Hills of Gold Wind Farm

I object to the project for the following reasons:

- Instead of the native scrub, scraggly trees, tree-covered hills, open grasslands and rocky ridges, the project will destroy them with broad roads connecting circular clearings at the base of at least 50 wind turbines.

- the project is prioritising profit over biodiversity by the French multi-national Engie’s Hills of Gold Wind Farm near Nundle, a small community of 600 people near Tamworth. The town has made a name for itself as a gold rush heritage and nature-based tourism destination.

- For nearly five years volunteers with landholder group Hills of Gold Preservation Inc have found themselves calling out omissions, mistakes, and inconsistencies in thousands of pages of an Environmental Impact Statement, Response to Submissions, and now an Amended Development Application.

- Volunteers have staffed a pop-up office daily for the past three weeks to explain red flag issues to community members dropping in to see the wind turbines plotted on an old school paper topographic map showing the steep contours of the mountainside and ridgeline earmarked for industrial infrastructure. This includes roads for oversize overmass vehicles, concrete batching plant, operations and maintenance building, substation, battery energy storage system and towers to support transmission lines.

The volunteers even organised a public meeting when a formal request to the developer for a public meeting was refused.

- Hills of Gold Wind Farm directly neighbours Ben Halls Gap Nature Reserve and “over 135 metres outside the closest extent of the development footprint” is Ben Halls Gap Sphagnum Moss Cool Temperate Rainforest, newly listed as Critically Endangered under the Environment Protection and Biodiversity Conservation Act. The Critically Endangered status is not referenced in the developer’s Amended DA.

The ecological community has a very restricted geographic distribution in Ben Halls Gap Nature Reserve and nearby Ben Halls Gap State Forest.

The Approved Conservation Advice makes special mention of the threat of fire, drought, storm damage, weed invasion and disturbance by humans and non-native animals. Sedimentation from soil disturbance, changes in water availability, and competition from weeds are ongoing major threats.

Yet earthmoving for roads and foundations is proposed on the neighbour’s land.

- National Parks and Wildlife Service expressed its concern regarding 28 turbines posing “Moderate Risk” to local threatened bird and bat species. “...A key question is whether a moderate level of risk to threatened species is acceptable adjacent to high quality habitat on national park?” For this reason, NPWS recommended removal from the proposal of all turbines neighbouring Ben Halls Gap Nature Reserve. The developer removed one turbine to create a 1.2km corridor, but a local veterinarian compares that to installing a pedestrian crossing and expecting birds and bats to use it.

There are other flora and fauna at stake. Some 447 hectares of vegetation would be disturbed, including 190 ha of native vegetation and 46 ha of koala habitat that is critical to the endangered species survival. Meanwhile local ecologist Phil Spark is studying the significance of the high elevation range, including Crawney and Hanging Rock, for remnant breeding populations following the serious decline of koalas at Gunnedah on the Liverpool Plains.

- Residents are concerned about the clearing and soil disturbance on steep country required for proposed Hills of Gold Wind Farm Western Connector Road and infrastructure including:

substation,

concrete batching plant

battery

operations and maintenance building

transmission lines/towers/easement, and

Wombramurra Creek, one of eight potential waterways between the New England Highway and the project area on the Great Dividing Range, that would need a substantial new bridge to carry oversize over-mass vehicles with the capacity to withstand flash flooding.

- The developer proposes a combination of biodiversity offsets and stewardship agreements to achieve no net biodiversity loss.

But The Integrity of the NSW Biodiversity Offsets Scheme Parliamentary Inquiry found that there are multiple problems with the scheme, and questioned its capacity to achieve a goal of ‘no net loss’ of biodiversity.

The inquiry found the scheme facilitates development rather than protecting irreplaceable biodiversity values. It heard that, “New South Wales's biodiversity is under threat. We cannot afford to hasten the extinction of what biodiversity remains through a scheme that trades off threatened species for cash.“

The 2021 State of the Environment report lists habitat loss and clearing as significant threats facing Australia’s biodiversity

An official review of the Environment Protection and Biodiversity Conservation (EPBC) Act says Australia’s main environmental law is failing both the environment and developers and contributing to the unsustainable decline of Australia’s habitats.

In Mayeta Clark’s story James Cook University adjunct professor and evolutionary biologist, Dr Tim Nevard, says, “Biodiversity is the buffer at the end of the tracks that stops the runaway train of climate change from bursting through.”

