Offshore renewable energy infrastructure area proposal: Pacific Ocean off Hunter

27 April 2023

Shelley Nancarrow, Assistant Manager
Offshore Renewable Energy, Adaption and New Industries Division
Department of Climate Change, Energy, the Environment and Water
PO Box 3090
Canberra ACT 2601

Dear Ms Nancarrow

Proposed Hunter Offshore Renewable Energy Area

Thank you for the opportunity to provide feedback on the proposed Hunter Offshore
Renewable Energy Area (HOREA), which extends from Port Stephens in the north to Norah
Head in the south. The southern portion of the proposed HOREA is located adjacent to the
Central Coast Local Government Area (LGA).

At the Central Coast Council meeting of 26 April 2023, Council resolved to make this submission to you to inform Minister Bowen’s decision about whether to grant a renewable energy area for the Hunter and Central Coast. Council recommends that DCCEW undertake further consultation with the Central Coast community before making this important decision.

Council officers have reviewed the available information and attended a briefing session on
7 March 2023. Council understands that the proposed HOREA will provide opportunities to drive economic growth, support and create jobs, provide clean and affordable power and help reach net zero by 2050. If these benefits are shared with the Central Coast, this initiative is expected to make a positive contribution to the LGA, which is a certified Australian ECO
Destination.

However, it is considered premature to declare the HOREA until the consultation is recommenced and further information is available so that it is clear that the project affects the Central Coast community and environment, and the Central Coast community have the opportunity to provide input regarding the potential positive benefits and adverse impacts associated with the proposal.

Wyong Administration Building: 2 Hely St / PO Box 20 Wyong NSW 2259
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Please find below Council’s key comments and concerns in relation to the proposed HOREA.

1) As the proposed HOREA extends along the Central Coast LGA, for full transparency and
to maximise consultation with all affected people, the name of the proposed area must
be amended to include reference to the Central Coast. The documentation omits
reference to the Central Coast, instead focuses entirely on the Hunter. For example, the
natural environment of the Hunter, the importance of fishing to the Hunter Region,
tourism in the Hunter Valley, and the benefits to the local Hunter economy.

Due to its proximity to the Central Coast LGA, all documentation needs to reference
the Central Coast and any benefits must also be shared with the Central Coast. The
consultation (including the location of sessions) must include communities and groups
that are most affected by the impacts, for example the Norah Head community and
representatives from the Norah Head National Surfing Reserve. The current
consultation has not targeted those groups.

2) Whilst it is understood that detailed studies will only be prepared once the area is
declared and a feasibility licence has been granted, there is currently insufficient
information available to demonstrate the environmental, economic and social impacts
the proposed HOREA will have on the Central Coast, including on the terrestrial and
marine environment, marine life and avian fauna, marine users and emergency services.
Council welcomes the opportunity to be engaged in further stages of the proposal, to
provide input from a local government perspective, and encourages DCCEW to
explicitly require potential proponents to consult with Council and the Central Coast
community as part of the development assessment and feasibility analysis processes.

3) Using a Radar Horizon Calculator (which considers the curvature of the earth) and then
factoring in environmental considerations, Council understands that on light wind days,
wind turbines would be visible for up to 40 kilometres from the coastline. Accordingly,
the wind turbines would be visible from a significant area of the surrounding coastline.
Additionally, it is assumed that the turbines will be lit at night. The visual impacts have
not been made clear in the documentation provided.

4) It would be useful if any licence for use of offshore coastal waters for renewable energy
generation explicitly required power generated from such an area to directly benefit
local communities.

5) Similarly, it would be useful if any licence for use of Commonwealth waters provided
for employment benefits to be shared across affected communities, in this case
including the Central Coast LGA, which is part of an identified NSW Renewable Energy
Zone.

6) Council requests that any licence, and subsequent Commonwealth development
assessment process consider the likely impacts of the proposed HOREA, during
construction and operation (including infrasound impacts) on marine life, including
migration patterns for marine mammals, marine reptiles and migratory and sea birds?
Careful consideration in any assessment must also be given to the impact on the Bird

Wyong Administration Building: 2 Hely St / PO Box 20 Wyong NSW 2259
P 02 4306 7900 l W centralcoast.nsw.gov.au l ABN 73 149 644 003
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Island Nature Reserve and the risk of bird strike with wind turbines. Additionally, is
there likely to be any impact and/or interference to the emergency communications
network for lifeguards and Surf Lifesaving and the shark mitigation technology that is
installed?

7) It is noted that in November 2022 Norah Head achieved National Surfing Reserve
Status. The impacts on the surfing reserve including the nine beach breaks, two points
breaks, three Bomboras and two Reef breaks should also be considered at the
appropriate time in the development assessment process?

8) If there are going to be any impacts to the Central Coast, how will the Commonwealth
Government (or the proponent) mitigate, manage or compensate for those impacts? If
there are going to be any adverse impacts, it is essential that all relevant affected
councils, and their communities, are consulted to ensure the appropriateness of those
measures. Additionally, any offsets/compensatory measures must directly benefit the
affected communities. For example, as the proposal also impacts the Central Coast,
proportionate offsets/compensatory measures must benefit the Central Coast.

