NewEnglandWindSubmission NSW REAP

7/31/2019 NewEnglandWindSubmission NSW REAP

1/7

26 October 2012

Renewable Energy Action PlanResources and EnergyNSW Trade & InvestmentGPO Box 3889Sydney NSW 2001

Dear NSW Renewable Energy Taskforce Members

SUBMISSION ~ NSW R ENEWABLE ENERGY ACTION PLAN

Please find enclosed a submission from New England Wind regarding the draft NSWRenewable Energy Action Plan.

We welcome the opportunity to be able to review and comment on the draft Plan, andcommend the NSW Government on their efforts to progress the pursuit of affordable andsustainable energy for residents and businesses throughout the State.

This submission is focussed on aspects of the Plan which are most relevant to our work establishing NSW's first community-owned wind farm, in the New England High Country.

While there are several aspects of the Plan which are positive with respect tocommunity-owned renewable energy and energy sustainability more generally, the Planoverall lacks sufficient clarity as to how the 20% renewable energy target will beachieved. Nor does it clearly position this Plan's focus on stationery energy within themuch larger context of NSW's entire energy footprint.

Two recent research reports reinforce the risk posed for residents and industry shouldNSW lag behind in the uptake of renewable energy and sustainable energy systems.

The 2012 Australian Energy Technology Assessment 1 predicts that by 2030 renewabletechnologies such as solar photovoltaic and on-shore wind are expected to have thelowest LCOE of all of the evaluated technologies.

Given that energy systems are long-term capital infrastructure with operational lives of40-60 years and more, the investment paradigm for energy has already swung towards

1 Australian Energy Technology Assessment, Bureau of Resources and Energy Economics,Australian Government Resources, Energy and Tourism, July 2012

WWW.NEWENGLAND WIND.COOP is a partnered community enterprise by www.starfishenterprises.net

PO Box 991 ARMIDALE NSW 2350 | ABN 26 150 552 962

Page 1 of 7
http://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.starfishenterprises.net/http://www.newenglandwind.coop/http://www.starfishenterprises.net/


2/7

renewables and away from fossil fuels. The affordability of NSW's energy supply rests onrecognition and response to this new reality.

Second, the health benefits of climate action such as renewable energy are significant.The recent briefing paper Our Uncashed Dividend 2 puts the health costs of coal-firedpower in Australia from lung, heart, and nervous system diseases at $2.6Bn per annum.As the largest coal-fired power user state in Australia, NSW residents bear the largestshare of this health burden.

Community-owned and community-scale renewable energy presents a strategicallysignificant opportunity in progressing energy affordability, sustainability, justice andsustainability by:

leveraging local investment with government and philanthropic support for community-commercial partnerships which utilise state-of-the-art renewableenergy technologies. A 2004 study by the U.S. General Accounting Office foundthat local ownership of wind farms generates an average of 2.3 times more jobsand 3.1 times more local dollars compared to absentee ownership 3

augmenting existing grid infrastructure at the points of generation and usage tosignificantly reduce the infrastructure costs, particularly of high voltagetransmission and distribution more generally

enabling local leadership, education and responsibility to solve energy needsrather than merely taking roles as advocates and complainants

We thank you for your consideration of our submission which follows.

Please feel free to contact the undersigned should you wish to discuss this submissionfurther or require any additional information.

Sincerely yours

Adam F BlakesterProject Director | New England Wind & Executive Director | Starfish Enterprises Network [email protected] | 02 6775 2501 | 0419 808 900

Attachment New England Submission regarding Draft NSWWind Farm Planning Guidelines

2 Our Uncashed Dividend, The Climate and Health Alliance and The Climate Institute, August

20123 Renewable Energy: Wind Powers Contribution to Electric Power Generation and Impact on

Farm and Rural Communities, U.S. Government Accountability Office, September 2004

WWW.NEWENGLAND WIND.COOP Page 2 of 7
mailto:[email protected]://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.newenglandwind.coop/mailto:[email protected]://www.newenglandwind.coop/


3/7

DETAILEDSUBMISSION

P OSITIVES

New England Wind applaud the NSW Government's specific consideration and supportfor community-renewable energy (CRE). There is a large and growing global evidencebase which demonstrates the significant benefits, leveraged return on investment andimportant part played by CRE within the broader energy sector.