“Destroying biodiversity in order to have greater amounts of wind energy is a complete oxymoron. It’s ridiculous. So we shouldn’t be doing it.”

- Three NSW Renewable Energy Zones are declared and another two planned, all of them oversubscribed with renewables expressions of interest.

Hills of Gold Wind Farm is not in a Renewable Energy Zone.

Rural communities in high value conservation areas are asking is the development process of Avoid, Mitigate, and Offset enough? Where biodiversity impacts are unacceptable they ask that a fourth process be an option, Stop.

Thank you, Michael Mobbs






- there will be a “fish skeleton” of road networks with clearing about 30 metres wide

- I want state and federal environmental protection frameworks adequately applied to renewables proposals in high value conservation areas such as the Hills of Gold are now

-

I am uploading my submission as a PDF

Refer to my attached Objection to the Hills of Gold Wind Farm

I have attached my submission

Reasons for objection:
1. Lack of information and consultation of planned wind farm development to residents of property owners in the Timor and surrounding areas.
2. Insufficient time given to raise any objections. (COVID restrictions which prevent personal contact with landholders or arrange meetings)
3. Issues concerning bio-security not addressed in report. (People & vehicles entering private property.)
4. Lost of property value. (Valuer’s report?)
5. Transport of oversized and heavy equipment via Crawney Road. 6. Impact on Isis River.
7. From my property the view is to the East(sunrise) to the mountains.
This is where the wind farm development will be evident of a morning.
Late afternoon when the sun sets, the sun will shine directly on the turbines. At night, we will see the red lights flashing as a pilot warning. Visual impact!
8. The reports states the benefits to the residents of “Nundle”, but not of the disadvantages to the people of Timor and district.

9. Wind farms are not a tourist attraction.
10. Bushfire management (what safety measures & financial support for fireworkers) 11. Effect on rainfall & climate change in Timor area.

STRONGLY OBJECT TO THE FOLLOWING:
1) Destruction of 46 Hectares (Ha) of Koala Habitat.
2) Poor quality of Crawney Road.
3) Loss of property value.
4) Contamination of natural waterways.
5) Increased risk of landslip.
6) Increased traffic flow and potential accidents, no mobile phone coverage.
7) Increased road kill of native animals.
8) Increased risk of bush fires and limiting bush fire control methods.
9) Destruction of timbered material ridge-line.
10) Visual Pollution with turbines 230m high, being 96 metres higher than the Harbour Bridge.
11) Overall destruction of native vegetation and native animal habitat.
12) Continuous ridge-line night lighting.
13) Unknown impact of turbine noise.
14) Potential health impact by blade shedding of fibres similar to aesbestos and cannot be detected for many years after initial contamination.
15) Increases security risk to rural dwellings with influx of itinerant workers.
16) No real job opportunities to existing residents.
17) Destruction of existing tourism by people who want to visit proper rural Australia.
18) Industrial development should be prohibited in rural areas.
19) Unknown impact of blade flicker.
20) Lack of honesty with those that i have personally dealt with.
21) Government developed quarries should not be used for private developer usage.
22) Increased extraction of quarry materials.
23) Increased road usage by heavy vehicles.
24) Quarry life for community purposes is diminished.
25) Seperate Environmental Impact Statement (EIS) should be assessed before any increased extraction quantities area allowed.
26) Thank you Tamworth Regional Council (TRC) planning department and councillors for representing your community.
27) Shame on Upper Hunter Shire Council (UHSC) for your unprofessional assessment of the EIS and Development Application (DA). Your lack of interest in your local community is disgraceful and has potential for a formal complaint to Independent Commission Against Corruption (ICAC).
28) This proposed project has adversely affected my health over the past 2 years causing stress and anxiety and has prevented my "quiet enjoyment" of my property.

I confirm all my previous reasons for objection contained in my submission dated 12/1/2021.

I wish to make an addendum to my last submission to update a photo used. The submission number is SUB-51789999 submitted 4 December 2022. Please replace the photo of road damage (taken October 30, 2022) on page 5 with these two updated photos (see attachments) showing how much the new road has deteriorated in the last 3 weeks. Photos taken November 11, 2022. This road will never be able to take an extra 311 vehicles per day as the Engie submission states will be the extra traffic, including some 156 daily truck movements projected to use this section of road.

