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DEVON NORTH WINDFARM PROPOSAL
APPLICATION FOR PLANNING
PERMIT by SYNERGY WIND PTY LTD
# 502416
10 July, 2006
DOCUMENTED NOTES, COMMENT
AND QUESTIONS TO COUNCIL IN RELATION TO THE
APPLICATION PERMIT.
The Permit Application by
Synergy Wind is poorly presented, disjointed, and thus awkward to read;
a compilation of consultant reports, AusWEA promotional sheets, charts,
maps and photo montages, interspaced with Synergy Wind comment. The following
comments follow the sequence of documents as presented in the Permit Application.
You will therefore find that this report is disjointed, just as is the
Permit Application.
APPLICATION
Who has provided the information?
The name of Applicant on
the Application for Planning Permit form, is entered as Synergy Wind Pty
Ltd. It has been signed by private consultant Bill Barber who is a consultant
to Synergy Wind.
Bill Barber is a member
of William G. Barber and Associates, of Traralgon, Victoria, whose letterhead
indicates ‘Regional Business Strategies'. It was Bill Barber who represented
Synergy Wind at their ‘open day' in Yarram in December 2005.
Comment:
Surely it is not admissible
to have a consultant sign an Application for Planning Permit for a $40
million project. There is no indication of who is Synergy Wind Pty Ltd,
with no identification of personnel nor responsible officer. Signing on
behalf of the applicant is one thing, but not knowing who the applicant
is, is another matter. Surely the question of accountability is important.
There is no financial or
legal documents presented as to the existence of Synergy Wind Pty Ltd,
and as to their ownership. It is understood that Synergy Wind Pty Ltd is
ownbed by German interests with a start-up capitl of $200
Question
to Council:
Is
council concerned with the financial viability and responsibility of any
commercial applicant who wishes to construct an industrial complex on rural
land , and in particular reference to a project that is claimed to cost
$40 million.
The ‘Notice of an application
for planning permit', sent to the neighbours is also not clearly identified.
It is signed above the name Synergy Wind Pty Ltd, but no individual's
name is offered. We are left to presume that it is Project Manager, Christian
Spitzner, with whom we are yet to meet. Overall, this notice to neighbouring
residents, as required by the Wellington Shire, is totally unsatisfactory,
being inept in its content and most unprofessionally and carelessly presented.
WIND ENERGY APPLICATION REQUIREMENTS
Two or More Dwellings. Page
2.
"There is a possibility
that a 10m x 10m transformer station will need to be erected on site".
The transformer would be
erected on the south side of Ingles Road, west of Stiney Creek bridge,
on property owned by N.Davis. The transformer station would be 160 metres
from the Stone/Bouker property. There are no details provided on noise
levels caused by the transmission station, which hs been annecdotally indicated
as beingt a cnstant ‘hum'.
Question
to Council.
Will
the erection of such a transformer station require a separate application
permit considering that there are no details presented for this structure
within this application. Alternatively, if permission to erect the transformer
station is to remain within this application, will council reject this
Permit Application and be asking for site details, and construction details
to be subsequently submitted with a new application.
Industrial. Page 2.
"Not applicable - construction
of wind farm only."
Comment.
A wind farm is an
industrial complex. It certainly is not a rural application. The generally
accepted euphemism of "wind farm" is mispleading. One does not 'farm' the
wind. A farm is "land in which crops or animals are raised'. To farm means
'to work on or operate a farm'. (Collins Australian Dictionary). Amusingly,
Christian Spitzner of Synergy Wind used the term "wind park", which, perhaps,
is more appropriate. Wind Turbine Complex is a more appropriate name, a
WTC. In Europe, it appears that turbines are referred to a Wind Energy
Converters, WECs. This is relevant in that the terminology is used by German-based
consultants in this Permit Application. Synergy Wind appear to prefer Wind
Turbine Generator, WTG.
Question
to Council.
Does
the council accept the fact that the proposed windfarm land is classified
rural, that a Wind Turbine Generation ‘windfarm' is not a rural activity
and is an industrial activity which does not come under current accepted
or defined use of rural land.
DEVELOPMENT PLAN. Page 3.
Throughout the application,
Synergy Wind make statements of what they will do and what will happen
in respect to the construction and operation of the windfarm.
