We have submitted our group submission to the NSW Planning Department for consideration.
Below is an extract from the executive summary.
EXECUTIVE SUMMARY
This Submission tables on behalf of the Community the Voice for Walcha’s (VfW) Group Objection to the Winterbourne Wind Farm Project (WWF). The full reasons for the Community Objection are set out in the eleven (11) sub-submissions attached hereunder.
The objective of this Executive Summary is to provide important context supporting the Objection rationale to;
- Provide a short overview as to the grounds for objection set out in the Sub-Submissions; and
- Convey on behalf of the Community their expectations as to what presents as just and equitable outcomes in the ongoing assessment process.
Context of course is everything - in the Project at hand it attempts to draw together analysis – often complex and introducing serious issues facing a community. Issues which will test the fabric, the understanding and ultimately the resilience of the Community. It shouldn’t be underestimated that the prevailing psychology in the Walcha Community is that this Project and those that follow – could present as the turning points, between either Walcha continuing to grow as a progressive agricultural economy contributing to Australia’s national and export objectives or an industrial waste land – a ‘host-baby sitter’ for concrete and carbon fibre’ purely for profit objectives.
Threshold Objections
The Sub-Submissions hereunder promote detailed consideration in each of its 11 assessments outlining 2 shortcomings – firstly, failure to achieve compliance and/or secondly, excessive and unacceptable impacts. Some of which are critical. Each attempt is to substantiate why consent should be withheld for the Project. Much of the basis for this conclusion is derived from the following threshold technical conclusions reached by VfW;
- The considerable project Impacts and the mitigation offered don’t confirm as ecologically sustainable development in accordance with the Objectives of the NSW Environmental Planning and Assessment Act 1979.
- The Project impacts on the UNESCO Gondwana Rainforest and Wilderness Area and the rich biodiversity do not justify approval by the Federal Minister of the Environment pursuant to the Environment Protection Biodiversity Conservation Act 1999.
- The Proponents presentation of the EIS is unacceptably deficient in project detail -it presents with numerous errors and misleading information. It’s content and technical detail is clearly not in compliance with the EPA Act 1979 and Schedule 2 of the EPA Regulations. Nor does it reflect the standards espoused by the State Significant Development Guidelines July 2021 and the Preparing an Environmental Impact Statement Guidelines -July 2021.
VfW maintain four considerations arise in respect to this deficiency;
- Obvious questions as to procedural fairness arise for the Community and others who were severely impaired in their opportunity to assess the merits of the Project through this EIS.
- The Proponents obvious failure to give serious consideration to analysis ‘of any feasible alternatives ‘to carrying out the proposed WWF development activity…’ in accordance with the SEAR and Schedule 2 of the EPA Regulations.
- The failure in preparing the EIS to ensure the requisite high standards, including the potential proffering of misleading information, as specified by the Clause 3 of the EPA Regulation and the July 2021 Guidelines. This questions the integrity of REAP Certification as to ‘completeness, accuracy, quality and clarity ‘of the information, submitted with the EIS and signed off by the Developer’s REAP; and
- The failure in preparing the EIS to ensure the requisite high standards, including the potential proffering of misleading information, as specified by the Clause 3 of the EPA Regulation and the July 2021 Guidelines. This questions the integrity of REAP Certification as to ‘completeness, accuracy, quality and clarity ‘of the information, submitted with the EIS and signed off by the Developer’s REAP; and
