Submissions must be made by 11:59pm Wednesday 15 November 2023.

 

Please find below some tips and ideas for completing your DCCEEW online survey. Please don’t simply copy and paste from here, but use these points as ideas for your own submission. There is plenty of information on the website, including links to further reading so you can inform yourself.

 

Tip # 1: You can indicate whether you'd like your response made 'Public', 'Public & anonymous' or 'Private & anonymous' so please don't be put off by the 'About you' questions. Every response counts and if you tick either of the ‘public’ options, this ensures that your submission is seen, counted and not hidden away. 

 

Tip # 2: It is important that the government understands how our community values and uses its beautiful beaches and coastline so it appreciates what it is asking us to give up. This forms part of the 'social licence' needed by developers. Many people living in the Illawarra live here precisely for its lifestyle and natural beauty, often enduring long commute times just for this privilege. At the end of the survey, it provides you with an opportunity to upload documents or photos to show how you use and appreciate our beautiful outdoor coastal areas. e.g. If you surf, upload photos of your favourite break. If watching the sunrise over an unbroken horizon brings you awe, describe the mental health benefits this affords you. If the beach provides a place of refuge during challenging times, say this! As one resident said recently "I surf, I hang-glide; the ocean and air are part of my soul!" So, before you start the survey, find a photo - a personal one or online - and/or think about what you might like to write in this section.

 

Tip # 3: After the first few pages of the survey, it asks for your feedback on 'Benefits or Opportunities' and 'Concerns' across 5 areas:-

1. Environment

2. Community & onshore transmission

3. Fishing - recreational & commercial

4. Visual amenity (They don't ask you if you see benefits or opportunities in relation to this)

5. Other - any other benefits, opportunities or concerns you might have

 

To make it easy, we have set out the information below in the same order but, please remember to make it your own. 

 

There is also a list of questions on our 'Tell Us Why' page that you might like to pose in your submission.

 

On our 'EPBC Referral' page there is also some new information about the significant negative impacts the project will have both onshore and offshore that were revealed in BlueFloat's EPBC Referral 3/11/23

 

ENVIRONMENT 

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1. Marine life: 

• The proposed REZ runs on top of the protected whale migration pathway which is located <15km off the Illawarra coastline. The REZ is proposed for 10km-30km off the coast. This is the first offshore wind project to be proposed on top of a whale migration zone and this poses an unacceptable environmental risk. Every year, this whale superhighway plays host to thousands of humpback, minke, southern right and pilot whales as they move northwards to warmer water for winter then return in Spring with their calves. At this year’s annual whale census on 25 June 2023, ORRCA reported that 5,092 whales were sighted on that day, up by 1,847 on 2022. Source

• All forms of underwater noise from offshore developments can reduce the survival rate of marine animals due to their impact on navigation, mating and migration pathways. source E.g., Noise can mask important natural sounds, such as the call of a mate, the sound made by prey or a predator. These mechanisms, as well as factors  such as stress, distraction, confusion and panic, can affect reproduction, death and growth rates, in turn affecting the long-term welfare of the population. (Southall, Schusterman, et al 2000, Southall et al, 2007, Clark, Ellison et al  2009, Popper et al  2014, Hawkins and Popper 2019) 

• Some sub-populations of humpback whales – notably the Oceania population that includes Eastern Australian humpback whales - are listed on the International Union for Conservation of Nature’s Red List of Threatened Species as ‘vulnerable’, ‘endangered’ or ‘critically endangered’.  Under national environment law (the Environment Protection and Biodiversity Conservation Act 1999), all cetaceans are protected in Australian waters. Protection measures include:

  • the Australian Whale Sanctuary that includes all Commonwealth waters from the three nautical mile state waters limit, out to the boundary of the Exclusive Economic Zone (i.e., out to 200 nautical miles and further in some places), and

  • within the Sanctuary it is an offence to kill, injure or interfere with a cetacean with severe penalties applying to anyone convicted of such offences.

• Constructing an offshore wind turbine plant in the proposed REZ could also expose other cetaceans, such as dolphins to harm from underwater noise, subsea cabling infrastructure,  disturbance of their habitat and risk of collision from vessels used for pre-development surveys, construction, operations and decommissioning. source

• Targeted seismic testing of more than 300 locations to test seabed structures will involve blasting the seafloor with high-powered airguns every 10 seconds. These blasts, which reach more than 250 decibels, disturb essential feeding and breeding behaviours, mask communications between whales and dolphins, and injure and kill marine wildlife around the clock for years on end. source. 