Question
to Council:
What
measures and procedures are in place to ensure that all Synergy Wind promises
as documented within th Permit Application, are kept, and if not kept,
what procedures are in place to ensure that such violations of the permit
will be rectified, and appropriate penalties applied.
ADDITIONAL REQUIREMENTS BY
WELLINGTON SHIRE COUNCIL
Council has posed a number
of questions to Synergy Wind which the company attempts to answer in the
Permit Application. These should be considered when studying the document.
One question by Council,
re Landscape and Visual Assessment, needs to be considered in detail as
it appears that Synergy Wind have not answered the question in full.
SITE ANALYSIS AND DESIGN
PURPOSE
This eighteen page document
was also sent to selected neighbouring property landowners.
Page 3, Item 6, Adjoining
Land Ownership.
(*a) "Site adjacent to state
forest and rural grazing areas".
No mention of private residences,
nor corporation-owned (pine) forestry land. This omission is also noticed
in the maps provided. No mention of ownership of private, non-farming,
residences.
Page 3, Item 7, Adjoining
Land Use.
(*b) "Adjoining uses are
rural. Few houses adjoining the wind farm site".
This is a totally misleading
statement. Whereas the word ‘few' is open to interpretation, it gives the
impression that ‘few' people will be affected by the windfarm. Synergy
Wind are well aware that the windfarm site is inappropriately located next
to a residential strip containing no less than thirty houses, with many
more off adjoining roads. Synergy Wind is clearly trying to give
the impression that the proposed windfarm is isolated in a rural area where
is only affects ‘few' houses.
Question
to Council.
Is
Council satisfied with these statements, *a and *b above, by Synergy Wind,
which is clearly misleading.
Page 3, Item 8, Site Area
and Turbine Location.
"The nine turbine wind farm
was also chosen so that the amenity of neighbours will not be unreasonably
affected".
Again, another misleading
comment. It must be stressed that no executive nor staff of Synergy Wind
have consulted directly with any resident owner whose property borders
the proposed windfarm, and hence it begs the question as to how Synergy
Wind has managed to determine how "neighbours will not be unreasonably
affected". At least Synergy Wind is admitting that neighbours will be affected
in some manner, and it demonstrates the arrogance of Synergy Wind in determining
for themselves what is reasonable and what is not. Synergy Wind are, through
this communication, expressing how unprofessional they are in preparing
their Permit Application, and how ignorant (or unconcerned) they
are of community concerns.
Question to Council relative
the consultation process is listed below.
Page 4, Item 9, Electrical
Grid Connection.
"... 8.5 km of new line
required..."
The location of the line
is not indicated in the material sent to neighbours, however is included
in the Permit Application.
Page 4, Item 11, Noise.
"Only two dwellings within
500m but no dwellings within the strict noise contours of the ANZ standard
AS/NZ 6808. Reports from experts that we are within specified limits".
The comment gives the impression
that "only two dwellings", which are within the 500 metre radius, will
be affected by noise. It fails to mention any proposed residences whose
construction is on hold (Bain/Dohnt). It makes the presumption that any
residence beyond 500 m will not be affected by noise.
There is further mention
of noise later in the Permit Application.
Synergy Wind conveniently
offer no indication of what action they will take if noise levels are unacceptable
to neighbours, irrespective of documented standards. Synergy Wind
infer that there will be noise but offer no indication of what the increase
in noise level, over ambient levels, may be.
Page 4, Item 13, Shadow Flicker.
"In the case that a house
would be affected by shadow flicker, the offending turbine would be programmed
to shut down for the duration that this problem otherwise occur".
Synergy Wind offer no confidence
that they would actually do this, nor how they would do it. It would be
a true optimist who believes that as soon as the flicker shadow affects
a residence, that Synergy Wind would ‘turn off' the turbine. Synergy Wind
offer no indication how this would be controlled. If by programming to
automatically stop the turbine, why has Synergy Wind not attended to this
already, and given clear indication of the residences so affected. Synergy
Wind know where the turbine towers will be placed, know where the residences
are, and can thus deduce where flicker will be problem by a knowledge of
the sun's position during any time of the day and season of the year. If
such a study had been done, Synergy Wind should so advise, indicating which
residences are affected, and by which turbines. Synergy Wind have given
no assurance of what redress the neighbour may have if the promised action
of stopping a turbine is not achieved.
