farm sits in a major flood area, impacted by
both the Namoi and Mooki Rivers. Floods through the affected area can
be of varying severity are not an uncommon occurrence. Any development
in this area is going to have unforseen impacts on flood waters and
may increase damage to property and increase the public safety risk
associated with flood events. My understanding is that current flood
plain management regulations stipulate that an impact of greater than
20cm by a proposed development on any other property is not
acceptable. I believe that the chain link fence required for this
project will create water displacement which will cause impacts far
greater than this. Central to my concern is the mention of, yet total
disregard of the `Carrol to Boggabri Floodplain Management Plan 2006'.
Several studies have been done on floods in the area which conflict
with graphic map representations (figures 6-32, 6-33, 6-34) in the
E.I.S. In addition the elevation mapping used to forecast flood
impacts has been acquired from the Shuttle Radar Topography Mission
(SRTM) (Page 189), which I understand to be accurate to 9.8 metres.
This is an unacceptable margin of error when trying to plan for a
flood event where varying depths of 100cm can have far reaching
effects. Furthermore, Light Detection and Ranging data (LiDAR) is no
longer cost prohibitive especially for a project of this scale and
with such serious and widespread potential impacts. LiDAR surveying is
also mentioned in the E.I.S, however it I suggested that it should be
done at a later date. This is a red flag to me as it suggests that
Pitt & Sherry at Photons request have opted to use the much more
`malleable' data from the shuttle survey to create mapping and
modeling to fit an end goal rather than undertake a genuine flood
impact study.

I also have some concerns with the visual impacts of the project.
There are several smaller holdings including mine located to the north
with residences in elevated positions which will overlook the project.
These smaller lifestyle blocks have a considerable amount of their
value tied to the aspect and ambience. Having paid a premium to enjoy
a rural view, I don't want it replaced with glass and steel nor do I
want to incur a loss in my capital value. I am unconvinced that there
will be little to no glare from the panels as suggested by
representative from Photon, especially seeing as though I am situated
directly north and some 25 metres above the project. The photo
montages fabricated by Photon (fig 6-24) are not a true representation
of the visual impact I will suffer.

I am also compelled to query if this is the best use of this land.
Prime agricultural land is our most precious resource and is not
portable. The climate band the property lies in enjoys the capacity to
grow a wide range of summer and winter crops including wheat, barley,
corn, sunflowers, pulse crops, sorghum, oilseed crops like canola and
linseed, as well as high yielding cash crops including cotton. As an
intensive irrigation property benefiting from both groundwater sources
and river water this farm has the capability to control the biggest
risk factor - that of rain, which gives this and other irrigation
properties the ability to produce every year. Agricultural commodities
like this provide much more to our district in terms of economic
benefit. Not only does the land holder profit, but numerous associated
support services like freight providers, agronomists, farm input
businesses (i.e. fertilizer, chemical) which provide sustainable
employment to the broader community.

Ultimately, like many Australians I support the integration of
renewable energy sources into our broader energy network. Not only am
I aware of the environmental impacts of fossil fuels, but also the
glaring reality that coal, gas, and oil are finite resources. It is
short sighted to not consider alternatives now to soften carbon
emissions, and facilitate the development of efficiency and viability
of renewable energy sources. It is the site of this project that
concerns me. Especially when there is a far superior site located
approximately 1.5km to the east on Orange Grove Road. I am sure the
department is aware of an alternative solar project being proposed.
This site is in a less flood prone area, sits on a lesser soil type,
has far fewer parties impacted in term of both flood, and visual
impacts. I would urge decision makers to seriously consider this
alternative as part of any approval process.

Concerned member of the community,

First of all, I am a firm believer in renewable energy, for a
sustainable future. However, in doing this it should not have a
significant impact on the community and surrounding residents.
My main concerns are for the proposed site being in a flood plain. My
concerns is that it will change the water flow and have detrimental
effects on the surrounding residents on properties during flood
situations.
The close proximity to town is also a concern. Surely there are places
further out of site, that would be more suitable for a solar farm. I
am sure it will be a real eye-saw and will decrease the value of
properties in close proximity, as well as removing valuable food
producing land.
I believe it is the wrong place, and plans should be sought to find a
new location/ site for the proposed Gunnedah Solar Farm.