I am uploading this submission on behalf of my father-Ian William Worley 11/4/1937. His mobile number is 0428381756. he is unable to use a computer and has asked me to type and upload this document. He is happy to be contacted if you need further clarification.

I object to the project. Please see attached.

The Hills Of Gold wind farm is not in the best interests of the environment. The location of the proposed wind farm is in a fragile and important ecological location. There are endangered species that would be threatened by the clearing and the disturbance of the wind farm. The site is very steep and the soils are shallow and fragile. Landslips are common and would become less stable where infrastructure is planned. The location is a recognised wildlife corridor and this would be severely compromised by the proposed wind farm.
The life of the wind farm is very short considering the environmental disturbance of the proposed project.
Access roads are not suitable for the traffic required to build the wind farm. The southern access from Timor is a very windy and narrow road. Vehicle accidents on the road are reasonably common as the road is primarily one lane and the corners are blind. The steep sides of the road pose a significant threat in accident. As a regular user of the road, my commute to our business location at Nundle would be impacted by significant traffic and the additional risk that poses is also a serious consideration. Certainly additional traffic combined with the resulting wear and tear to the road could risk human life. The northern access from Nundle toward Crawney is similar.

Objection attached.

Objection by Businees Owner- Oakenville Farm Store

I am a co-owner of the newly opened small business, Oakenville Farm Store and have also worked from home on our farm on Oakenville Creek Road teaching pilates classes, offering health treatments and accommodation. Firstly, the proponent has failed to address or even acknowledge the many concerns made in regards to traffic by community members and businesses. It seems that once again, the community is not considered “stakeholders” even though it us, as residents, who have chosen this beautiful area as our home. As a landholder, resident and business owner, I made a detailed, heavily researched science and statistics-based submission about my traffic concerns, mainly relating to traffic on the Nundle-Tamworth Road and through the main street of Nundle. The proposed alternative routes entering Nundle; the Private Rd By-pass and the Happy Valley Rd loop fail to meet or address my personal concerns in regards to noise pollution, pedestrian safety (particularly children), traffic disruptions for Nundle-Tamworth, Nundle-Quirindi commuters, reduced over-taking time, increased vehicle accident risk and damage to already poor-condition roads (please refer to my earlier submission). In fact, the proposed transport route raises additional concerns, particularly in terms of environmental impact. The ‘Private Road By-pass’ will take heavy vehicles directly through a flood zone alongside the Peel River. The ecological impact of removing several trees (dismissingly referred to only as “vegetation”) on this flood zone has not been addressed. No EIS has been conducted to address the impact on wetland-type species which rely on intermittent flooding and other specific ecological conditions provided only by this environment.

The private-road by-pass will effectively avoid the busier end of Jenkins Street, however this will completely alter the popular River Walk which loops up to the Innes Street/Jenkins Street corner. This track was constructed using community funds and is popular amongst walkers and was regularly utilised by the Nundle Runners group, of which I am the organiser.

The alternative route, the Happy Valley Rd loop, also raises many serious concerns. Several months ago my partner and I opened Oakenville Farm Store and we operate out of the shop next door to the Nundle Post Office on Oakenville Street. Currently, the noise pollution from the log-trucks is significant. These log trucks undertake about 30-40 passes per day at a noise volume measured by my neighbour of between 60-70 decibels. With the door to our shop open, it is impossible to hear customers for the duration of their passing. The over-mass vehicles are estimated to be double the weight of the log trucks, on average 120 tonnes vs 60 tonnes. The suggestion by TTPP that the noise would by only 58 decibels simply does not add up. The noise pollution alone will cause major disruptions to the our ability to hear and serve customers and will severely impact the quiet, relaxing environment of our shop, recently described by a customer as “a walk into serenity” which is “warm and hospitable”. As a Herbalist and Therapist, I also use the space for one-on-one sessions and will simply not be able to work from this space if I cannot hear clients when speaking.

Our Oakenville Farm, which we also operate our business from, is located on Oakenville Creek Road, 1km from Nundle and ourselves and people staying at our accommodation, often walk from the township to our property. Even though there is minimal road verge, it is quite safe to do so and local cars and traffic are aware of pedestrians (and often families of the Australian Wood Duck) on this road. The intersection of Oakenville Street and Oakenville Creek Road will be significantly altered and the turning area required will impact greatly on our neighbour’s paddock. In addition, this turn will require major works as this is also a a flood plain for Oakenville Creek. The failure to refer to the wash-away and major under-cutting of the Oakenville Creek bridge, causing single-lane traffic only, is a major oversight by the proponent. I surmise that an engineer’s report (if one had been done) would find that this bridge could simple not withhold the weight of over-mass vehicles.
The suggestion that over-mass vehicles reverse down Happy Valley Road is also preposterous; not only would this be incredibly dangerous for pedestrians, other vehicles and wildlife which regularly move through this area, the noise pollution due to braking on this steep road would be significant and I imagine well over the estimated 58 decibels.