There is further information
on shadow flicker later in the Permit Application.
Question to Council relevant
to flicker is indicated below.
Page 4, Item 14, Electromagnetic
Interference.
"No direct microwave transmission
line of sight installations. Two dwellings within 500m".
This comment needs clarification.
Does it mean that only two dwellings will be affected?. It is generally
understood that at least two residences will be directly in line with the
turbines and Mount Tassie where television signals originate. It appears
that Synergy Wind have given little consideration to this event.
Question
to Council.
Will
Council seek assurances from Synergy Wind that no residence will be affected
by the construction of the proposed windfarm.
Page 5, Item 15, Visual Impact.
"Site is not within a significant
viewing area and not within any direct views to any features of visual
significance".
How presumptuous of Synergy
Wind to make such a judgement on our behalf. To the local community, the
view is most significant, and Synergy Wind are well aware that it is the
view that has attracted most of the residents to the area. It is another
example of Synergy Wind arrogance in not considering in any way the feelings
of the local community.
"The site is encompassed
by two no-through roads and a state forest".
Incorrect. It is not a state
forest - it is a commercial plantation. Also, both Ingles Road and Bolgers
Road are not ‘no through' roads.
Page 10, Map.
Although the map is provided
to show land contours of the site, only five turbines are shown.
It is significant to note
that this map, with its five turbines (not nine) was sent by Synergy Wind
to some neighbours in 2005.
Page 12, Map.
Only five turbines shown.
Page 13, Cultural Features.
Synergy Wind state that
a study by the Gippsland Cultural Heritage Unit at Sale recommended that
an overseer be on site when each foundation is dug "to ascertain if there
were any artefacts therein". Synergy Wind mention the report, but do not
indicate that they will indeed advise or encourage such an overseer onto
the construction site.
Page 17, Map.
Map provided in the Permit
Application is barely legible. Same map provided in documentation to neighbour's
is readable.
The is titled, ".. showing
the wind turbine layout and dwellings within a 2000 metre radius of the
site". The map is clearly incorrect, with only a dozen houses indicated
within a kilometre, and with many houses omitted (and sheds shown as dwellings).
The location of several houses is incorrect, and some existing houses not
shown. A farm shed and a dairy is shown as dwellings. Mistakes can occur,
but this demonstrates that Synergy Wind have given scant concern to the
accuracy of their submission, particularly when they have been advised
of the errors. The map does not indicate any proposed dwellings.
It is interesting to note
that the site of one proposed dwelling would be within one hundred metres
of a turbine (Bain/Dohnt property) and the sites for other existing dwellings
are within 285 metres, 365 metres, 520 metres, and with a further nine
existing homes within 900 metres. So much for Synergy Wind's assertion
that there are few neighbouring residences.
Page 18, Summary.
There is no indication by
Synergy Wind as to the noise levels emanated from sub-station, which is
known to generate noise. This is of vital importance to the nearest
residence which is 160 metres distant. .
DEVELOPMENT PLANS
Photo montage.
The significant point here
is that the photo were taken in April 2005; Synergy Wind have been requested
to provide montages from significant locations for the past six months,
yet none have been provided.
Note that Synergy Wind provide
no montages from residential properties, specifically from those residences
and proposed residences within 500 metres. This would give a much more
dramatic indication of the intrusion of the 120 metre towns so close to
a dwelling.
The photo montage showing
the shed and house, shows only six turbines. (The house is that of the
Reakes family. The Lynch family residence is to the left, out of the picture,
and closer to the turbines).
The photo montage with the
tree is taken from Ingles Road, and shows only seven turbines. The Stone/Bouker
residence is to the left, out of the picture.
Temporary Site Facilities
- Plan
Note the construction of
a work site area complete with car park, between Bolgers Road and WTG #
1.The Construction Site will be 300 metres from the Heibert property on
Bolgers Road.
Questions
for Council.
What
restrictions and procedures are in place to ensure the least disruption
to neighbouring properties as a result of the location of the construction
site, viz noise, traffic, dust, vehicle pollution?