Thank you

To: The NSW Department of Planning and Environment

I am writing a submission to officially object to the proposed
Gunnedah Solar Farm at 765 Orange Grove Road, Gunnedah. I am an
immediate neighbour directly to the north and feel the proposed
position of this project is wrong and should not be built on prime
food and fibre producing land of excellent quality.
I disapprove of the proposed solar farm for many reasons, some of
which include the fact that the site is situated in the middle of a
flood plain and will change the flow and heights of water considerably
in times of flood which will have a major impact on surrounding farm
land and property, including people homes.
Photon Energy have done hydrological studies which they admit are not
accurate and certainly do not conform with the Carroll to Boggabri
Management Plan 2006 which was undertaken by the Government. Many
other flood studies have been done in the area that differ
considerably with the information represented in the E.I.S.
As I am a direct neighbour in an elevated position to the solar farm,
it will have a considerable visual impact on the view from my
property. We have recently built a new home to capture the essence of
the wonderful rural views. The visual impact will not be reduced with
landscape screening as our farm is 15-20 metres above the project and
the solar panels will be visable from every inch of our farm.
It has been suggested to us by local real estate agents that this may
reduce the value of our land by up to 20%. This is of great concern as
we have paid a considerable amount of money to acquire such a unique
holding and don't want to wake up and look at a solar farm for the
rest of our days on this property.

Yours sincerely
Graeme Brown

To: The NSW Department of Planning and Environment

I write to you to express deep concern in relation to the proposed
Gunnedah Solar Farm (SSD8658) for which I am opposed.
I am in favour of renewable energy, however I am not in favour of the
chosen position of the proposed solar farm. Its position raises many
concerns that will have a devastating impact on local residents.
Firstly as a direct neighbour to the North, and at an elevation of
15-20m, I am horrified at the thought of such an enormous project
being constructed on prime farming country within a peaceful,
picturesque farming community. Our farm, along with all our direct
neighbours on Tudgey Road, are not large rural properties. They are
simply lifestyle acreages that need to seek off-farm income to
survive. I have paid a significant price to acquire our farm in such a
beautiful rural setting with close proximity to the township of
Gunnedah. I have also recently built my forever home to capture the
scenic outlook of agricultural land.
The E.I.S states that "the overall sensitivity of views from Tudgey
Road is considered low". This statement is grossly untrue as the
visual impact from an elevated position is extremely high as it will
be visible from every inch of our property. The implementation of
vegetation screening will not improve the visual impact especially the
effect of the glare and shimmer over a span of 470,000 panels.
I have been informed by local rural property agents that our once
valuable properties will decrease substantially, up to 20%, if such a
proposal is to go ahead.
Another major concern I have is the fact that construction will cover
a massive flood plain. In times of flood, especially due to the
proposed security fencing requirements (that will capture debris),
will cause major destruction to homes, livestock and infrastructure.
This project will change the flow direction and water levels, this in
turn putting local residents at risk.
The proposed flood model is an inaccurate display of where the flood
water will travel to with the solar farm in place and has neglected to
consider the "Carroll to Boggabri Floodplain Management Plan 2006".
Further studies have been conducted in the area since which also have
conflicting information to that set out in the E.I.S.
The levels of air and noise pollution is another aspect that has not
been taken into consideration nor have any measurements been made or
levels tested. This peaceful, rural location would suffer considerably
and our beloved aspect will be lost if such a project is approved.
Yours sincerely
Emma Brown

Hello,

I object to this proposal for the Gunnedah Solar Farm.

Orange Grove Road and the surrounding roads are not suited to handle
100+ vehicles entering site each day, especially large trucks carrying
materials for the 12 month construction period. The edges of the road
are well worn and driving alongside consistent construction traffic is
a hazard to the residents of the area, as well as the school bus route
that passes by the site. In particular Old Blue Vale Road is
technically 2-way 100km/h traffic but practically requires both cars
to only have 2 wheels on the sealed portion.