We also welcome the broader focus and inclusion of energy efficiency, recognising itscritical part in achieving affordable and sustainable energy overall, as well as its role inensuring that renewable energy is only used to satisfy efficient energy demand.

The creation of new resource mapping data to identify viable locations for renewableenergy development, and Crown land that can be used for potential renewable energyproduction, is likely to be very valuable.

There is an obvious opportunity, albeit complicated to realise, of identifying locationswhich are 'sweet spots' in that they have renewable energy resources, accessible gridcapacity, suitable land and supportive landholders and neighbours.

And lastly, New England Wind wishes to strongly support the continuation of theRenewable Energy Precinct Program (REPP), and the proposed review with a view toexpanding the Program. The REPP has provided critically important assistance to NewEngland Wind and other CRE projects throughout NSW. They have also played animportant role in facilitating communication between the community, local stakeholdersand renewable energy developers.

A REAS N EEDING F URTHER W ORK

New England Wind's main concern with the current draft of the REAP is the significantreliance on a NSW Government role of facilitating, encouraging, exploring andlinking. It is often unclear exactly what action is being proposed, who will do the work,what resources are to be allocated, when outcomes are expected, and who isultimately responsible for implementation.

While the REAP notes that current forecasts show that wind energy will deliver the bulk of new renewable generation up to 2020, the development of wind farms in NSW arebeing hindered by the uncertainty created with the proposed draft NSW Wind FarmPlanning Guidelines remaining incomplete.

There is a very significant reliance upon the new Renewable Energy Advocatethroughout the entirety of the Plan. However it is not clear whether this is a new office or unit, or merely a new staff person, and whether it is adequately resourced to fulfil the

breadth and scale of responsibilities identified. The Plan is also unclear what agreementshave been established with the relevant authorities and key stakeholders (eg. EssentialEnergy, AEMO, TransGrid) to enable the identified functions for the Advocate.

http://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.newenglandwind.coop/http://www.newenglandwind.coop/


4/7

These weaknesses seriously undermine the Plan with respect to realistically mapping apath to achieve the 20% renewable energy target for NSW. NSW is especially vulnerable

given its very low current level of renewable energy, and the fact its current generation ispredominantly from the Snowy Hydro Scheme given the increasingly variability of rainfallpatterns with climate change, and increasing needs for environmental flows ashighlighted in the Murray Darling Basin planning process.

The proposed support to facilitate community ownership of renewable energy projectsby providing funding for local feasibility studies for up to five community renewableenergy projects is welcome.

However, the Plan falls short of being able to meaningfully progress projects. Most CREprojects in NSW, other than New England Wind, require pre-feasibility rather than

feasibility studies to move ahead. Having moved beyond this point, projects like NewEngland Wind need more significant funds to progress to the critical point of being ableissue a share offering. Sustainability Victoria provided staged funding of $1.1m for Hepburn Wind, while the Australian Government are providing a 50% capital grant for Denmark Wind Farm. New England Wind will need to undertake the commercialequivalent of $4-6m of work before being able to issue a share prospectus.

The Plan also misses the critically important area of demand management, and fails toadequately address the need for fairer terms for small scale renewable energygenerators (including solar hot water). These two strategies, together with energy

efficiency, play a significant part in reducing both electricity usage (and bills) as well asreducing the need for energy generation.

New England Wind recognises that the scale of its impact will be significantly influencedby the extent to which we can enable homes and businesses to reduce demand,increase efficiency and install embedded generation. In this way, our community-ownedwind farm can best contribute to the widely shared vision for energy self-sustainability inthe New England High Country. Such big goals are best achieved with each party andpart of the energy system 'rowing in the same direction'.

Recognising this, New England

Wind works with a three-stagemodel for sustainable energy,and recognises that the mostsustainable energy system is onewhere the renewable energysupplies the most essential andvalue-adding energy needs only(and not wasted or wastefulenergy use).

In contrast to the new energyresource mapping, we feel thatthe proposed information portal



5/7

summarising all government programs is unlikely to create new information or addressthe substantive barriers to greater uptake of renewable energy.

Lastly, the REAP is not sufficiently clear in how it describes the various renewable energyinitiatives to distinguish between those that are situated in NSW as compared with thosewhich are NSW Government endeavours. This leads to numerous instances where thePlan implies attribution of an initiative to the NSW Government when in fact there hasbeen limited or no involvement. For example, Sydneys role as a major financial centrefor facilitating investment in renewable energy projects is an Australian Governmentrather than NSW Government initiative.