Is
council concerned that the site, on rural land, will be used for construction
and assembly of the towers and blades, with its incumbent noise and dust
polution, on rural land?
Development Plan - Plan
Note that three kilometres
of maintenance track will scar the land. All maintenance tracks will be
accessed by one entrance from Bolgers Road.
Note that the scale indicated
on the map is incorrect. The scale shown should be doubled. Note that the
grid is one kilometre.
ENVIRONMENTAL MANAGEMENT
PLAN (Eight pages)
This is a planning document
indicating what should be done, not what will be done. It is imperative
that the tasks agreed to be undertaken by Synergy Wind are adhered to,
hence measures to measure such tasks must be in place. In some instances,
neighbouring property owners will be able to measure and report on such
tasks, such as construction operation hours, dust control, noise.
Page 6. Noise.
Note that construction times
are set down as from 7.00am to 6.00pm week days, and 7.00am to 1.00pm on
Saturdays.
Question
to Council.
What
procedures will be implemented to ensure that these times are not exceeded,
and what procedure should be followed in order to report a breach of any
of the activities as laid down by Synergy Wind in the Planning Application.
Page 7. Traffic.
Mention is made of mobile
concrete batch plants to be located at Devon North. There is no indication
as to where these will be located. Factors such as noise and dust, and
general disruption, have not been mentioned.
Question
to Council.
Will
Council seek advice as to the manner of use of these ‘mobile concrete batch
plants', with respect to their noise and dust pollution.
Page 8. Decommissioning.
Comment: What is to
stop Synergy Wind "doing a runner" when the windfarm is no longer financially
viable?
Suggestion:
Determine today's
cost to decommission and dismantle the windfarm. Obtain this amount from
Synergy Wind, and place in an interest bearing account. Pay Synergy Wind
appropriate interest, less administration, less inflation costs, such that
at the end of any period there are sufficient funds to dismantle the windfarm.
Question
to Council:
What
measures will council put in place to ensure that Synergy Wind complies
with their responsibilities in "at least 25 years" time, when the windfarm
may be decommissioned.
ACCESS ROADS AND CRANE AREA
FOR TUBULAR TOWERS
Note the amount of expected
traffic during construction times:
- 35 concrete and
building vehicles
- up to 18 heavy lorries
for crane erection
- approx 10-12 heavy
lorries with turbine components
- max. vehicle length
40 m.
- max. overall weight
130 tonnes.
What is the meaning of these
figures?. Does it indicte the number of actual vehicles used, which is
immaterial. There are no statistics as to the traffic frequency of of Bolgers
Road. It is estimated that some four hundred concerete-truck journeys will
be required on Bolgers Road.
CONNECTION TO THE ELECTRICAL
GRID
Connection to the main grid
will come off the windfarm property at the south-east corner of the property
(thus at the bridge over Stoney Creek on Ingles Road), and then SSW across
Davis property, turning ESE to join the main 66kV grid at what appears
to be the intersection at the end of Church Road with Old Whitelaws Track
and Davis Road.
The transformation station
is to be located on Ingles Road, west of the Stoney Creek bridge. No noise
figures have been presented. This is of concern to the Stone/Bouker property
which is within 160 metres of the exit point from the windfarm property.
Question
to Council:
As
Synergy Wind have not given any details of the transformer station, nor
any indication of the noise generated from such a station, what procedures
will be implemented to ensure that neighbouring houses (specifically the
Stone/Bouker property within 160 metres) will not be disrupted by the continual
humming noise of the station.
SP AUSNET CONNECTION PROPOSAL
This covers specific licenses
and requirements in order to connect to the grid, and is of little concern
to neighbours except for those within proximity of the transformer, and
those landholders on which the connecting cables will be constructed.
It is interesting to see
a 'Preliminary (Works) Program', whereby construction is expected to commence
in April 2006, and completed in April 2007.
It is interesting to note
that the connecting cabling from the windfarm to the 66kVA grid, will cross
over the main Jack River telephone line servicing all of Devon North.
Question
to Council.
Is
council concerned that the connecting line may cause interference with
the telephone services to Devon North?
