This letter is an abridged version of the concerns raised with OSMI regarding its Community and Stakeholder Consultative Committee (‘the committee’).
OSMI states: “The committee will be responsible for facilitating the accurate and timely flow of information about the project’s development to and from the community and assist in obtaining feedback and making decisions about aspects of the project which may impact on the windfarm’s neighbours and wider community.”
OSMI already uses many tools to share information including print media, social media, a website, community engagement officers, email, letters and Community Open Days. There were meetings with community groups and councils prior to the public announcement of the proposal.
The problem is not one of dissemination but the accuracy and currency of OSMI’s information. For example, as of 19 February 2020, OSMI’s website stated: “The number of direct jobs predicted to be created during the construction phase for 53 turbines was 209, along with 18 longer-term positions created during the operational phase. Many more indirect jobs (up to 520) will be created from the increased economic activity in the area. These figures will be updated as the project evolves.” An OSMI email dated 4 December, 2019 stated: “The current estimate of jobs created by the projects around 75 direct and 109 indirect during the construction phase, and around 12 direct for the lifetime of the project”.
Community groups must understand that any benefits they receive through this project are potentially a redistribution of wealth from those most impacted. Those with the most to lose have the smallest voice on a committee stacked with people in favour of the proposal and potential beneficiaries.
It has already been challenging for individuals to raise legitimate concerns without accusations of climate change denial or nimbyism. By November 2019, the SSF had just 12 members and not all lived locally. It has the same representation as the SCA with well over 1,000 members and over 400 households within 5km. The Gippsland Climate Change Network will also have a representative.
HVP has failed “to treat all neighbours honestly, fairly and with respect” despite this aim in its Stakeholder Engagement Plan. HVP worked with OSMI on the proposal for over two years without informing neighbours and has actively avoided accepting any responsibility for its impacts. Why does it deserve representation?
OSMI has already released its final plan and will be submitting this to the Minister for Planning. The committee will merely be a forum for the ‘discussion and exchange of information relating to planning’. While OSMI may ‘encourage stakeholder and community input’ and ‘acknowledge local concerns and issues raised by the community in relation to the project’, it has already ignored local concerns by denying requests to adhere to the National Wind Farm Commissioner’s recommendation that turbines over 200m tall should have a 2km setback from houses.
With a show of community engagement and benefit, OSMI increases the prospect of the wind farm being granted large-scale generation certificates under the VRET auction scheme. This is clear from DELWP’s guide for renewable energy developers. Electricity retailers must purchase certificates to show they are meeting the renewable energy target. The sale of certificates is extremely profitable for operators but costly for retailers. For example, the Hepburn Wind Farm earned $3,423,371 from the sale of electricity between 2013 and 2018 and $3,367,494 from the sale of certificates. The retailer simply passes on the certificate costs to consumers.
Delburn Wind Farm is without precedent in Australia in terms of turbine size, siting within fire prone forest and close proximity to townships. The same setback distance of 1km has guided the placement of turbines that are noisier and much larger than those at the Bald Hills Wind Farm despite its proven breach of the Victorian Public Health and Wellbeing Act.
Will committee members consider the risks associated with this project as well as the potential benefits? What contingencies will there be for those most impacted in the community should the Victorian Public Health and Wellbeing Act be breached? Will OSMI be informing committee members about the Environmental Protection Amendment Act 2018, specifically the:
Principal of Equity
Principal of Primacy of Prevention
How will community representatives be selected? Who is in charge of that process? Why aren’t there representatives from the emergency services such as the CFA given the impact on aerial fire fighting and communications? Will representatives be required to publicly declare vested interests?
The committee’s code of conduct will result in a lack of transparency. Representatives are effectively gagged from raising matters of public interest. All communication must go through the Chair who will be appointed by OSMI. No committee member can make unauthorised statements and all must support, adhere to and not publicly contradict the decisions of the committee.