Hills of Gold Wind Farm

Ref: Hills of Gold Wind Farm Amended Application (SSD – 9679)
(see Full Attached Submission "HOG WF Nov 2022 Timor Submission (UHSC)"

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 have failed to respond adequately to concerns from the Upper Hunter Council (UHSC) in their correspondence with NSW DPIE dated 29th of January 2021 (attached).
• Engie have not responded at all to the letter from the Upper Hunter Council (UHSC) to NSW DPIE dated 8th of March 2021 (attached).
• The proposed development breaches multiple areas of the UHSC Development Control Plan 2015 (Table attached)

Action Requested:
o Engie formally respond to the UHSC letter dated 8th of March 2021.
o Engie fully comply with the UHSC Letter dated 29th of January 2021
o Engie HOG Farm proposal to comply with the UHSC Development Control Plan 2015, to ensure the community’s safety and protect the Upper Hunter Environment.

Summary Assessment of UHSC Letter dated 29th January 2021
See attached Table 1 Attached

Summary Assessment of UHSC Letter dated 8th March 2021
See attached Table 2 Attached

The location is remote with terrible access. The landscape will be decimated to allow for roads and construction to occur. The roads in the area are thin and windy and steep and terrible for existing traffic let alone extra trucks and worker traffic. The land and outlook is stunning, and part of why people have spent good money to buy and live in the area and a wind farm would pollute this and completely ruin the area and vista, and lower the value of peoples homes. The topography and access is completely wrong for this project, and will ruin such a historic and beautiful area that relies on its beauty and tourism to thrive.

I object.....see my submission file attached

Please find my objection attached

Please find attached a submission objecting to the proposed Hills of gold Wind Farm.

I object to the grant of the Hill of Gold Wind Farm application as set out in my attached submissions.

I support the Hills of Gold Wind Farm proposal ID SSD-9679.
This project will benefit several communities both socially and economically by increasing employment opportunities, upgrading infrastructure ie roads, cheaper electricity and through other possible flow-ons, eg eco-tourism. It will also assist the environment by providing green energy I understand that there may be some disruption during the construction phase however I think the benefits of this project will outweigh the negatives.

I wish to lodge a complaint against the Hills of Gold Wind Farm
Wind farms are a danger to raptors and the koala.
BIODIVERSITY
It is unacceptable to disturb 447 hectares of vegetation, including 46.2 ha of koala habitat.
Removal of WTG 41 and minor movement of 19 WTGs does not remove the barrier effect to birds and bats returning to home roosts between the project area and Ben Halls Gap Nature Reserve.
Aerial firefighting around wind turbines remains seriously compromised, being at pilots' discretion, the most reliable and highest water source and landing area unavailable due to siting of infrastructure.

TRANSPORT
No viable transport route to the project area due to steep topography, lifestyle properties, tourism, lack of landholder permissions, and undetermined Native Title Claim and Aboriginal Land Claim.
Unacceptable impacts to residential and business areas of Nundle, Hanging Rock, Crawney and Timor.
Volume of street and roadside tree and soil removal not transparent.
Disruption to movement in and around Nundle, Hanging Rock, Crawney and Timor from construction of up to eight new bridges between the New England Highway and the project area, construction of a private road behind The Peel Inn, No Parking exclusion zones on left lanes of Oakenville and Jenkins St during blade deliveries, 311 additional daily vehicle movements (including 156 daily truck movements - 101 trucks through Hanging Rock village), and six daily Oversize Overmass vehicle movements for nine months.

VISUAL
CASA requires two red steady lights for 28 turbines (56 obstacle lights total), polluting our dark night sky.
Proponent does not provide photomontages of impact of cut and fill for wind farm infrastructure, reshaping the profile of the range.

HERITAGE
Proponent does not assess the potential impact of wind farm and transport impacts on the curtillage of Nundle heritage listed buildings.
Proponent does not address impacts to Bicentennial National Trail across Crawney Pass.

CHARACTER
Proponent does not acknowledge impacts of constructing or operating wind farm infrastructure to residences and businesses, including The DAG Sheep Station wedding and country music venue, Crawney Pass National Park, Teamsters Rest Recreation Area, Sheba Dams, Riverside Park, and Nundle Sport and Recreation Ground.