INFORMATION ABOUT THE LOCATION
OF THE DWELLINGS WITHIN A 500 METRE RADIUS OF THE SITE
Once again, the map provided
is incorrect with respect to the location of houses.
Of particular interest:
There is a table (of potential
visual impact sites), showing the location of dwellings and specific details
of dwelling windows, sizes, height, and a comment as to whether the 'Wind
Farm (is) Visible' from the dwelling.
Property B (Stone/Bouker)
has indication that NO, the windfarm will not be visible.
Likewise, NO visibility
from properties G (Heibert), F (Reakes), E (Lynch), I (Strobel), J (Jung),
M (Burgoyne), and O (Handley).
These are clearly incorrect.
Properties B and H, two of the closest to any WTG tower, will be have a
severe visual impact. Synergy Wind are no doubt aware of this. Also, it
is obvious that if property H (Harrington) has visual intrusion, then certainly
property G (Heibert) will have worse - a brief visit to the location will
recognise this.
Question
Council:
Is
Council concerned abouut the inaccuracy of the map and would Council consider
having Synergy Wind provide the correct information before further consideration
of the Application Permit?
Note: A plan, provided later
in the application, indicating visual impact within a two kilometre radius
of the windfarm, clearly shows that, for example, property B (Stone/Bouker)
will see all nine turbines. (It is accepted that even this is not true,
as some turbines will be hidden by vegetation).
Comment:
It begs the question as
to how Synergy Wind knew the exact dimensions of the windows on my property
(B). Have they trespassed on my land in order to make measurements? The
relevant windows face north and north-west, with no visual access from
any public point, nor the Helleren property. If they have not entered the
various properties, how do they know of the window dimensions?
CALCULATION OF GREENHOUSE
BENEFITS
The Wind Energy Ready Reckoner
sheet is totally misleading. Irrespective of any judgement on the veracity
of the data, the numerical values are incorrect in so far as our Australian
standards of numerical expression is concerned, and it appears that a European
standard has been used. Where a comma should be used to delineate a thousand,
a full-stop has been used, ie 107.081 trees should read 107,081 trees.
Likewise, where a decimal point should be used, it has been substituted
with a comma, ie 7,36% should read 7.36%. This begs the question as to
the concern of Synergy Wind to provide information that is within our common
understanding. As to the veracity of the data, it must be questioned how
16,569 cars will be ‘taken off the road'.
ASSESSMENT OF WIND FARM VISUAL
IMPACT
This document (pages not
numbered) includes a clearer, larger copy of the table of visual
impact sites as mentioned previously.
Of the fifteen 'sites' listed,
only five are indicated as 'Wind Farm Visible'; one of these is the windfarm
property, and one does not exist (but is possibly meant to be the Neiss
property at Five Ways).
These blatant errors indicate
some doubt as to the credibility of the consultants report, and should
have been picked up by Synergy Wind.
It is important to note that
report indicates: '... the visibility of the windfarm is prominent within
a 2 km radius'. And, ... the visibility decreases over 6km, 15km, 20km.
And ...' those areas where only part of the windfarm can be seen decreases
with distance...'.
Comment:
It appears that visual
impact study is not an exact science!! The bottom line is that the
report is clearly in error; whether this is by design or incompetence is
hard to say. And what is the relevance of including photographs of the
Toora Windfarm?
Comment:
Only two montages
have been presented - one from Bolgers road east of the Reakes property,
one from Ingles Road east of the Stone/Bouker property. No montages have
been prepared from any residences, which would thus clearly define the
visual impact. The AusWea standards clearly state: '.. developers are required
to prepare photomontages of how the wind farm will appear from (these)
vantage points. These photomontages can also play an important role in
the community consultation process.' Synergy Wind have clearly demonstrated
their inability to consult with the community, so it is to be expected
that they would not be concerned in providing photomontages from
the residences most affect. They were certainly asked on several occasions
to do so, with each request ignored.
PRELIMINARY FLORA AND FAUNA
REPORT
Prepared by consultant Biosis
Research.
An extensive report of 37
pages which, in reality, says nothing specific in respect to the actual
environment situation at Devon North.
On Birds, it indicates what
should be done to observe bird life. The suggests that DEH (presume meaning
DSE) should do a study.