• Even species who do not communicate by sound use the acoustic scene (or soundscape) to learn about and exploit their environment. source Thus, anything in the environment that interferes with the ability of a fish to detect and use sounds of biological relevance, such as the underwater noise from offshore turbines, could have a substantial impact on their fitness and survival. source

• Electromagnet fields (EMF) generated by the subsea inter array cables that carry electricity from each wind turbine to the export cables, may create barriers to migration and behavioural changes for sharks and rays. Other marine taxa such as fish (e.g., eels and salmon) and marine reptile (e.g., turtles) also use geomagnetic fields to guide migrations and so could be negatively impacted. Crustaceans have the ability to detect and utilise Electromagnetic Frequencies with a relatively high degree of sensitivity and environmental fluctuations caused by offshore turbines have been shown to have a multitude of effects on their behaviour and physiology, resulting in smaller size individuals and reduced reproduction. source

• Subsea electricity infrastructure may potentially interact with sensitive marine receptor species, potentially resulting in impacts including:

  • disruption to species navigation/migration

  • avoidance/attraction to the cable infrastructure, the latter possibly causing entanglement (source)

  • negative physiological or developmental impacts

• There are knowledge gaps around how different characteristics of underwater noise (i.e., its intensity, length, pitch and tone) impact different forms of marine life.

• Offshore turbines should not be built until we have more information about the impact of various noise types on local marine life, accurate seafloor and habitat maps for the proposed area and more reliable information on population connectivity.

• Effects on hydrodynamics and sediment transport processes: The Physical presence of OWF infrastructure can change natural patterns of ocean water movement (e.g., currents, waves and mixing dynamics,) and the transport of nutrients and sediments in marine systems. This can alter the spatial distribution of biological productivity in the water column, and reduce the growth of food for fish, and marine mammals, such as seaweed and plankton, which may have follow-on implications for marine fauna that feed on plankton and the distribution and settlement of planktonic larvae of commercially and ecologically important species. E.g., The wind wake effect of offshore wind farms has been shown to change hydrodynamical conditions which can negatively impact primary production by up to 10% and cause a decline in bottom water deoxygenation thereby increasing the level of carbon in the ocean sediment, both of which can have a significant impact on the structuring of coastal marine ecosystems. Source1,  Source 2

• Invasive marine species: Use of international vessels and equipment which make direct contact with the seabed (e.g., pile driving equipment, dredges) are particularly high-risk vectors for the introduction of invasive species. In addition, the introduction of new clean hard substrates, such as turbine foundations and scour protection to the marine environment, may influence the potential for establishment of invasive marine species in the REZ. source

• A submission made by BlueFloat to DCCEEW on 3/11/23 in relation to their proposed project for the Illawarra listed the following environmental impacts associated with the first phase of their development:-

  • Vegetation clearance for the construction and operation of the onshore transmission line, substations and ancillary services (e.g. access tracks). Depending on which of the 3 transmission routes are chosen, this could involve clearing or disturbing subtropical rainforest in Killalea Regional Park, estuarine and swamp forests along Minnamurra River and its tributaries to remnants of heathland and rainforests to the west of the Princes Highway around the quarries through to the tributaries of Lake Illawarra (Route 3) or if Route 2 is chosen, endangering six threatened ecological communities and digging large trenches under Lake Illawarra through to the Tallawarra Power Station. 

  • Groundworks/excavation for underground cabling (trenching or boring)

  • Dredging and/or trenching of seabed for subsea cable laying to connect to offshore substations (*There will be 2 x 10km+ long trenches running from each offshore substation to the onshore landing point i.e. 6 x 10km+ wide trenches in total

  • Increase in marine vessels during construction and decommissioning such as tug boats 

  • Operation of Wind Turbine Generators (WTGs) and substations offshore

  • Impacts listed in other EPBC referrals for Gippsland, the Hunter and Tomago include:-

  • Vessel strike of marine fauna during vessel transit

  • Poor water quality from a vessel oil or waste spill

  • Disturbance of the seabed through taking shallow sediment samples or anchoring equipment deployed to the seafloor

  • Entanglement of marine fauna in equipment cabling or anchorage

  • Long term equipment deployment which may foul or cause contamination of the marine environment (particularly if coated with antifoul)

• Offshore turbines should not be built until we have more information about their impact on marine life and ecosystems.

 

2.  Birdlife

• The welfare of seabirds, shorebirds and land birds is at risk due to the potential for collisions with the turbines, as well as from displacement/avoidance as they adjust their travel routes. The latter can significantly impact their endurance, especially migratory species and impact the survival of nestlings by lowering provisioning rates. source. ​

• Significant migratory sea bird fatalities have been reported at marine wind farms close to breeding colonies. source

• In the Illawarra, the presence of offshore wind turbines may alter the upwelling effects at the edge of the continental shelf, reducing the nutrient-rich water brought from the deep, cold water to the ocean surface for foraging seabirds to feed on. source

• Light during the pre-development surveys, construction, operations and decommissioning phases can disrupt critical biological behaviours, cause physiological changes and potentially pose a barrier to the recovery of listed threatened species. Impacts of artificial light are particularly relevant for birds and marine turtles. Light pollution has a negative impact on many seabirds including several globally threatened species such as the albatross, petrel and shearwater (source). Some birds, such as burrow nesting seabirds and many nocturnally migratory species, are attracted to lights and this can be catastrophic and involve mass kills which threatens the viability of their populations. (source)

• The Five Islands Nature Reserve located approximately 3.6km offshore from Port Kembla provides habitat and breeding sites for the threatened sooty oystercatcher, breeding sites for the wedge-tailed shearwater and short-tailed shearwater and habitat for white-bellied sea-eagle. source The installation of turbines near this site and in the flight paths of these birds, poses an unacceptable and significant risk to the lives of these bird species and risks the threatened sooty oystercatcher.

