Thank you for preparing this important policy which seeks to shape and optimise the outcomes of State Significant Renewable Energy Developments in the Armidale Local Government Area. Its close relationship to the soon to be exhibited draft Policy for Community Engagement and Benefit Sharing for Renewable Energy Projects is noted. SLA would like to reserve the opportunity for further comment following assessment of the second policy in association with this policy.
Sustainable Living Armidale (SLA) has been active in the community since 2007 towards its vision of a thriving, proactive, self-reliant community with low carbon emissions, and its mission to raise awareness of the implications of the implications of climate change and depletion of natural resources, inspiring and empowering our community to build a more self-reliant, resilient and sustainable future. SLA strongly supports a just transition from fossil fuel energy sources to renewable energy along with a suite of other measures such as energy efficiency.
It is important that this policy identifies that it has been developed in response to the State Government roll out of the New England Renewable Energy Zone and associated State Significant Developments. This is reflected in the allocation of responsibility for the policy to the Economic Development Officer rather than the Sustainability Officer. The REZ developments could potentially be approved by the State Government without necessarily contributing at all to Armidale Regions Zero Emissions Goals but at the same time having adverse impacts on our landscape and on natural capital and ecosystem functions. As specified in the Framework for Climate Action, A Zero Emissions Renewable Energy Policy, Strategy and Plan is needed that is specific to Armidale LGA, identifying the budget commitments and delivering the programs that will enable the rapid and strategic transition to zero greenhouse gas emissions energy sources by 2030. It appears that these planning documents will need to be additional to the Renewable Energy policy on exhibition – hence the need to specify that it is a Renewable Energy Zone policy.
It is also important that council advocate strongly for the community’s desire for the region to lead a zero emissions future, which is reflected in Councils 2019 Climate Emergency Declaration and in the Framework for Climate Action produced by the Climate Emergency Working Group of the Environmental Sustainability Advisory Committee in 2020 and 2019 EcoARC — Greenprint for a Sustainable Future.
Through the Zero 30 project, Council has set a community wide net Zero emissions target for 2030. There is an opportunity to include in the REZ policy an objective to transition the LGA to a carbon neutral and zero waste future. This would give a yardstick to measure how each Renewable Energy Development proposal might contribute to the ARC zero emissions goal both through straight emissions reduction and through the Climate Active Carbon Neutral Standard (as per the Zero30 Project). Referencing the community benefits policy still to be adopted, the yardstick concept could also apply to a baseline for assessing community benefits.
While the Best Practice Charter for Renewable Energy Developments identifies a range of potential adverse impacts from developments and wording designed to minimise those impacts, each clause includes wording that does not bind the developer. For example, engaging with the community on plans for the responsible decommissioning and refurbishment/repowering of the site does not commit the developer to actually implementing actions towards responsible decommissioning (including seeking to and possibly paying extra to recycle or dispose of materials used). Council should advocate for changes to the Charter seeking binding commitments.
Through the policy, council seeks a challenging balance between fostering renewable energy towards the state transition from fossil fuels sources, economic development of our region and protection of the unique climate, land scape and environment of the region. We rely on good planning and ongoing community consultation by council in this regard.
Well informed assessment by ARC of environmental impact assessment information provided by developers to the NSW government is needed prior to development approval – council may need to pay expert skilled consultants in this regard. This should include assessment of adequacy of biodiversity conservation measures such as protection and enhancement of existing wildlife corridors and remnant vegetation, particularly along riparian areas and adjacent to significant vegetation communities. Completion of a Biodiversity Strategy and Plan by council would facilitate this process.
Pre construction assessment is also needed relating to the recyclability and durability of materials proposed to be used – cheap materials have in the past resulted in the medium term failure of some large renewable energy projects.
SLA strongly supports inclusion in the policy of measures to protect landscape, natural capital and ecosystem services as well as inclusion of measures to enable cost effective access to renewable energy for the local community and businesses.
Thank you for being proactive in developing this important policy.
Yours Sincerely, Helen Webb, Convenor, SLA
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