Appendix I mentions that local council are not able to provide
resources to work on extending or maintaining the roads used and have
suggested outsourcing it. If it is not explicitly stated in the
principal's contractors requirements, then any care or due diligence
to the road after construction will not be carried out by any party.
The residents will be left with heavily impacted roads that the local
council can not afford to fix themselves.

There was also mention of school bus times + the possibility of truck
access restrictions being investigated. Unless written this will not
happen, drivers will only be informed about the bus route timing.
Trucks are going to be delivering resources from across the state to
provide materials to a remote site such as this without regard to
delivery times. There will be long haul deliveries that will take many
hours and unless drivers are assigned to the project and there are
restrictions in delivery times then school bus times are definitely
going to be affected. Another concern miscellaneous third party
delivery drivers that may not be site inducted and do not obey site
instructions unless there is traffic management to specifically hold
up all construction traffic during the school route time periods.

In addition I also am opposed to the potential for environmental
damage as the area is a floodplain which has a delicate ecosystem that
will be impacted by all the earthworks required for construction and
cabling of high voltage lines/substations etc. There will be loss of
vegetation to land clearing and the effective amount of agricultural
land will reduce which affects residents and their livestock. The area
is currently in drought and needs all the usable land available. Given
that there is still more flood modelling to be undertaken this
proposal should not go ahead prior to this data being taken and
impacts analysed.

Finally, the lifetime of the farm is quoted at 25 years and there is
no guarantee that the area will continue to be used as a solar farm
after this point. There is the possibility for the farm to simply be
decommissioned and the area does not have any party committed to
rehabilitation of the area. It is likely the original area will never
be restored to what it was due to the amount of time passing, and
likely a different generation of parties involved will be managing the
aftermath that did not originally survey and appreciate the area.

Regards,

Ben Potter

Dear Sir /Madam,
I write in relation to the proposed Gunnedah Solar Farm, identifier
8658.
I am not a donor to any political organisation or individual.
I strongly support the solar farm development and look forward to its
completion and operation should the environmental concerns be
addressed.
As an immediate neighbour, sharing a common boundary downstream of the
proposed development, I have significant concerns about the effects of
flooding, caused principally by the proposed fence.
I believe that the current fence design, during a significant flood is
a danger to the solar farm and to our farm.
The proposed fence could be modified to allow the free passage of
water and debris and alleviate the above problems but the current
design does not in any way allow for this.
Small increases in flood levels will have serious detrimental effects
to the infrastructure, animal welfare, operation and financial
viability of our farm.
I also believe that the EIS is flawed (see appendix J, section 7) and
understates the effects of the solar farm on flood levels and water
velocities, both crucial parameters affecting our farm. Calculations
in the EIS have been made based on data from the 1984 flood and does
not include the most accurate or pertinent available figures.
The developer's submission also states that more work needs to be
done. I believe that to be true and believe that any further work on
the EIS needs to be done and approved before any approval is given to
proceed with the develppment.

To The NSW Department of Planning and Environment. I am writing a
submission to officially object to the proposed Gunnedah Solar farm at
765 Orange Grove Rd Gunnedah. I have 3 friends that live in clear view
of the proposed site. These families all work in Gunnedah as their
properties are lifestyle blocks rather than big agricultural
properties. Therefore they need to make an income from jobs other than
their farms. These people all purchased these properties with
magnificent views looking back towards Gunnedah. They have all worked
very hard to be able to give their families such beautiful homes and
land. They have been informed that if the proposal is to go ahead
their property value will decrease by 20%. Had they have known there
would be a solar farm built in their front yards they would never have
purchased this land. The proposed site is also a major flood plain. In
the event of a large flood there would be a significant risk to
property, homes, stock, infrastructure and lives because the direction
of the water flow would be changed. Please consider our worries
Yours sincerely
Renee Torrens

1. Flood modelling shown to me did not include the cumulative impacts of
both the Namoi and Mooki Rivers and as such is grossly inadequate.
2. The proposed site of this development is a major break out zone for
the Namoi River and as such the proposed chain mail fence will become
a major blockage and that will increase flood heights; any increase in
flood height will adversely impact my home and property infrastructure
as well as other properties in the locality.
3. Location of this development should not be on prime agricultural
land.
4. I have major concerns in regard to increased traffic movements and
safety along Orange Grove Rd, Kelvin Rd and Old Blue Vale Rd as a
result of this development.