• Turbine developers claim that they have Artificial Intelligence tools that monitor sea birds that are most at risk but these are still in the development phase and, unlike on land where birds killed or injured by turbines fall to the ground and so can be seen, those injured or killed by offshore turbines will be a hidden statistic!  

• Before approving offshore turbines, Australia needs to develop a national standard for baseline bird and bat utilisation studies for wind farm development that ensure that the studies done by developers follow the following best practice guidelines recommended by the Clean Energy Council (2018):- 

•    Identify significant bird and bat habitats and habitat components

•    Undertake bird utilisation surveys and modelling to identify species at risk of collision and/or  displacement, particularly listed threatened species and

•    Undertake bat surveys to identify any listed threatened species in the area source

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4.  Onshore rainfall and ambient climate

• Studies have shown, the wind that passes through the wind turbine sites, decreases in strength for distance of 60-100kms, and that this reduction of wind speed, may affect local weather, including the rainfall in those areas. eg source

• Wind turbines can affect local circulation and regional weather; if sufficiently large, they may even alter the structure of weather systems like low-level jets. source

• How could the potential change in onshore weather patterns impact all onshore flaura and fauna, including humans and our quality of life? Will developers need to submit an environmental impact study of this as part of the development application process?

• Research suggests that the impact of large clustered offshore windfarms on the sea surface climate and introduced spatial pattern in atmospheric conditions on ocean dynamics and the structure of the marine environment should be considered in climate change impact studies.

• Will the possible negative environmental impact of offshore turbines on onshore atmospheric conditions and on marine life through changing the sea surface climate need to be addressed during the developers' application process?

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5. Landfill

• Wind turbine blades are not easily recycled and are ending up as landfill. While improvements in technology mean that more parts of the turbines are now recyclable, this does not mean they are being recycled because there is no financial benefit for developers to do this. Australia has no facilities to recycle them. source 

• According to an ABC report on 21 June 2022, “there could be more than 40 million tonnes of blade waste in landfill by 2050.” This plant could contribute the equivalent of 33,705 metres of blade in landfill if not recycled! Ask the government to, if this project is to go ahead, guarantee the developer will recycle all parts of the turbines that can be recycled as part of the contract.

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6. Mining of non-renewable rare earth minerals for turbine magnets 

• For every 1 MW capacity of the wind turbine 216 kg of Neodymium, a rare earth mineral is required. So for a turbine plant with a proposed 2000MW capacity grid as is proposed by Illawarra Offshore Wind, this would require the mining of 432,000kg or 432 tonnes of neodymium alone. Not only is this a disaster for the environment but rare earth materials are not replaceable.

• Furthermore the demand for them are expected to increase globally in the coming 30 years but supply will not keep up and we are far away from manufacturing a competitive rare earth free magnet. This raises serious doubt about whether wind turbines really are a viable long-term source of renewable energy. Furthermore, given that neodymium magnets are more susceptible to corrosion than SmCo magnets and can lose their magnetic properties if they overheat which means that they are unable to generate electricity, what will happen if their magnets need replacing during their reported 30 year life span and there are no rare earth materials available or supply is disrupted by geopolitical tensions with China? What will happen to these turbines? How will this impact the volume and reliability of the electricity that can be generated?

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7. Rehabilitating damaged seabeds: How will the developers be held to account for decommissioning the turbines and rehabilitating the seabed and local environment once the turbines had reached their end-of-life? We don't do this effectively now with on-shore mines or even petrol stations. Why will it be any different with these developers of offshore power plants?

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8. Water pollution: How can we be sure that the floating wind turbines won’t become dislodged during heavy seas or be left to gradually rust into the ocean as they near the end of their life-cycle? We've suffered the blight on the environment of the Oceanlinx Wave Generator at Port Kembla which broke from its moorings and was left as a huge rusting eye-sore off Port Kembla for years. Let's not make the same mistake again!

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9. Lack of clarity regarding how environmental risks will be assessed

• The government has said that the developer will need to conduct studies to determine the impact of offshore power plants on the environment but how can we rely on a party with a vested interest to do this thoroughly and impartially? The DCCEEW’s own Guidance document ‘Key Environmental factors for offshore windfarm environmental impact assessment under the Environmental Protection and Biodiversity Conservation Act 1999’ refers to “acceptable impacts” however there is a lack of clarity around:-

• What is an “acceptable impact”? i.e. How severe and how much damage will be permitted?

• What are the criteria for determining this? Who will decide this? DCCEEW or the proponent or the proponent’s consultants?

• Will these studies be reviewed by DCCEEW? If so, in how much depth?

• What will be the basis of the review of the proponents’ studies of the 13 factors given that as at October 2023, DCCEEW is still working to define appropriate survey protocols and data standards for offshore renewable projects?