ENGIE'S INDUSTRIAL WIND WORKS SUBMISSION



"FARM" is such a nice smooth gentle word, reminiscent of McDonalds . . . and bringing forth images of fluffy white lambs gambolling around on a velvet field of luxuriant green.

"INDUSTRIAL" is what these things are, monstrous great big mechanical works thumping around disturbing the neighbourhood, full of oil. And self destructing in flames one in a thousand times per year, which for 100 over 20 years, is not merely 2 but as you remember multiple birthdays being quite likely in your school class, maybe occurring 6 or 7 times. And probably similarly likely to throw a blade or two.



There is considerable community push back to renewable projects. In the US over 471 wind farms had been rejected by early October. Source robertbryce.com. The US communities do not want them, and nor do the Australian communities.

GO BACK FROM WHERE YOU CAME, WE DON'T WANT YOU.


I object to paying subsidies. If it is so good, let it stand on its own merits.

I especially object to providing government subsidies, as money is better spent directly on the environment, and the contingent liabilities will reduce our credit standing.




As each new wind construction and solar works come online it makes the grid less and less reliable. Up to 50% renewables may just about be handled by 33% spare capacity in fast response coal and gas. No country has successfully gone beyond that. So double down with even more renewables? No judicial area in the world has achieved 100% renewables, even with twice the capacity.



I ask the proponent to itemise:

1. Public monies. Detail the description and dollar amount of each subsidy, and other benefit, both direct and indirect, to be received from the public purse in a time line. Indirect benefits, including the value of a government guarantee, need to include an actuarial calculation.


2. Itemise the amount of materials needed to manufacture and construct all parts of this project. Including rare earths, where they are going to be sourced from and disposed to.


3.Itemise the amount of CO2 released in all aspects of creating this project, and compare it with the anticipated CO2 to be saved. with timeline, including from the loss of vegetation from the site and connecting roads and transmission lines.


4. Detail the change to global carbon dioxide levels and temperature to be achieved by this project both in gross terms and net after 3. above.


5. A calculation of energy in to energy out to create the project.


6. Detail how the turbines and blades will be recycled or not and amount of material to be disposed of and where.


7.Detail the number and skill level of the jobs to be created and to be exported.




I request the Planning Department:

1. To require a bond or irrevocable third party AAA guarantee for damage repair, removal, rehabilitation, and toxicity to third parties.


2. To ensure that NO SLAVERY or CHILD LABOUR be used in the manufacture of any of its components.


3. To require the proponent to publicly provide annual reports for the project, including itemisation of each government support, and where those are indirect, an actuarial calculation of their value to the proponent and cost to the economy, and 5 min generation and supply.

4. To provide annual ESG reports.

5. To make the project, and its owner non transferable.


6.That adequate environmental safeguards be required for fire and toxicity.


7.The fire and toxicity of BESS have adequate safequards.

8.Require the proponent to provide and pay for their own connection costs to the grid upfront.

9.Require the proponent to pay the costs of transmission upgrades based
on their proportionate capacity, upfront.
10.Require strict limits on the frequency and voltage of acceptable supply.

11.Impose severe penalties on supply contracted for but not delivered.

12.Require effective braking to enable supply in high wind conditions.

13.I further ask the Planning Department to apply the Precautionary Principle in relation to the uncertainty of the net benefits, and the known and likely risks to the environment, to reject the proposal.




REJECT THE PROPOSAL.

Submission attached.