RECOMMENDATIONSThe following recommendations are made to strengthen the REAP and address theweaknesses detailed above:

1. Ensure the REAP delivers affordable and sustainable for NSW residents and industryby

1.1. Include an assessment of how the Plan will contribute to achieving the20% Renewable Energy Target, including the policy, regulatory and budgetarydrivers which will do this

1.2. Clearly explain that the focus of the REAP is on the 20% Renewable

Energy Target by 2020 which addresses stationery electricity only, and does notaddress the far greater energy demands for transport, liquid and solid fuel

1.3. Commit to review the current 20% renewable energy target in view ofthe ABARE modelling which highlights the likelihood of renewable energyproviding a lower cost of energy than coal or gas by 2030

1.4. Ensuring the identified priorities are supported with sufficient resourcesand delegated responsibility, including

a) sufficient capacity for the new Renewable Energy Advocate

b) sufficient capacity for the current and potentially expanded RenewableEnergy Precincts Program

c) negotiating agreement with the various relevant non-NSW Governmentauthorities and stakeholders identified as key

d) establishment of a stakeholder mechanism to provide ongoing dialogueand facilitate collaboration, including the participation of industry,consumer, community, welfare and environmental groups

1.5. Review and incorporate the key role of the Industry Capability Network to ensure NSW businesses are informed to consider providing services to allrenewable energy projects (in NSW, Australia and New Zealand)

1.6. Incorporate demand management



6/7

2. Increase support for community-owned and community-scale renewable energyby

2.1. Funding pre-feasibility studies for new initiatives (it is suggested thatgrants of $50,000 per initiative would be adequate)

2.2. Provide adequate funding for projects which have progressed intofeasibility study work to significantly progress their developments (it is suggestedthat grants of $250,000 and upwards would be required per initiative)

2.3. Investigate the merits of local and regional renewable energygeneration with respect to optimising use of existing local distribution networks(and so reducing demand on the high voltage transmission network, and inturn the need for expensive capital infrastructure upgrades)

2.4. Finalise the draft guidelines for wind farms (refer enclosed copy of NewEngland Wind submission)

2.5. Strengthening support for small-scale generation including

a) a fair price for exported energy

b) implementing the COAG agreement for the mandatory phase out ofelectric hot water systems

c) review and upgrade BASIX which still enables construction of large energyusing new dwellings with only the most basic considerations of embeddedenergy and passive and active energy efficiency



7/7

ABOUT NEW ENGLAND WINDNew England Wind is working to establish the first community-owned wind farm in NSW,with 8-12 turbines producing the equivalent of electricity for 10-15,000 homes (being theequivalent of usage by around half the homes of the New England High Country).

The final size and capacity of the wind farm will depend upon a range of variables suchas wind resource, electricity grid capacity, turbine technology and requirements toensure overall financial viability. The project has completed pre-feasibility and is nowworking through the feasibility of a specific site, 20km north-east of Armidale.

New England Wind is currently operating under the auspice of Starfish Enterprises, with an

independent organisation, New England Wind Cooperative, in the process of beingestablished to carry this work longer-term.

ABOUT STARFISH ENTERPRISESStarfish's purpose is to enable social change for rural and regional sustainability. Starfish isstructured as a non-profit company that uses as community enterprise business model.Starfish supports a network of community entrepreneurs who work individually andcollectively on a diverse range of sustainability initiatives.

Community renewable energy is a priority for Starfish.Starfish is responsible for the largest community solar initiative in Australia, Farming the Sun , which won a

NSW Government Green Globe Award in 2011.The principle at the core of Starfish's DNA, and themeaning behind our name and logo, is to enable,support and spin-off self-sustaining initiatives ~mimicking the starfish's natural ability to grow an entire new starfish from a lost limb aswell as regrow its lost limb!

Auspicing New England Wind is an example of this principle in action, providing servicesand support which enable it to become independently viable and self-sustaining.

Community-owned renewable energy is highly sustainable. It delivers significantenvironmental, economic and social outcomes. It enables community leadership andresponsibility and enables a profoundly more benign and affordable energy system.


NewEnglandWindSubmission NSW REAP

Documents

Transcript of NewEnglandWindSubmission NSW REAP