 

• Will the relevant Minister(s) confirm that he/she/they will take into account the precautionary principle when making a decision as is required by DCCEEW’s ‘Significant Impact Guidelines 1.1 Matters of National Environmental Significance in that “where there are threats of serious or irreversible damage to relevant protected matters and there is also a lack of full scientific certainty as to the nature or scope of the threat to this damage - as is being widely claimed in relation to the potential impact on whales – that the decision maker must apply the precautionary principle (and consider the need to take precautionary measures) in making their decision.”

 

COMMUNITY & ON-SHORE

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1. Jobs & Income from Tourism 

•  Wollongong LGA: In 2022, 6,651 jobs were employed directly and indirectly by tourism (i.e. 3,579 directly & 3,072 indirectly) and income into the economy from Direct Sales and the Value Added by Tourism was $1.72 billion! Wollongong has worked hard over the past 10-15 years to transform its image from an industrial city to a major tourism destination and industrializing our ocean with 300+ turbines more than twice the size of the Sydney Harbour Bridge could undo this hard work and harm our tourism economy.

• Shellharbour LGA: In 2021, the total visitor spend in tourism and retail was $123 million, which supported 6,264 jobs. Furthermore, according to the Shellharbour Regional Economic Development Strategy - 2023 Update, Tourism was listed as its number 1 'endowment' underpinning its economy and regional competitiveness.

• Kiama LGA: In 2021, 1,105 jobs in Kiama were in the Accommodation and Food & Beverage Service sectors, accounting for 18% of all employment in the region and adding $56.089 million to the economy.  

• 'Going to the beach' is the 2nd highest activity tourists who visit the South Coast region engage in, with 52% citing this as the reason for their visit, just behind 'Eating out/dining at a restaurant or cafe' with 59% engaging in this activity during their visit. 

• Research shows that most people do not want to holiday at beaches that have a view of offshore wind turbines – and that those who will, expect steep rental discounts. i.e. 54% said they would not rent a holiday home if turbines were in view at all, no matter how large a discount was offered on the rental price. The remainder would only be willing to choose beach holiday homes with turbines at 12.9km if there was a significant discount. source

• Exclusion zones of 400m² - 500m² around each of the 300+ wind turbines spread across 1,461km² of pristine ocean will significantly restrict the access of recreational fishers, divers, and tourists to an area of pristine ocean which equates to the size of 1 Wollongong LGA + 2 Shellharbour LGAs + 2 Kiama LGAs, and force them either further out to sea or to other locations.

• Research shows that people will switch the beaches they visit if turbines are 10km offshore.

• Based on this research, we are deeply concerned that tourism visitations will drop across all three LGAs, negatively impacting jobs and income in the hospitality, tourism and accommodation sectors.

• BlueFLoat's own report 'Preliminary Terrestrial Environmental Assessment, June 2023' (pp.71-72) noted that offshore turbine plants will negatively impact on Key Viewpoints which attract tourists and are loved by locals, including the Royal National Park, Seacliff Bridge, Sublime Point Lookout, North Wollongong Beach, Shellharbour North Beach, Port Kembla Hill 60 Lookout, Bass Point Nature Reserve and Kiama Blowhole (Viewing Platform). It even noted that from North Cronulla Beach, turbines could be visible when looking southeast even with the closest turbine being 24km away. (See Table 2.14)

• How does BlueFloat's projection of 200-300 ongoing jobs in the renewables sector possibly compensate for the potential risk to 14,020 jobs that are currently provided directly and indirectly by tourism, accommodation and hospitality across the Wollongong, Shellharbour and Kiama LGAs that will be impacted by this REZ?

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2. Property values

• “Wind farm visibility reduces local house prices, and the implied visual environmental costs are substantial” (Journal of Environmental Economics and Management, 2015).

• While many reports and studies claim that there is no evidence that the proximity of wind turbines reduce property prices, these reports are predominantly about onshore turbines where the value of the land is not as heavily determined by lifestyle or visual amenity, tend to involve properties that are receiving an income from the turbines and/or where the developers have purchased the surrounding properties to keep prices stable, or the reports have been prepared by valuers on behalf of the developers. Those that do relate to offshore turbines involve plants that have far fewer turbines than the 300+ proposed for the Illawarra REZ, involve turbines that are ⅓ - ½ the height of those 280m+ high turbines proposed for the Illawarra, and are offshore to much smaller populations who are predominantly located inland and are not ocean-facing.

• The reality is that there is no offshore turbine plant of this size or scale this close to such a large population (i.e. 316,227 as at 2022) anywhere in the world so it is difficult to know exactly what the impact will be on property prices but based on a review of numerous reports and the studies within these, including a NSW Valuer General report, 2009, 'The Social and Economic Impact of Rural Wind Farms' Senate Standing Committee on Community Affairs 23/6/2011 prepared for the Australian Government, and other research e.g. (Hives, 2008), (Heintzelman & Tuttle, 2012), if one were to exclude the data that is biased by vested interests (e.g. prepared by valuers for windfarm developers), we know that:-

  • properties whose value is predominantly based on the aesthetic qualities of the surrounding environment and lifestyle, like many of those in the Illawarra, are most sensitive to a decline in their value,

  • the values of less densely populated areas are affected more than urban areas

  • from a sample of 420 residents surveyed in Western Australia, nearly 25% of people would pay less for a property if turbines were within view, with 38% indicating they would pay 1-9% less, while 22% indicated they would pay 10%-19% less. 