Dear Mesdames and Sirs
This is a Submission is in objection to the project Ref No SSI-10046
The TRRRA is a non-profit association whose charter is to represent to Tamworth Regional Council (TRC) and other government bodies on behalf of TRC residents on matters that affect their interests by any person, organisation or government body.
The below comments are made as a matter of public interest to assist Tamworth Regional Council in its decision making.
The proposed Dungowan Dam in the Peel River catchment is estimated to cost $1.3 billion to provide only an average of an additional 7,000 ML per year and will not secure Tamworth water supply into the future. This water would cost an estimated $70,000 per ML while much cheaper alternatives are available. The proposal to build the Dungowan Dam is constrained by the terms of references set by the State and Federal Governments.
There are two major criticisms of the proposal for Dungowan Dam:
First, the Federal Government has announced on 25 October in the Budget that funding will be deferred for four years, saving $900 million on the budget over that four year period. There is no current funding for the Dam and it seems unlikely to emerge in the foreseeable future
Second, the water sharing plan, whether a new Dungowan Dam is built or not, would ideally include a section or clause, giving power to Tamworth Regional Council to require immediate arbitration, or mediation, with recourse to the Land and Environment Court and appeal from the Land and Environment Court to the Supreme Court of NSW if there was failure to agree between Water NSW and/or its successors and or the Minister for Water and or their successors, if Tamworth Regional Council determined that releases were excessive. That section or clause should also require that all releases from Chaffey Dam and/or Dungowan Dam shall cease except for the minimum environmental flows and the Tamworth water supply during the continuance of arbitration, mediation or appeal to the Courts. A repetition of the management of Chaffey Dam that occurred between 2017 and 2020 in the Peel Valley cannot be countenanced.
We regard the EIS as being competently prepared by the Water NSW personnel within the terms of reference that they were provide with, but however make the following points:
1. The Environmental Impact Statement (EIS) fails to comply with the Secretary of Planning assessment requirements (SEARs).
The EIS does not:
 analyse and optimise alternatives;
 assess all threatened species including those listed under Federal law;
 provide all assumptions used in modelling.
 
2. The project will not meet its objective to provide the most cost effective or efficient option for securing Tamworth water supply:
 There is no analysis of the benefits of the proposed Tamworth Regional Council industrial water recycling project;
 The EIS fails to identify industrial use of town water supply. In Tamworth up to 50% of potable water supply is used by three large meat processing plants;
 Options analysis was constrained by terms of reference developed in 2015 and does not reflect current best practice;
 Limited options were analysed in the summary business case.
3. River health impacts:
 Loss of 192 km2 of high quality native fish habitat and loss of migration opportunities for Federally listed threatened Murray Cod, Silver Perch and Eel-tailed Catfish;
 Dungowan Creek is within the threatened Lowland Darling River aquatic ecological community. Offset measures for impacts on threatened native fish are not adequate;
 Dungowan Creek and Peel River have a healthy Platypus population that will be genetically separated;
 The loss of flows in the Peel River will cause a failure to meet the Environmental Water Requirements of the Murray-Darling Basin Plan and impact on environmental health of the Namoi River catchment.
4. Biodiversity impacts:
 A significant area of critically endangered ecosystem and Koala habitat will be cleared, including habitat for many other endangered mammal and bird species
 The EIS fails to assess 18 threatened species known or likely to be in the area of impact including 6 threatened species protected under Federal law such as the Greater Glider and 2 critically endangered plants.
5. Aboriginal cultural heritage impacts
 Many sites of high cultural significance will be impacted;
 Many sites require further research and not all of the pipeline easement was assessed;
 There are no cultural flow allocations in Dungowan Creek or the Peel River.
6. Cost impacts
 The political promise that all construction costs will be granted does not meet current user pays policy for new water infrastructure in NSW and increased water costs will be imposed by IPART;
 Taxpayers of NSW do not want to pay for a project with no cost benefit and significant environmental damage;
 The Federal Productivity Commission deemed the project poor value.
7. Social impacts
 The required workforce will compete with other industries and intensify labour shortages;
 Regional infrastructure spending to fix flood damaged roads should be prioritised;
 Local jobs were not generated by Stage 1 pipeline project – it was constructed by FIFO workers;
 Local concerns raised about loss of river flows and fish populations;
 Loss of cultural connections and place.