1. While generally supportive of renewable energy projects, this project
will adversely impact adjoining and down stream landholders. It is in
a major breakout zone and will be inundated and be damaged by flood
water.
2. Consultants have been selective and biased in their reporting of
concerns advised by landholders. In the event of a major flood no one
is able to access properties along Orange Grove Road and poses a major
risk to emergency services in being able to provide support or
assistance to this proposed facility or affected landholders.
3. Consultants have not referenced or appear to have sourced
additional information provided to them relating to flood studies and
work being done in relation to Health Flood Plains Project which is
currently in draft form on the Water NSW site.
4.The chainmail fence is a major concern as this will impact the flood
height and direction and is likely to adversely impact landholders in
the locality.

1.Increased traffic along Orange Grove Rd will impact the road surface
and safety of users, there does not appear to be any contribution to
improvements or upgrades for the road or intersection to the benefit
of local users or broader community.
2. Any fence build on the flood plain needs to be able to collapse or
allow flow to proceed and not block flood flow or affect our
neighbours and their properties, a chain mail fence is a major problem
associated with this proposed development.
3. Once the development is established there does not appear to be
many economic or employment benefits flowing back to our community
because only 2 people will be employed full time when complete.
4. Flood modelling as noted in the EIS page 189 is not of a sufficient
detail/refinement to determine flood impacts. Any increase in flood
deviation or flood height will affect those in the immediate area and
down stream landholders and Gunnedah township.

1.There does not appear to be many economic or long term employment
benefits associated with this proposed development for our Gunnedah
community.
2. This is in the wrong location as this is on prime agricultural land
and is where the Namoi River breaks out in moderate and large flood
events.
3. Visual pollution is a major consideration as this will affect our
neighbours and has the potential to create a traffic distraction and
also source of ignition for bushfires.
4. The detail in the EIS does not have sufficient information to
provide confidence that this proposed development will benefit our
broader community.

I do NOT agree that the right place to have a Solar Farm is on prime
farming land! Seriously this is NOT rocket science!

I object to the proposed Gunnedah Solar Farm because:-
a) It is the wrong place for a solar farm on a flood plain as it will
change the direction of the water and pose a high risk to residents in
times of flood.
b) Decrease the value of neighbouring landholders due to shimmer &
glare

During twenty three years living at Manaree, 1170 Orange Grove Road,
we experienced five major floods. The longest time we were isolated
from Gunnedah was four days. The point which initially cut us off was
always the torrent leaving the Namoi River and passing across the
Orange Grove Road from Galton's and Dawson's into Myalla (site of the
proposed solar farm).

Before any further consideration of a solar farm is undertaken I would
strongly recommend the proponents see for themselves the significant
amount of water and debris that rages across the paddocks.

26th May, 2018





Planning Services
Department of Planning of Environment
GPO BOX 39
SYDNEY NSW 2001

Natasha Homsey
Environmental Assessment Officer
Resource & Energy Assessments
NSW Planning & Environment

Dear Natasha,

I live at my father's property which is located less then a kilometre
away from the proposed solar farm. We also own another block of land
directly across the road from the proposed site where most of our
livestock are situated.

I am concerned that Photon Energy are planning to construct a solar
farm in this flood way which will effect both of my father's
properties. We live in a high risk area for flooding, therefore if the
proposed solar farm goes ahead you will be increasing this risk to
livestock and infrastructure.

I cannot understand why the NSW Government would spend millions of
dollars investing in a solar farm that could potentially be washed
away causing destruction and harm to our local community.

I oppose the solar farm as I have seen the flooding in our farm many
times and do not consider building a solar farm in a flood prone area
near a substation a practical investment.

Yours sincerely,

Jake Dawson
ORANGE GROVE NSW 2380