  • the decline in property value appears to conservatively be between 2% - 6% depending on how close the turbines are

  • this decline in value commences as soon as turbine developments are proposed

  • a Canadian Realtor association found that properties adjacent to turbines sold for 20% - 40% less than comparable properties that were out of sight from the turbines. They attributed this drop to a reduced pool of interested buyers

• An Investment Analyst in property, logistics and energy investments who is also an Associate of the Australian Property Institute reviewed the international research on the impact of wind turbines on property values and concluded the following:-

  • "large high number and density offshore wind farms should not be placed close to high density high value residential areas."

  • in the Northern Suburbs of Wollongong with the escarpment coming in close to the shore at high elevation, this means that they will be more affected by the visual disturbance and the 280m+ high turbines will cause the residences to appear 'walled in' between the escarpment and the turbines 

  • the estimated loss in property value are most likely to be in the range of 10% - 22%, "similar to the losses one would expect when other industrial infrastructure, such as high voltage power lines, are built within view." Drawing on ABS and CoreLogic data, and using a more conservative estimate of 9%-14% loss, this represents $8.7 - $13.5 billion in taxpayer and ratepayer equity essentially handed over to developers

• In some US counties in the US, turbine developers have to provide a property guarantee to property owners (Note: point 4.27).

• In terms of compensating property owners, the CSIRO has recommended that instead of wind turbine developers directing compensation funds into a ‘community fund’ that is held in the local council’s consolidated revenue and used for community infrastructure projects, that a profit-sharing arrangement based on a sliding scale that is proportionate to the loss incurred be directed to those community members most negatively impacted. (Note point 4.25)

• Question: Given the building of offshore turbines, and even the proposed building of offshore turbines, could trigger a loss of tax payer and rate-payer equity in the value of their home and that only the developer profits from this build, do you commit to ensuring developers are required to put aside sufficient funds for the explicit purpose of compensating residents for any loss in their property value based on the turbines? Alternatively, if, the Australian government is confident that the building of offshore turbines will have no impact on property prices for those in the Illawarra, does it commit to providing home-owners with a property bond or guarantee, that protects the value of their home for the pre-announcement amount and to providing a compensation fund that they can access should the value of their properties not increase at the same rate of a comparable house in a comparable location that is not within the visibility of a wind turbine?

 

3. Surfing resources, tourism and recreation and the impact of changes Hydrodynamic changes

• Since the start of the COVID-19 pandemic, surfing has boomed as people increasingly turn to outdoor activities. source Offshore turbines have the potential to interrupt waves’ shoreward transmission and change their characteristics to such an extent that these changes are manifest at the surf zone when the waves break there. This is because  the structures cause wave energy to be blocked, re-directed, and extracted as it passes through a development site. source

• Not only could this negatively impact the ability of locals to engage in recreational surfing, but it could mean regular surfing competitions and the income derived from these and other surfing-related tourism, both directly and indirectly could be lost. For example, it is estimated that 15% of visitors to the South Coast engage in surfing. If the total tourist spend across the Wollongong, Shellharbour and Kiama areas in 2022 was $1.9 billion, and 15% of these visitors came to surf, even if only 1% of these visitors migrated to other areas where waves were not impacted by turbines, this could potentially represent a significant economic loss to the local economy.

• The Illawarra hosts multiple surf competitions every year. It is important that a swell impact study is carried out before any turbines are built to ensure that they do not jeopardise the competition’s viability and that should this  study indicate there is a risk to local surf, the Minister consider declaring a National Surfing Reserve to protect this area.

 

4. Australian Marine Parks and their values

• Depending on the location, the construction and presence of OWF infrastructure can affect the values of Australian Marine Parks (AMPs). Sources of impact may include underwater noise, light and EMF entering AMPs, disturbance to seabed features including benthic habitats and UCH, physical presence causing barriers and hydrodynamic effects, interference with social and commercial use and access, visual amenity, increased risk of the introduction of IMS, and additive effects to cumulative impacts from all pressures.

• Even though there are no Australian Marine Parks in the Illawarra, there are concerns about the impact of offshore turbines, especially on bird life and marine life, in the following:-

• Five Islands Nature Reserve (NSW NPWS),

• Killalea Park including Killalea National Surfing Reserve,

• Bass Point including Bushrangers Bay Aquatic Reserve,

• Seven Mile Beach National Park,

• Lake Illawarra

 

5. Impact on a Category 1a “Strict Nature Reserve” The Five Islands Nature Reserve

• Comprising Flinders Islet, Bass Islet, Martin Islet, Big Island and Rocky Islet, The Five Islands Nature Reserve makes up an area of approximately 26 hectares.

