Department of Climate Change, Energy, the Environment and Water
[email protected]
27 April 2023
Offshore renewable energy infrastructure area proposal: Pacific Ocean off Hunter Submission
To whom it may concern
Thank you for the opportunity to provide input to the Offshore renewable energy infrastructure area proposal: Pacific Ocean off Hunter.
The Clean Energy Association of Newcastle and Surrounds (CLEANaS) strongly supports the development of offshore renewable energy in Australia, and the designation of the Offshore Renewable Energy Area in the Pacific Ocean off the Hunter.
CLEANaS is the Clean Energy Association of Newcastle and Surrounds, a not-for-profit association formed in 2012 by a group of locals passionate about clean energy. CLEANaS is dedicated to driving the uptake of clean energy so that our region can transition from its current dependency on fossil fuels to a more competitive and sustainable local economy. We achieve this by working with our partners to demonstrate profitable community-led and community-owned clean energy projects; raise the profile of clean energy in the local economy through education and awareness raising; and by improving access to financing mechanisms and affordable technologies so that investment and activity grow. Our initiatives must deliver a win-win for local community investors, local enterprise and, of course, our environment.
CLEANaS is currently planning to build a 1MW Community Owned Solar Farm here in the Hunter near Scone.
As you are aware, Australia is in the middle of a renewable energy boom. This means cleaner and cheaper power, local economic development and more resilience in regional communities. Already, the renewable energy build-out is creating jobs across regional Australia. However, we are concerned that the Hunter and Central Coast might miss out on both the short and long term benefits that the mass investment and construction of solar, wind energy, and storage will bring.
The declaration of an offshore renewable energy infrastructure area off the Hunter and Central Coast is an amazing opportunity for the region.
The AEMO reported[1] offshore wind has great potential due to its high resource quality, lower social licence hurdles than onshore renewable energy, and reducing costs. New offshore wind projects have capacity factors of 40%-50% due to wind availability, and larger turbines.[2]Capacity factors are higher than Gas, Solar, and Onshore Wind, and close to the rapidly declining capacity factors for Coal.[3]
The Blue Economy Offshore Wind Energy Report found that the ongoing expansion of offshore wind to large 15 MW turbines can enable individual projects to have a capacity of 1-2 GW, which means that offshore wind can upscale rapidly as coal plants close and the energy transition accelerates.[4]
AEMO noted that the Hunter Coast offshore wind zone has good resource potential with:
- relatively shallow waters close to shore,
- a capacity of 10GW,
- a proximity to major load centres such as Sydney.
- existing strong transmission corridors of existing 330 kV lines, and
- a current network transmission limit of around 5.5 GW.
Newcastle, Hunter and Central Coast has a skilled workforce, significant electricity grid connections (e.g. Munmorah, Eraring, Kooragang Island) and substantial deep-water port infrastructure at Newcastle suitable for construction and maintenance of off-shore wind farms.
Climate ChangeThe impacts of climate change on the environment are significant and severe. The present scientific consensus is that the earth's climate is warming due to human activity (https://climate.nasa.gov/scientific-consensus/ ), and the negative impacts of increased greenhouse gas emissions are measurable globally and nationally.[5]
Australia has warmed faster than the global average and is on average 1.44 ± 0.24°C warmer than when national records began in 1910 with most of the warming occurring since 1950 with every decade since being warmer than the one before.[6] If compared to a pre-industrial (1850-1900) baseline, then by 2019 Australia had warmed by greater than 1.5°C.[7]
The government is responsible for the environment, the health and wellbeing of its citizens, and the financial security of the nation. As we see the impact of increased carbon emissions, we also find evidence of the impact on Australian native wildlife, the Australian people and the wealth of the nation as noted by the catastrophic Black Summer bushfires, crippling drought and more recently floods.
The urgency of the Climate Crisis indicates that we need to take full advantage of renewable resources where available, and the opportunity to build offshore renewable energy off the Hunter Coast. Therefore the construction of renewable energy within this region needs to be given priority over other uses in this area.
Amendments to the proposed areaPart of the proposed area is the edge of the continental shelf where depths exceed 200m deep where building wind turbines and undersea cabling is more difficult and expensive to construct. South of Norah Head is excluded because the area is used for military exercises as is anywhere within 46 km of Williamtown RAAF base. Note that the PEP-11 offshore gas permit did not appear to have these restrictions. Mitigation measures to reduce the exclusion zone for radar and airplanes should also be examined more closely.
In the North of the zone, the zone is close to islands off Port Stephens where Australia’s rarest endemic seabird the Gould’s Petrel nests.
We are not concerned about the visual impact of wind turbines, in fact, they are far more desirable in our eyes than the numerous coal ships currently dotting our local horizon, which are a constant reminder of our current fossil fuel dependence. However moving turbines 15 km from elevated and populated areas such as Norah Head, the Central Coast and the entrance to Port Stephens may help secure social licence and increase community confidence in the development of offshore renewable energy.
The Minister should look at all opportunities to expand the Area into waters that are less than 200m deep, while keeping the Area 15 km from shore and neighbouring islands.