I fear if this project is approved, we will need to close the doors of our new, innovative business whose main goal is to educate people about simple ecologically sustainable solutions and offering products which have a minimal ecological footprint. As a business, we highly value community connections and working cohesively to come up with ecologically sustainable solutions. We have held a small local produce market out the front of our shop and believe that one of the most achievable and meaningful solutions to our “climate crisis” is through “localisation” e.g. eating local food, building using recycled materials and if possible using renewable energy solutions in the form of off-grid solar, managed by individuals, not multi-national, foreign companies. This project will threaten our business and the very lifestyle that we encourages our customers to adopt. Our businesses approach to sustainability is about community-based solutions, community innovation, community inclusivity and changed behaviours with social, ethical, economic and ecological outcomes. This project fractures all of these ideals and values profit over biodiversity and political punch over community cohesion. Please re-consider this project. This project is not renewable, nor sustainable, nor economically beneficial to this community.

Ref: Hills of Gold Wind Farm Amended Application (SSD – 9679)


Christopher Eagles
On behalf of the Concerned Citizens of Crawney and Timor
“Alston” 1339 Crawney Road
TIMOR NSW 2338

The Concerned Crawney and Timor Citizens Object to the Engie Hills of Gold Wind Farm (HOG Farm) application.

We wish to note that our previous objections to the original EIS remain current and applicable to this Amendment Report, November 2022.

We acknowledge and accept the NSW Department of Planning and Environment’s disclaimer and declaration.

Objections are as follows.
• Engie’s in preparation of the initial EIS, and now once more for the amended DA, has failed to consult appropriately with the Timor and Crawney community. Breaching NSW Wind Energy Guidelines 2016
• The Amended DA change of access should have been consulted by Engie more widely with all of communities that will be impacted by increased Traffic between Crawney / Blandford and Gundy and the New England Highway. Breaching NSW Wind Energy Guidelines 2016. Unleashing a wave of traffic from contract workers from the Major cities and other regional towns, on poorly maintained sealed and unsealed minor rural roads will result in tragedy, either to locals or that workforce. A Project of this scale should never have been proposed, in a poorly serviced rural area such as the Isis Valley, without proportionally scaled associated infrastructure, such as roads etc. Engie’s poorly organised and hence poorly attended community meeting in June 2022, hardly constituted community consultation.
• Engie’s offering of a monetary donation, and then later sponsorship, to the NSW Rural Fire Brigade, during the assessment process, understandably raises doubt in the mind of the community about the integrity of some aspects of the HOG Farm Assessment process.
• Engie completed no Noise and Vibration Assessments in the Timor/Crawney area. This is simply unacceptable
• Engie’s Visual and Landscape Assessment is deeply flawed. How can the GREAT Dividing Range be assessed as “MODERATELY” Scenic???
• Engie’s failure to assess the impacts of the proposal on Water and Soils South of the Range, encompassing a third of the surrounding geographical area, is actually dangerous and completely unacceptable.
• Engie is understating the Environmental Impacts of this Project area by not accounting for the large scale clearing that has occurred on the Host landholder’s properties during the planning process. The alignment between historical clearing and the Wind Farm layout is obvious in the Project Layout. Why is Engie and NSW DPE turning a blind eye to what is so obvious to the local communities?
• Engie’s Environment reports reveal a lack of understanding of the actual environment in the Timor/Crawney area, bat roosts being a case in point, which in turn means that determinations will be made based on incomplete assessments of the actual environmental impacts.



Action Requested

• That Engie’s Reports be independently assessed by NSW DPE to verify that the impacts to areas South of the Range have been fully assessed. It is clear that very few of Engie’s consultants actually visited the Western Project area, the area that is most fragile and will have most impacts South of the Range. Instead they chose the easiest areas and the least contentious areas.