• Under the International Union for the Conservation of Nature and Natural Resources (IUCN, 1994), it is defined as a Category 1a “Strict Nature Reserve” that is;

 

    An area of land and/or sea possessing some outstanding or representative ecosystems, geological or          physiological features, and/or species, available
    primarily for scientific research and/or environment monitoring. Nature reserves are reserved under the      NPW Act to identify, protect and conserve areas containing outstanding, unique or representative              ecosystems, species, communities or natural phenomena.

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• Under the Act, nature reserves are to be managed in accordance with the following principles:

• the conservation of biodiversity, the maintenance of ecosystem function, the protection of geological and geomorphological features and natural phenomena,

• the conservation of places, objects, features and landscapes of cultural value,

• the promotion of public appreciation, enjoyment and understanding of the nature reserve’s natural and cultural values,

• provision for appropriate research and monitoring.

• The installation of numerous 260m+ high turbines and possibly an offshore powerplant in this area could contravene these management principles, specifically the ability of the public to appreciate and enjoy the reserve’s natural features and potentially restrict access to authorities who need to monitor and protect this site

6.   Impact on Matters of National Environmental Significance (MNES) 

• Vegetation clearance for the construction and operation of the onshore transmission line, substations and ancillary services (e.g. access tracks). Depending on which of the 3 transmission routes are chosen, this could involve clearing or disturbing subtropical rainforest in Killalea Regional Park, estuarine and swamp forests along Minnamurra River and its tributaries to remnants of heathland and rainforests to the west of the Princes Highway around the quarries through to the tributaries of Lake Illawarra (Route 3) or if Route 2 is chosen, endangering six threatened ecological communities and digging large trenches under Lake Illawarra through to the Tallawarra Power Station. 

FISHING - COMMERCIAL & RECREATIONAL​

• The 400m² - 500m² exclusion zones around each turbine will restrict access to 1,461km² of pristine ocean waters home to recreational and commercial fishers and there is no information being made available about how close fishers can fish around the turbines

• The potential impacts of OWFs on fish communities can be as follows: source

• Disruption of orientation, especially for migratory species;

• Impediment of foraging activities;

• Habitat loss-not just from the actual wind turbines, fish may move out of areas due to increased stress levels;

• Damage to fish eggs;

• Alteration of fish species availability and abundance;

• Alteration of fish community composition and abundance

• Disturbance and redistribution of sediments;

• Scouring of sediments around the base of turbines;

• Re-suspension of pollutants within the sediment;

• Accidental release of chemicals and hydrocarbons during installation;

• Pile hammering associated with the construction of the foundation for offshore wind turbines may result in damage to fish and fish larvae or changes in fish behaviour due to high levels of underwater noise associated with this;

• Underwater noise produced during the operational phase of offshore wind farms may change fish behaviour;

• The presence of offshore wind farms may cause changes in seabed characteristics which can influence the distribution of demersal fish species;

• Absence of fisheries within the offshore wind farm, because fishing is not allowed, may change the characteristics of both the fish community because detrimental impacts from fisheries will be absent;

• The presence of the offshore wind farm and wind turbines may lead to the introduction of invasive species   

• The effects of targeting seismic testing and construction have the potential to cripple the recreational sector and commercial industry and cause overfishing from displacement of the site during construction.

• High voltage cables linking the turbines and to shore would be a fouling hazard and dangerous for fishing with lobster pots. 

• Land based turbines leak gear oils onto the ground and this would be an environmental disaster out at sea. 

• Underwater cables emit electromagnetic fields that can change the way crustaceans behave which impact their feeding, physiology and reproduction habits source

• If there is an incident involving a turbine, other government department regulators (e.g., AMSA) can step in and add their own rules and restrictions around turbines.

• In fog the turbines become a navigational hazard as radar equipment can be affected by turbines causing multiple false echoes. 

 

VISUAL AMENITY 

• Visual pollution refers to the visible deterioration and negative aesthetic quality of the natural and human-made landscapes around people and to the study of secondary impacts of manmade interventions. ​

• Building 300 x 260m+ high turbines with ~6 offshore substations is industrialising an untouched pristine ocean and horizon. 

• The ~300+ offshore turbines + ~6 offshore substations will be easily visible from onshore. According to research: -

  • Facilities of 100 turbines can be easily seen at distances exceeding 35km or even farther. Those in the Northern Illawarra will be just 10km offshore, Shellharbour 16km offshore & Kiama 30km!

  • At night, aerial hazard navigation lighting was visible at distances greater than 39km. Those proposed for the Northern Illawarra will be 10km offshore!

  • At distances of 14km or less, even isolated small facilities will likely be a major focus of visual attention in seaward views 

  • Land based turbines have terrain to hide amongst, trees and hills offer some camouflage, where offshore wind turbines have no cover to hide behind. 