Recommendations:
- The Hunter Offshore Renewable Energy Area is a critical area for renewable energy development, because of the available grid and port infrastructure, the location close to large electricity loads, and the quality of the wind resource. Given the urgency of the climate crisis, development of renewable energy projects must be given precedence over other uses of the Hunter offshore area.
- The outer 11 km x 82 km edge of the proposed Area is between 200m and 1,000m deep, which will increase the technical challenge and cost of offshore wind projects, and the cost of electricity. The Minister should look at all opportunities to expand the Area into waters that are less than 200m deep, while keeping the Area 15 km from shore and neighbouring islands.
- The area south of Norah Head and more than 10 km offshore is 70m-200m deep and close to grid connection points, but has been excluded because Defence has said that they use it for military exercises. Defence should be encouraged to carry out exercises on other parts of the coast. The proposed Renewable Energy Area should be expanded approximately 30 km south towards the mouth of the Hawkesbury, while keeping the zone a minimum of 15 km from shore in consideration of the higher elevation areas at Norah Head and Toowoon Bay. We note that this area is already covered by the PEP11 petroleum exploration permit.
- The proposed 46km/25 nautical mile exclusion zone for the RAAF Williamtown base removes a significant portion of potential Area that is between 100-140m deep, and close to grid connection points. Mitigation measures for radar and planes used in other countries should be implemented to expand the proposed Area for renewable energy development to the west, to a minimum of 15km offshore.
- Petroleum Exploration Permit 11 (PEP11) covers a significant portion of the proposed Renewable Energy Area, and adjacent areas to the south and west. PEP11 should be cancelled, and the existing gas exploration well securely and permanently capped so it does not interfere with renewable energy development.
- The Renewable Energy Area should be a minimum of 5 km from marine habitat protection zones in the Port Stephens – Great Lakes Marine Park and Hunter Marine Park.
- The Renewable Energy Area should be a minimum of 15 km from Tomaree mountain at the entrance to Port Stephens Bay, as this is a higher elevation lookout area.
- The Renewable Energy Area should be a minimum of 15 km from the nesting grounds of the Gould’s Petrel (Cabbage Tree Island, Boondelbah Island, Broughton Island, Little Broughton Island, and Montague Island) which are approximately 5 km from Tomaree Headland.
- Recreational fishers should be allowed to fish within the boundaries of offshore wind farms (as is the case in the USA and UK).
- Federal government should work with state and local governments to establish streamlined and effective development and approval processes for offshore wind development. This should include undertaking strategic planning (continuing what this consultation has started) in advance of, and paving the way for efficient project development.
- The Federal government should set a National Offshore Wind Target to demonstrate to the international community that we are serious about developing offshore wind and a strong local capability and industry.
- The government must coordinate the development of transmission infrastructure from the grid to a shared connection point at an offshore substation to facilitate accelerated development of offshore wind. Projects in the Area should be required to cooperate on the use of shared infrastructure with an appropriate mechanism to allocate costs, risks, ownership, and control.
- The government must coordinate the development of transmission infrastructure from the grid to a shared connection point at an offshore substation to facilitate accelerated development of offshore wind. Projects in the Area should be required to cooperate on the use of shared infrastructure with an appropriate mechanism to allocate costs, risks, ownership, and control.
- The Declaration should require that all licences issued in the area maximise the contribution of the project to the Australian economy and local communities, including:
- maximise the use of locally produced and supplied goods and services
- maximise the employment of suitably qualified local workers
- provide for training and skills development of local workers, minimum requirements for trainees and apprentices, worker transition opportunities from industries facing closure, and the employment of workers from groups underrepresented in the workforce
- increase employment and income opportunities for First Nations
Thank you for considering our submission,
Sincerely,
Alec Roberts
CLEANaS Chair
on behalf of CLEANaS
[1] AEMO (2022). 2022 Integrated System Plan - For the National Electricity Market. Retrieved from https://aemo.com.au/en/energy-systems/major-publications/integrated-system-plan-isp/2022-integrated-system-plan-isp
[2] IEA (2019). Offshore Wind Outlook 2019. Retrieved from https://www.iea.org/reports/offshore-wind-outlook-2019
[3] Robertson, B. and Mousavian, M. (2021) Australia’s Gas-fired Recovery Under Scrutiny. Retrieved from https://ieefa.org/resources/australias-gas-fired-recovery-under-scrutiny
[4] Clayton Utz (2022.) Australian offshore wind guide 2.0. Retrieved from https://www.claytonutz.com/knowledge/2022/september/australian-offshore-wind-guide-2-0
[5] NASA (n.d.). Scientific Consensus: Earth's Climate is Warming. Retrieved from https://climate.nasa.gov/scientific-consensus
[6] BOM & CSIRO. (2020). State of the climate 2020. Retrieved from https://www.csiro.au/en/research/environmental-impacts/climate-change/State-of-the-Climate.
[7] Steffen, W & Bradshaw, S (2021). Hitting Home: The Compounding Costs of Climate Inaction. Retrieved from https://www.climatecouncil.org.au/resources/hitting-home-compounding-costs-climate-inaction/.