On Bats, it states: 'Bat
monitoring can only indicate levels of bat activity on the site and utilisation/risk
assessment cannot be calculated for this group'. So that leaves them out
of consideration.
Summary as stated by Synergy
Wind:
'The site does not support
habitat that is considered important for any threatened fauna species'.
Comment:
- Much of the report is
based on overseas studies, and provides extracts from overseas scientific
papers.
- No mention of Powerful
Owl, nor Wedge-Tailed Eagle.
- Swift's Parrot (endangered)
is a 'rare visitor'. (How this was determined is not indicated).
See later document, Bird
Utilisation Study.
WIND FARM NOISE ASSESSMENT
REPORT
Consultant Report prepared
by DLC, of Germany.
This is a complex report
of seventeen pages.
Once again it utilises the
incorrect house placement provided by Synergy Wind as per maps previously
mentioned, whereby some houses are missing, others so indicated do not
exist. Noise level figures and graphs are provided for five properties
(one the windfarm residence), where sound monitors were established in
2005. The neighbouring properties are B (Stone/Bouker), E (Lynch), G (Heibert),
M (Forder). Figures for other properties have been interpolated from the
monitored residences.
In summary, as indicated
by Synergy Wind:
- the noise level at the
monitored neighbouring residences will be below the standard adopted by
the Victorian government, (NZS 6808).
- the Hellerens will have
the highest noise impact
Comment.
It is clear that several
residences will be above the accepted noise standard level, for both ‘worst
case' and ‘real' scenarios.
Question
to Council.
Will
Council reject the Permit Application on the grounds that the expected
noise levels will exceed the accepted Victorian government standards.
BAT ACTIVITY REPORT
Consultant Report by Biosis
Research, seventeen pages.
Of note:
- bat activity is highest
in spring and early summer, yet study conducted in autumn (April)
- study conducted using
an Anabat ultrasonic detector, operating from 1730 to 0700 hours, over
eight days
- five species of bats identified,
another four species presumed.
- conclusion: bat activity
in the vicinity of the proposed turbines is low. However, some mortality
of locally common species may still occur.
- real figures can only
be provided by counting the dead bats after installation.
BIRD UTILIZATION STUDY
Consultants: Brett Lane
and Associates. Twenty-six page report. Extensive use of tables of birds
observed. Extensive use of overseas reports, and also brief details of
experience on four Australian windfarm sites.
Summary, as presented by
Synergy Wind:
- birds observed and counted
for fifteen minutes at a time at eight sites, over ten days.
- no species of national,
state or regional significance was observed.
- recognition that turbine
blades do kill birds, but '.... generally (they are) able to avoid collisions
and do not simply fly into wind turbines'.
- site lies within the territory
of one pair of Wedge-Tailed Eagles, 'which used the site with very low
frequency during the (five day) bird utilisation surveys.
- expected bird mortality
for the Devon North windfarm is 9 to 36 birds a year, non of which are
a threatened species.
Note:
Consultants document the
presence of a pair of Wedge-Tailed Eagles. These are frequently observed
by residents.
Question
to Council.
As
a proposed windfarm in central Victoria was recently refused by the Victroian
Government because of the presence of a pair of Wedge-Tailed Eagles, would
this not set a precedent for the Permit Application for the Devon North
windfarm to be rejected.
APPENDIX - ASSESSMENT OF
OTHER POTENTIAL IMPACTS
SHADOW FLICKER FORECAST
Littman Consultancy of Germany.
Under the heading ‘legal
statement', is the statement:
It is understood that any
forecast based on computational simulation without the possibility of
on-site verification ... cannot be guaranteed... (My italics).
Does this mean that the
study was done without visiting the site? Possibly so, based on basic data
provided by Synergy Wind. One has to question the credibility of the study
by D.L.C Consulting, a German company (mentioned in respect that Synergy
Wind is German-owned), and also the credibility of Synergy Wind in presenting
a ‘study' that has not attracted an examination of the site.
The map included in the study
is the incorrect map included in several places within the Permit Application;
DLC provides shadow flicker for non-existent residences and cow sheds.
Included with the report is the aforementioned table that indicates that
several marked houses will NOT be able to see the windfarm. And yet the
report indicates that these same houses are indeed affected by shadow flicker.