• The government and wind companies will say the visual effect is very low, so there should not be an issue putting them closer to the where the power is needed and research shows that the visual simulations developed by wind turbine companies “lack accuracy or representativeness” and “mislead the public” and “…commonly under-represent turbine number and size … (and are) too narrow to adequately represent human vision and under-estimated how many wind turbines were visible from a single landscape position.”

• The proposal for wind turbines off the Illawarra coast was announced on the 16 August 2023 by Minister Bowen, but has been in the pipeline for some time, yet why did it take until the 24th October, 8 days after the first deadline for submissions, for DCCEEW to release these? And when they were released, why don't they appear to meet some of the basic criteria for accurate and reliable visual simulations of renewable energy projects? Overseas countries have standards that developers need to meet when creating these visual simulations for renewable energy projects, so when will Australia have similar standards so that the general public can be adequately informed information when forming their opinions about this and future renewable energy projects? 

 

OTHER

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1. Disturbance of underwater cultural heritage

• Construction and operation of an OWF can result in the disturbance of cultural heritage including underwater cultural heritage (UCH). Identifying cultural heritage values that may be impacted should consider First Nations peoples’ beliefs, practices and connection to Sea Country, places of cultural significance and cultural heritage sites in the proposed REZ.

• A lack of understanding of the cultural heritage values that may be at risk due to the proposed OWF is a potential critical issue, as this may prevent the proponent from identifying and evaluating relevant impacts.

• Developing an OWF within a protected zone declared under the UCH Act is a potential critical issue, particularly if there is uncertainty about whether a permit may be granted to enter the zone, or it would be possible to comply with any conditions of entry attached to a permit. This has the potential to limit officials from entering the zone to monitor and protect its UCH.

 

     First Nations Underwater Cultural Heritage

• The development of offshore turbines has the potential to expose or disturb Aboriginal sites and artefacts, both on-shore and underwater.

• Submerged Indigenous Heritage was mentioned by BlueFloat Energy as an item to be covered in their studies during the Thirroul Surf Club Drop-In session in June 2023.

• The Five Islands Nature Reserve, comprising Flinders Islet, Bass Islet, Martin Islet, Big Island and Rocky Islet, which together make up an area of approximately 26 hectares, is important to the Illawarra Aboriginal community due to stories of country, continuing cultural associations and past occupation of the area. This area was occupied by the Wodi Wodi people who spoke a variant of Dharawal language and there are many fresh water and salt water Dharawal creation stories that relate to the Five Islands.

• There has been an ongoing utilisation of the islands from pre-European times to the twentieth century for the harvesting of plant and animal resources. Middens and stone artefacts provide evidence of occupation and use of Big Island, although sites on Big Island are now largely covered by vegetation (Mills 1990; NPWS Aboriginal Sites Register). Illawarra elders describe the harvesting of sea birds and eggs from Booidoorong (Big Island) up until the mid-twentieth century from the settlements at
  Hill 60 and Official camps. source

• The Five Islands Nature Reserve is also of regional significance for its cultural heritage values, particularly the local settlement history of the Illawarra. source

• In 2018, large areas of reef, ancient volcanic vents, relict rivers formed thousands of years ago and strange round patterns that looked like ‘crop circles’ were discovered in the sea floor off the Illawarra coast by marine scientists from the NSW Office of Environment and Heritage (OEH) and the University of Wollongong

• The development of offshore turbines, specifically their disturbance of the sea-bed and the changes in hydrodynamic conditions created by the turbines, has the potential to irrevocably destroy these ancient relics and areas of reef.

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    Shipwrecks and submerged aircraft

• Activities involving seabed intervention in particular (e.g., subsea cable burial, foundation installation) may adversely impact remains of shipwrecks and submerged aircraft and their associated articles which have been in Commonwealth waters for 75 years or more, and other sites/protected zones declared under the UCH Act which contain articles of heritage significance.

• According to the DCCEEW’s own Australasian Underwater Cultural Heritage Database there are 14 shipwrecks within the proposed REZ, the oldest dating back to 1825,  ‘Charlotte’ which was wrecked off Five Islands however according to records held by the Black Diamond Heritage Centre in Bulli, it is estimated that there are between 105-120 ships that were wrecked or grounded along the Illawarra coastline from 1829 onwards, and many of these now provide wreck scuba dive sites that are visited by locals and tourists e.g. SS Bombo off Port Kembla, SS Cities Services Boston off Bass Point, Queen of Nations off Towradgi, Alexander Berry of Shellharbour, Our Own off Shellharbour, an unknown ship off Port Kembla

 

2. The proposed development contravenes the Clean Energy Council’s Best Practice Guidelines for Implementation of Wind Energy Projects in Australia June 2018 which state that it should be:-

 

a. Safe: The wind farm will not negatively affect the health and safety of the community … during its development, construction, operation and decommissioning.

During construction, the community will potentially be subject to noise from the blasting of high-powered airguns; blasts that will occur every 10 seconds and reach more than 250 decibels as well as noise from pile driving that can be detected from 100km away source. During their operation, the community will be subject to visual pollution, both during the day in the form of a wall of 280m+ high turbines which will be a major focus of visual attention in seaward views (source) as will a potentially tall bright yellow offshore substation, and at night, the white marine navigation lights, the bright lights of the offshore substation and the red aviation lights will appear to flash as the rotor blades turn in front of them.