Yours sincerely,
Tamworth Regional Residents and Ratepayers Association

As a freelance journalist based at Nundle for 22 years, I have written many stories on Nundle property and business owners, and events.
The highly scenic landscape has been central to my ability to interest editors in stories about Nundle and Hanging Rock.
The physical beauty of the range helps Nundle punch above its weight for lifestyle media attention in national publications including Galah, Country Style, Australian House and Garden, Open Road, The Australian and The Sydney Morning Herald.
Nundle has hosted some of Australia's leading editorial photographers and attracts freelance photographers who photograph the landscape and people in it.
The proposed Hills of Gold Wind Farm will change 24km of a 1200-1400m elevated ridgeline. The photomontages and Truescape computer generated video provided by Engie do not adequately depict the visual impact of construction on the range, particularly clearing for roads, and turbine foundations.
The videography and photography of Far North Queensland wind farm construction by Steven Nowakowski is a more transparent visual reference.
The proposed Transverse Track and Western Connector Road would be engineering challenges given the 20-<50% gradient of the range. The community has not seen any plans or photomontages for the Transverse Track and Western Connector Road, and consequently there is considerable uncertainty and risk regarding the environmental consequences of building them (visual impact, habitat and soil removal, soil erosion and mass movement).
Looking at a topographic map it is difficult to imagine the cut and fill required to even build the 25m diameter wind turbine foundations in narrow sections of the range where there will need to be significant cut and fill. That has a visual impact beyond the turbines and foundations themselves and it has not been transparently communicated. I saw a reference for up to 10m vertical batters, but the reference didn't specify where they would be, foundations or internal roads?
Similarly, proposing to locate five elements on a shelf at the Crawney end of the project area creates another visual eyesore. An Operations and Maintenance Building, Construction Compound and Carpark, Battery Energy Storage System, Substation, Concrete Batching Plant and Transmission Towers/Wires/Easement will industrialise what is now private grazing land and woodland, neighbouring The DAG Sheep Station, Crown Land, Teamster's Rest Recreation Area, and Crawney Pass National Park. The route itself is part of the Bicentennial National Trail.
In addition to the visual impact of clearing on the range there is a need for roadside and street tree removal. This will add to the reduced visual amenity of residents and visitors.
The entrance to Nundle, frequently photographed for its spectacular autumn colour is proposed for a private road and carpark.
The proponents of Hills of Gold Wind Farm do not share the same values as the local majority opposing the wind farm. There is no social licence for the destruction proposed.

Submission attached

Please find attached my OBJECTION to the Hills of Good Wind Farm amendment Report No.2

The negative effect on the environment, the loss of the iconic vista of the ranges and the unsuitability of the roads for the construction traffic make this proposed project unacceptable.
please refer to the attached letter.
thank you

1. I would like to thank Planning NSW for the opportunity to comment again on Engie’s flawed proposed project for Nundle and Hanging Rock area. I am not an opponent of renewable energy projects, but I strongly believe such proposals should be located in appropriate locations, not simply dumped here or there because of the existence of electricity infrastructure and it shouldn’t be at the expense of the environment which this project is. I do believe at some stage soon the Department is going to have to determine the application and leave the community in peace and get on with their lives.

2. When the project is expired there is no proposal by the proponent for subsurface remediation or bond retained to remediate the area, so the large concrete and steel pads and indeed redundant turbines are retained in the earth and the precious native vegetation and wildlife habitat gone forever. This needs to be addressed now, not in 30 years and undoubtedly several owners/operators later. This will leave a legacy for the local community and NSW taxpayer to remedy if not addressed now. The omission of a remediation plan or bond reduces the social licence of such a project that will be a blight on the environment for more than a generation(s).

3. In relation to the site proposed for this project I have grave concerns for strategically important biodiversity of the region, the environment, endangered species including Koala and plants, water catchment area, heritage and visual amenity. Old growth trees which are habitat for a number of endangered species including Koalas will be impacted by this project if they haven’t already by reckless clearing. The main property owner and proponent pre-empting an approval by the NSW Government, has already cleared many trees along sites proposed for turbines harming the precious biodiversity.
4.
There are impacts on tributaries that flow into either the Peel or Barnard rivers such as contamination and erosion, impacts on heritage and impacts on visual amenity. There should be sensible sighting of large-scale renewable projects, not large expanses of renewables on ridge lines, particularly as beautiful as those at Hanging Rock and Nundle.

5. The project is unlikely to realise the economic bounty promised to the Hanging Rock and Nundle communities, construction workers and contractors are likely to be FIFO, not situated locally and the projects annual Community Enhancement Fund of $2,500 x 64 turbines will be shared between at least three local government areas.

