Appendix A – Consultation in preparation of this NMP

Consultation on V02-01 A draft version of the NMP was released for community consultation in 2019 (V02-01 dated 31 October 2019). Comments were received from one submitter, with responses provided below. It is noted that further consultation is planned for this updated version of the NMP.

The comments and responses are provided below:

Comment Response

It appears that this is a very early stage draft plan merely provided to fulfil the Condition 25 requirement. Referring to maps that are not included, known dwellings absent, not peer reviewed etc etc. Near Field Testing – The concept of building something, and then testing to see if it is acceptable, is against the whole idea of Planning and reasoning of NZS6808. V02-01 was an early version released for consultation prior to the finalisation of turbine locations and details. That information is provided in the current version.

The Near Field Testing is required under Condition 20 of the Planning Permit. It is important to recognise that it is only one aspect of the noise compliance assessment process for the Golden Plains Wind Farm that also includes: • The Pre-Construction Noise Assessment: a predictive report that will be required to demonstrate that predicted noise levels from the wind farm and ancillary infrastructure comply with the applicable noise limits. The Pre-Construction Noise Assessment will be based on technical information supplied by the wind turbine manufacturer about the noise emissions from their wind turbines. As required by Condition 18, this must be submitted and approved before development starts. • The Post-Construction Noise Assessment: a report that assesses, based on measurements, whether or not the wind farm is complying with the applicable noise limits at noise-sensitive land uses once it has commenced operation.

The Near Field Testing is considered important for this project because: • The Pre-Construction Noise Assessment will include technical information supplied by the wind turbine manufacturer and the Near Field Testing will be able to verify that the installed turbines are operating in accordance with that technical information. In the unexpected event of higher noise levels from the installed turbines, the Near Field Testing results can be used to determine whether additional measurements are required at or near noise-sensitive locations to assess compliance with the applicable noise limits. • It can provide information on the noise levels from the site more quickly than the Post-Construction Noise Assessment. Near Field Testing can commence as soon as wind turbines are generating and the test procedure, while dependent on wind conditions at the site, generally takes no more than 48 hours, allowing analysis of the data after a relatively short timeframe. In contrast, the measurement procedure for the Post-Construction Noise Assessment requires multiple weeks of data prior to analysing the data and, subject to the timing requirements of the Planning Permit, would normally only commence once most or all of the turbines at the site are operational.

Comment

Serious concerns regarding lack of noise monitoring post construction.

Absence of a clear process/plan for what the consequences will be when the project is noncompliant Response

A total of 15 noise-sensitive locations, including 12 for Stage 1, have been identified for post-construction testing of wind farm noise within the NMP, selected based on their geographical spread around the wind farm and as they are predicted to have the highest wind farm noise levels in different areas around the site. The locations have been selected with review and input from the independent environmental auditor.

If the Near Field Testing determines that wind turbine noise levels are higher than was originally stated by the turbine supplier, then the NMP requires that additional testing be considered.

In addition to the above, noise levels from ancillary infrastructure will need to be assessed for compliance with the EPA Victoria Noise Protocol at the closest noisesensitive location. Section 9 of the Draft NMP details the requirements for any Noise Remediation Plan that must be submitted to the Responsible Authority in the event of a noncompliance being detected.

The Draft NMP requires that any Noise Remediation Plan be prepared by an independent, suitably experienced acoustic consultant and detail, amongst other things: • The date on which the wind farm operator became aware of the noncompliance. • Proposed mitigation measures to be implemented at the site to achieve compliance. • Evidence that those proposed mitigation measures to achieve compliance have been implemented at the site. • Requirements for additional noise testing to demonstrate compliance.

The Noise Remediation Plan must be submitted to the Responsible Authority no later than six weeks after the date on which the wind farm operator became aware of the non-compliance and must be accompanied by a peer review from an independent environmental auditor. Considering this and the need for evidence to be provided in the document, the mitigation measures to achieve compliance will need to have been implemented well before this six-week date.

It is important to note that, in the event of a non-compliance, the nature of the mitigation measures will depend on the nature of the non-compliance and it is therefore not possible to detail those measures in the NMP.

In some cases, the preferred mitigation measure may take time to develop and/or procure and would therefore take longer than six weeks. The Draft NMP addresses the potential for this by requiring interim mitigation measures to be implemented while this process occurs, to ensure that compliance is achieved in the interim. These interim measures would be anticipated to involve curtailment of individual or multiple turbines to achieve the necessary noise reduction, an option which is readily available as part of modern wind turbine control systems.