The data presented is based
on the sunshine hours for Melbourne, some 200 km west of the windfarm site.
Devon North is in the same ‘climatic belt' as Melbourne but does not have
the same day to day weather patterns. The study also uses wind values
determined from the East Sale airport.
The report presents several
pages of what is defined as the ‘worst case scenario', then promptly denounces
these figures as bing unrealistic and should be dismissed. Then why present
them? The alternative ‘real case scenario', seems to be based on an adjustment
to the ‘worst case scenario' figures. Be that as it may, both figures should
be considered.
The report presents both
the (estimated) number of shadow flicker hours per year for each marked
property, for both the ‘worst case' and real scenarios.
Of the first six marked building
locations, the average ‘worst case' scenario is 124 days of the year with
shadow flicker, averaging 43 hours per year, at .393 hours per day (23.6
minutes). The same buildings attract an average figure of 11.76 hours per
year under the ‘real case' scenario. There are no figures presented
for the average number of hours per day of shadow flicker under the rea;
case scenario.
Note that the Australian
standard of what is ‘acceptable', is set at 30 hours per year. Clearly,
many residences will exceed this figure under the ‘worst case' scenario,
but, conveniently, are under in the ‘real case' scenario. It begs the question
as to how the real case scenario is determined.
Several homes however will
be over the accepted standard, both in ‘worst case' and ‘real' terms.
Note again Synergy Winds
statement in Site Analysis and Design Purpose, Page 4, Item 13, Shadow
Flicker.
"In the case that a house
would be affected by shadow flicker, the offending turbine would be programmed
to shut down for the duration that this problem otherwise occur".
Question to Council.
Is Council satisfied
with the figures presented in the Permit Application in respect to shadow
flicker, consider the base dta (from Melbourne and Sale) is not accurately
representative of conditions at Devon North.
Is Council satisfied
with the procedures in place to ensure that Synergy Wind will actually
close down a WTG when the resultant flicker from that WTG affects a residence?
IMPACT ON NEARBY AIRFIELDS
In a letter from the Civil
Aviation Safety Authority, to Christian Spitzner of Synergy Wind, 5 September
2005, the following statement is made:
Based on the information
provided to CASA, the planned wind farm will be a hazard to the operations
of aircraft due to the elevation of the turbine tips being above 110 metres
AGL, and up to 120 metres AGL. Therefore a determination will be made in
accordance with Part 139.370 of the CASR, that the proposed Yarram Wind
Farm will be hazard.
Note that Synergy Wind state
that the closest airfields are not affected by (the) proposal. (Site Analysis
and Design Purpose, page 5).
It is interesting to note
that CASA mentions the adequacy of lighting provisions ‘to ensure the safety
of air navigation'. The possibility of having the turbine towers ‘lit-up',
has not been considered before, and would be another visual intrusion.
Question
to Council.
Is
council concerned about the concerns expressed by CASA, and will these
be considered in their determination of the Permit Application.
RESULTS OF PRELIMINARY CONSULTATION
WITH RESIDENTS AND OWNERS
It is to be stressed that
at no time has any immediate neighbour had any direct consultation with
the Project Manager Christian Spitzner, who has indeed refused, in writing
or by ignoring invitations, to meet with the neighbours. The limit of their
‘consultation' has been documentation sent 7 September 2005 advising of
their intentions to construct a windfarm, and correspondence 3 July 2006
giving notice of the application for a planning permit.
An ‘open day' on 16 December
2005, was conducted by consultant Bill Barber. Project Manager Christian
Spitzner may have been in attendance, but if so his presence was not announced,
and thus there was no ‘consultative process' with any executive nor staff
of Synergy Wind Pty Ltd.
Barber reports in a letter
to John Traa, Team Leader-Statutory Planning, Wellington Shire, 19 December
2005, that eighteen people visited the open day and ‘were given an overview
and information'. It must be stressed that very little ‘information' was
made available other than the hand-out of AusWEA promotional brochures.
Specific questions that I, with three others, asked, were frequently not
answered as Barber simply did not have the answers. Christian Spitzner,
Project Manager for Synrgy Wind, did not present at the ‘open day'.