6. The new proposed routes through Nundle village seem poorly considered and will still see impacts to vegetation including precious native vegetation – Happy Valley Road, Oakenville Road, Barry Road and impacts to the heritage buildings of the main street – Jenkin Street, in terms of vibration and noise as well as street tree impacts. Then the impacts to the two bridges on Crawney Road and further felling of native vegetation. I see there is also further clearing not far from Teamsters Rest, again pre-empting project approval when there isn’t currently approval.
7.
In summary I believe the applicant has not addressed the impacts on the Nundle and Hanging Rock communities during construction and operation; biodiversity considerations; native flora and fauna; the environment generally; the need for removal of large quantities of native vegetation; the large quantity of native vegetation already cleared by a proponent without authorisation; the large quantity of water for construction of the concrete turbine pads given the possible relative scarcity of the resource in drier times; bird and bat strike by the turbine blades during operation; visual amenity; heritage; safety of proposed roads in the vicinity of the Nundle village and Crawney Road; access of vehicles through private properties; impacts on water catchments - Peel and Barnard rivers and McDivitts creek; the paltry figure proposed for the Community Enhancement Fund per turbine over three local government areas; the number of jobs promised during construction and operation; exaggerated community support for the project. I believe the project has adverse impacts on the land of high biodiversity significance, heritage and tourism that ultimately requires the protection of aesthetic values and includes land identified as critical habitat under the Biodiversity Conservation Act, 2016 and the project should be rejected.
Mark Rodda
7 December 2022

I object strongly to the proposed Hills of Gold wind project on the following grounds.
1.Biodiversity destruction including- Destruction of 440 ha of native trees and fauna habitat including particularly Koala Habitat. We are being asked to sign up for hosting Koala Preservation areas by the Government on the one hand and being told that habitat destruction is condoned on the other. Destroying the environment to save the environment?
2. Stress on road systems and infrastructure resources
3. Construction of access roads on extreme gradients
4.Mental stress on neighbours and community in general during years of protracted negotiation THIS IS A SERIOUS MENTAL HEALTH ISSUE for this and other similarly affected communities and is being ignored.
5. Inequality of community status.. ISEPP Amendment document acknowleges contra effects of these projects on Albury, Armidale, Bathurst Dubbo, Griffith, Orange, Tamworth, Wagga Wagga and legislates an exclusion Zone of 10km
Why were these towns chosen.
What about Nundle,Walcha , Uralla, Guyra etc .
Is it an attempt to placate the large voting centers. Is it political. Double Standards
6. Visual Amenity,obvious , particularly the red lights.
7. Lifestyle

I object to this proposal due to this wind farm not being suited to this area. The developers of such projects need to select sites carefully. I believe that any roads infrastructure they are proposing in the town of Nundle, is going to destroy the town and impact businesses and residents using the town center for their day to day living.
The no parking zones is a terrible idea considering we have limited parking already. This little township is a desirable place to live and many people have moved here to get away from the busy roads and construction activities. The developers are proposing to remove street trees, modify intersections, create a raised gravel road through the green paddocks just behind the pub, which will be the first ugly thing you see driving into the township. The visual effect of their proposed road works is tremendous and will deface the town. Added to it will be construction noise, traffic delays. They do not guarantee no interference with the school bus hours nor do they guarantee that there will be no night time traffic, construction or turbine components deliveries.
Many rural properties surrounding Hanging Rock and Nundle will be impacted. This beautiful area will be completely ruined and many people's views impacted. And their views is often the reason they moved here and bought their property in the first place. By taking away their views, the developers are taking away something that the people have paid for. The host land owner will be handsomely compensated and everyone else around impacted. So he is getting rich at the expense of other people, how selfish.

Name of submitter to be withheld. Organization name can be published. Refer attached letter for our reasons for rejecting this wind works proposal.
Yours Faithfully
Save Our Surroundings (SOS)

I am opposed to this project because of the impact it will have on the environment in the Nundle area. The roads and infastructure are not capable of taking all the through traffic that is proposed. It will lead to trees and even houses having to be destroyed and will block the main road into Nundle. Nundle is a picturesque tourist spot and many people rely on the tourists for their income. Not many will continue to visit if the peaceful and beautiful environment they enjoy is destroyed.