 

b. Socially sustainable: The wind farm proponent will actively seek stakeholder participation and support through well-planned, open, inclusive and responsive engagement processes.

One of the proponents, BlueFloat either has not appeared or not made themselves known at any of the community information sessions held from 18 September onwards. They have also refused to release the preliminary visual simulations of the proposed plant for the Illawarra they have prepared explaining that they would only do so once the REZ was declared and after a feasibility licence was issued. (source: Email from BlueFloat dated 23/8/23)

 

c. Economically sustainable: The windfarm will make a positive economic contribution to the community in which it is located.

There are serious doubts about the economic contribution of this offshore wind power plant to the community, given the following:-

• According to government officials at two community information sessions, 66% of the electricity generated will be going to the Steelworks and the rest into the national grid, so none for local residents and no plans for reduced electricity prices to residents

• BlueFloat confirmed that there could be 200-300 ongoing jobs in the renewable sector after construction but how does this compare with the potential loss of jobs in the tourism and hospitality sector which currently provides 14,020 jobs in the communities impacted by this development

• Offshore turbines overseas are proving unprofitable (source, source, source, source) and are facing serious supply chain issues source

 

d. Environmentally sustainable: (i). Any significant negative impacts will be avoided or minimised and appropriately managed or offset as required.

• The DCCEEW’s own Guidance document ‘Key Environmental factors for offshore windfarm environmental impact assessment under the Environmental Protection and Biodiversity Conservation Act 1999’ lists 13 environmental impacts of offshore wind turbines and refers to “acceptable impacts” however there is a lack of clarity around:-

• What is an “acceptable impact”? i.e. How severe and how much damage will be permitted?

• What are the criteria for determining this? Who will decide this? DCCEEW or the proponent or the proponent’s consultants?

• Will these studies be reviewed by DCCEEW? If so, in how much depth?

• What will be the basis of the review of the proponents’ studies of the 13 factors given that as at October 2023, DCCEEW is still working to define appropriate survey protocols and data standards for offshore renewable projects?

• Will the relevant Minister(s) confirm that he/she/they will take into account the precautionary principle when making a decision as is required by DCCEEW’s ‘Significant Impact Guidelines 1.1 Matters of National Environmental Significance in that “where there are threats of serious or irreversible damage to relevant protected matters and there is also a lack of full scientific certainty as to the nature or scope of the threat to this damage - as is being widely claimed in relation to the potential impact on whales – that the decision maker must apply the precautionary principle (and consider the need to take precautionary measures) in making their decision.”

• The blades are currently not able to be recycled in Australia, and the recycling processes located overseas are still under development.

• The components of the wind turbine technology use six rare earth metals which are not renewable, cause extensive pollution and illness in the countries where they are mined (source) and the demand for these is expected to grow globally over the next 30 years, creating even further damage to the environment (source)

• Furthermore, it is expected that the production of these rare earth metals will not keep up with this demand (source) which raises the question as to whether wind turbines are a viable long-term source of renewable energy, especially given a wind turbine is an enormous structure that contains more than 8000 different components, many of which are made from steel, cast iron and concrete which all require the mining of raw materials, and not all of these components can be recycled.

d. Environmentally sustainable: (ii).The windfarm will make a positive contribution to the environment by producing clean energy and therefore reducing the production of greenhouse gases from fossil fuel fired power stations

When a DCCEEW official was asked at the Bulli Information session on 18 September ‘How much less coal will be burnt as a result of this windfarm?” the answer was ‘I don’t have those figures.” Does anyone know and can these figures be provided to the Illawarra community as soon as possible please?

 

e. Reliable: The windfarm will supply clean electricity into the grid in accordance with the relevant industry standards.

• Failure rates of components of floating wind turbines are higher than those of onshore devices. source

• Unexpected and increasing wind turbine failure rates, largely in newer and bigger models, are savaging the profits of some of the world’s biggest manufacturers, and making them unviable. The most common failures include bearings, blades, gearboxes, and generators.(source)  Faulty components created a €472 million ($A28 million) hole in Siemens Gamesa’s December quarter result, making up more than half of the nearly billion-euro loss for the period. GE blamed its $US2.2 billion annual loss on rising warranty provisions from its wind division in the September quarter, which contributed to a 17 per cent drop in revenue (source)

 

The offshore wind turbine power plant proposed for the Illawarra does not meet any of the Clean Energy Council’s Best practice guidelines.

 

FINAL QUESTION

The last section of the survey allows you to include documents, files and photos and is limited to 10mb. Use this section to describe how you value and use the outdoor areas in and around the coastline and upload photos or pictures that show this. You can also upload a more detailed submission. Remember, the government needs to understand what the building of offshore turbines will take away from you so even if you just upload your favourite Illawarra photo, something added is better than leaving it blank.