• Engie’s offering of a monetary donation, and then later sponsorship, to the NSW Rural Fire Brigade, during the assessment process, understandably raises doubt in the mind of the community about the integrity of some aspects of the HOG Farm Assessment process. The NSW Rural Fire Brigade promoting the project, in Engie’s Winter newsletter seems inappropriate. This should never have occurred. How can the community be satisfied that all parties have acted impartially, in what should be an impartial process?

• That a full assessment of the Environmental impacts includes the clearing on the host landholder properties during the planning process for the HOG Farm.

• The NSW Environmental Legislation has changed substantially since the issue of the original EIS for this proposal. Given now the opportunity, through the Public Exhibition of the Proposal and the Amended DA, to provide updated responses, then we call on the NSW Government Department BCS and National Parks, to update their responses to the Environmental impacts of this proposal, based on the New Legislation. As an example, applying the updated NSW Legislation for Koala Protection and the EPBC Act has upgraded the Threatened Ecological Community Ben Halls Gap Nature Reserve Sphagnum Moss Cool Temperate Rainforest to endangered.

• National Parks should hold Engie to account and demand that, as requested, the Turbines adjoining the boundary of the Ben Halls Gap Conservation area be “Removed”. Engie’s response to “Move” (that’s a different verb Engie) Turbines small distances, but still retain the right to move the Turbines up to 100M during the detailed design, giving them the opportunity to move them right back where they came from, is just “Jiggery Pokery”.

• The change of Project Access proposed in the Amended DA, will drive increased traffic volumes on to local Upper Hunter Roads (Crawney – Timor - Blandford and Crawney – Timor - Gundy). If this proposal is to proceed, then these Minor Roads should be upgraded to support the increased traffic volumes.

I am opposed to the Hills Of Gold Wind Farm.

I do not agree with the damage to wildlife habitat from land clearing on the wind farm site or for access.

I Object to this project on the following grounds:
1. The proposed traffic routes will create major disruption to the township of Nundle, impacting both residents, the local school and peaceful enjoyment of residents.
2. The proposed traffic route via Crawney, will have a detrimental impact on environmentally significant landscape.
3. The terrain of the proposed site installation is not geological stable for the installation of the towers.
4. The proposed installation site is part of the water supply catchment for the City of Tamworth. The negative effect of both construction and installation on this water supply is too high a risk and has not been evaluated.
5. The impact of bird strikes will have a negative effect on endangered / protected birds
6. Rehabilitation of the sites at the end of the project has not been adequately documented.
7. The material used on the towers (blades) cannot be recycled and will been a toxic waste deposited into land fill.
8. The towers will greatly impact the ability for air craft to fight bushfires.
9. The lights on towers will impact the area due to light pollution.
10. The technology is financially unviable without government subsidy, if Government policy changes over the lifespan of the project in relation to subsidization the project will collapse.
11. The technology is already obsolete and alternate power generation methods should be investigated.

My family live and work at Wombramurra Station 504 Head of Peel Road Nundle. The proponent has not adequately addressed the concerns regarding the Hills of Gold Project I raised in my origin response to submissions especially in relation to consulting with neighbouring properties and I have many concerns with the amended DA.
The use of Crawney Road by large numbers of trucks and oversize overmass vehicles will affect the safety of myself and my family travelling as this is the only access to our property. There is also a requirement of upgrading at least eight bridges which will contribute significantly to delays for us to travel to Nundle or Tamworth. The network of roads to be constructed as part of the Wind Farm within the project area have no engineering of design proposals and as much of the terrain is very steep and prone to erosion I am concerned as to the affects these types of works will have on the mountain range, we all find so beautiful and a unique part of the Nundle landscape. There is also limited information on waterways and the influence this project will have on runoff from the mountain except to say water will be diverted away from certain areas which could be very damaging to areas such as Ben Halls Nature Reserve and Crawney National Park. The use of sedimentation beds and banks to control erosion will also have large affects on the hydrology of the mountain and potentially affect the quality and quantity of water flowing into Chaffey Dam, Tamworth’s main water supply
The proposed alternate transport route through Nundle will entirely change the visual entrance to Nundle and thus the character of the town. To me this is unacceptable added to the road works causing potential increased flooding risk for residential properties in Nundle. There are numerous areas in the amended DA where inaccurate or misleading information is presented and several alternative locations for location of infrastructure. The project should not be approved when there is limited accurate information presented and there is not a viable transport route for construction.

I am opposed to the HOG Wind Farm.