EMM has made a submission to NSW Department of Planning and Environment (DPE) on the Draft Revised Large-Scale Solar Energy Guidelines
We support the development of guidelines like these in order to give greater certainty to all involved in the process; developers, communities and government agencies. Given the rapid roll-out of renewable projects required to meet the NSW Government’s NET Zero Plan for 2050, greater certainty around the approval process will benefit all.
We recognise that land use conflict is an emerging issue in relation to renewable projects being proposed and developed in traditionally agricultural regions, impacting both the landscape and the economy. Government and industry stakeholders need to assist this transition. We recognise that the NSW Government has designated Renewable Energy Zones (REZs) and is prioritising investment to encourage renewable projects in these regions. While this is discussed in the Guidelines, the current planning approval process and assessment requirements do not differentiate between projects inside and outside REZs.
The Guidelines significantly increase the investigation requirements for soils, agricultural and visual impacts. We have reviewed the proposed standards of investigation and are concerned that they will impose significant costs on projects that are not proportionate to the degree of risk or impact. EMM supports appropriate investigations targeted at significant environmental and social risks but believe that “blanket” requirements for studies may impose financial penalties during project development and assessment even when they are considered low impact and low risk.
For example, the Guidelines propose new requirements for soil surveys but do not explain the purpose of this data collection, nor how it will be used by the decision makers. This needs to be clarified to give project developers a better understanding of the approvals process and establish clear “goalposts”. Solar farms can have relatively minor impacts on the soil profile during construction, and we are increasingly seeing agriculture and solar farms co-existing on the same property and sometimes on the same land.
Our recommendations to DPE include the following:
- The Guidelines should differentiate between projects located within REZs and those outside.
- The Guidelines should provide for risk-based assessments rather than blanket guidelines applying to all projects. There is already a mechanism in place for this, based around the Scoping Report and the Secretary’s Environmental Assessment Requirements (SEARs). The Guidelines should focus on requiring sound investigation for the Scoping Report, and then allowing the SEARs to set the requirements for studies required to support the environmental impact statement (EIS) based on site and project specific information.
- The increased requirement for soil surveys and agricultural impact assessments should be based on a clear Government policy position, and/or be risk-based, whilst recognising the range of potential impacts of solar farms on agricultural and soil productivity.
Feel free to contact us if you would like a full copy of our submission.