The letter indicates also
that Colleen Murphy, Environment Planner, Wellington Shire, attended and
‘she appeared satisfied with information supplied by Synergy Wind'. Discussions
with Murphy on shire policy, benefits and concerns of windfarms, and the
proposed location of the windfarm generated what could only be described
as a non-informative stance and the comment "I like windfarms'. So much
for the consultative process. (Ms. Murphy is no longer with Wellington
Shire).
Barber also writes:
‘It would appear on balance
that given the amount of publicity and the response, that the Open Day
provided those who were interested, an opportunity make representations
to the company.'
Synergy Wind have indicated
that their ‘community responsibility' ended with the ‘open day', and Spitzner
has refused to speak in person to anyone concerned about the proposed windfarm.
The conduct of Synergy Wind as ‘a good corporate citizen', as quoted by
Barber, is arrogant, and Synergy Wind have even defied the AusWEA standards
of hat is deemed to be ‘community consultative process'.
By including the docuemtns
presented within the Permit Application, Synergy Wind are attempting to
persuade that they have adequately consulted with neighbouring residents.
Question
to Council.
Is
Council satisfied that Synergy Wind have adequately and professionally
consulted with neighbouring property owners, and given consideration to
their concerns, prior to submitting the Permit Application.
ENVIRONMENTAL EFFECTS STATEMENT
Advice is given that a meeting
was held between Ms Susan Taylor of DSE, Ms Colleen Murphy of Wellington
Shire, and Mr Daniel Gilmore of Biosis Research, to discuss environmental
issues,. The conclusion, as per the document in the Permit Application,
to the question (does) the Minister require an Environmental Effects Statement,
is "not applicable". The meaning of this is not clear.
An interesting note. There
was a fourth person who attended this meeting, a male of European nationality,
who. although he did offer a name when questioned, the reply was incomprehensible,
possibly because of the language barrier. Who was this mysterious person
who sat quietly at the back of the room taking copious notes during the
‘open day', but who did not offer an introduction until so requested by
visitors? Could it have been Synergy Wind's illusive Project Manager, Christian
Spitzner.Spitzner claims to have been present at the ‘open day'.
If present, why did he not make his presence known?
MATTERS PERTAINING TO CLAUSE
55.01.01
"There are no existing buildings,
including farmhouses and farm out buildings, located in close proximity
to the proposed location of the wind turbines.."
Comment:
Really!! This generalised
and incorrect comment defies credibility.
"The wind turbines are located
well away from any land boundaries, including rural roads..."
‘Well away', ? What can
one say? How can Synergy Wind say that a turbine tower within 50 metres
of Bolgers Road is ‘well away'. How can more than a dozen private residences,
clearly to be affected by noise, flicker, visual intrusion, traffic disruption,
and construction noise be regarded as bing ‘well away' from the windfarm?
Question
to Council.
Is
Council satisfied with the generalised and unqualified statements that
are presented in the formal Permit Application.
WRITTEN DESCRIPTION
Dated 16 December 2005, this
is a duplicate of the same document as previously included in the Permit
Application, and is the same as the letter from Synergy Wind to some neighbours,
dated 7 September 2005.
MEDIA RELEASE
From the Office of the Premier,
2 November 2005.
From Auswind: Wind energy
industry welcomes Victorian renewable energy scheme, 2 November 2005.
(Of course they do. Auswind
is AusWEA).
Note that as of early 2005,
Synergy Wind was not a member of AusWEA, yet they always used their promotional
brochures, and have avoided a close adherance to their quidelines.
And finally, seemingly as
an afterthought:
ABORIGINAL CULTURE HERITAGE
Correspondence from Bill
Barber to ‘Rob' of ‘Culture Heritage'.
(Rob Doultat, Gippsland
Cultural Heritage Unit).
Question
to Council.
Will
Council implement measures to ensure that a cultural adviser is present
on the construction site during any excavation?
Finally:
Question
to Council.
Is
Council satisfied with the overall standard of the Permit Application,
in that it provides all the data required in order for Council to make
a decision on its approval or otherwise, and in that it can be understood
by the resident/ratepayer?
If
Council is not satisfied with the standard for such an application,
will council request Synergy Wind to resubmit a Permit Application with
all, and correct, data. |