9) An analysis of the shape of the area and existing water depths shows shallower water
closest to Norah Head (water depths of 70-100m), off the Central Coast LGA. Closer to
Newcastle and further east, the water depths are approximately 100-200m before
dropping dramatically at the continental shelf. At the briefing session, advice was
received that it is generally not viable to construct fixed turbines in water depths
greater than 60m. Instead floating infrastructure would be likely. Further information
will need to be provided in relation to the preferred water depths in which wind
turbines would be constructed to enable an assessment of the visual and
environmental impacts, at the appropriate stage of the development assessment
process.

10) If floating infrastructure is to be provided, it is assumed they would need to be
tethered by tensioned cables. It is noted that the maximum height of offshore waves
(as measured by Waverider Buoys operated by Manly Hydraulics Laboratory) are up to
30 metres. Evidence at the development assessment stage must be provided
demonstrating that there is no risk of the fixed points failing, particularly due to the
proximity of marine vessels. This is essential due to the size and volume of the marine
vessels and the material they transport.

11) In periods of large swells, large marine vessels are often moved out to sea. Any licence
should consider potential impacts of activity within the proposed HOREA on the ability
for these vessels to move out to sea during large swells.

12) The licence and subsequent development assessment process must consider land-
based impacts, including the launch site to facilitate construction of the infrastructure,
maintenance access and supply of energy to the mainland.

This includes understanding how and where will the cables transporting the energy
generated from the HOREA be ported into the land and what and where are the likely

Wyong Administration Building: 2 Hely St / PO Box 20 Wyong NSW 2259
P 02 4306 7900 l W centralcoast.nsw.gov.au l ABN 73 149 644 003
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onshore infrastructure requirements (for example connection into the grid, cable
landing facility, converter stations, onshore substation/interconnection). It is assumed
that access to the high voltage power lines near Lake Munmorah, Eraring and Vales
Point power stations (within the Central Coast LGA) will drive development within the
HOREA.

The movement of helicopters for the maintenance and transport of staff, particularly
during the operational phase, should also be considered at the appropriate time in the
development assessment process

13) Whilst the documentation states that the area is to be shared, it also states that there
will be restrictions imposed around specific infrastructure. Further clarification should
be provided in any licence on what these restrictions will entail. For example:

a. Will these restrictions include volumetric restrictions to prevent aircraft from
flying over this infrastructure? How will this impact flying operations, including
Williamtown, recreational and commercial flights and emergency aircraft
movements?

b. Will emergency services have exemptions to any restrictions, for example Marine
Rescue and Air Ambulance NSW? If not, this will result in increased travel and
rescue times. Additionally, how will the movements of rescue services be
accommodated during the construction period?

c. Will the HOREA result in any changes to the routes travelled by marine vessels
travelling to the Port of Newcastle or Port Kembla (which appears to be the case
based on the 2020 Vessel Traffic identified on the mapping tool)? If so:

i. Will marine vessels (particularly those travelling between ports) be required
to travel closer to the coastline?
ii. Will marine vessels associated with port movements, be prevented from
entering “Coastal Water Areas” (except where immediately
accessing/exiting a port). That is, will they be restricted to waters within the
designated “Offshore Areas”.
iii. Will there be any additional queueing of marine vessels along our
coastline? If so, how will any hazards be managed to prevent potential
impacts, for example pollution along the coastline in the event of an
incident. Whilst it is understood that renewable energy is an alternative to
coal, as the coal ships from Newcastle Port are for external export, will the
proposed HOREA result in any reduction in the number of coal ships? If
not, the cumulative impact of coal ships and the renewable energy
infrastructure need to be considered at the appropriate time in the
development assessment process.
iv. Is there an opportunity to amend the HOREA so that marine vessels
travelling between ports can still travel in a south-east direction when
exiting the Port of Newcastle?

Wyong Administration Building: 2 Hely St / PO Box 20 Wyong NSW 2259
P 02 4306 7900 l W centralcoast.nsw.gov.au l ABN 73 149 644 003
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14) It is noted that the Hunter Central Coast Offshore Energy proposal (available at Hunter
Central Coast Offshore Energy (hccoffshore.com)) shows that wind turbine project as
currently 50% through the feasibility phase, with the approvals process having
commenced and referrals being prepared under the Environmental Protection and
Biodiversity Conservation Act 1999). Additionally, the proposal extends significantly
further south than Norah Head, to approximately Terrigal. Clarification needs to be
provided on the relationship of this proposal with the HOREA, including the
timeframes identified and the southern boundary of the project/HOREA.

15) It is also noted that the consultation documentation states that the capacity of the
Hunter-Central Coast Renewable Energy Zone is likely to increase over time with the
growth of offshore wind. Clarification is required on whether the offshore renewable
energy area is anticipated to be increased in size, particularly to the south.

16) Reference is made to the existing petroleum licence. Details should be provided in
relation to the remaining life of the existing petroleum licence and the interaction
between any approved HOREA and the existing licence.

In summary, whilst Council supports transition to net zero emissions and understands that any proponent would be required to undertake relevant studies during the feasibility and development assessment phases, it is considered essential that further information is available so Council and the Central Coast community can provide informed feedback on the proposed HOREA and potential future renewable energy developments. The consultation material, including the name of the proposed area, does not reflect the likely impacts on the
Central Coast. As a consequence, Council recommends that the consultation period be extended with updated material being provided.

Central Coast Council looks forward to continuing to work closely with you to explore, consider and appropriately manage offshore renewable energy opportunities in the vicinity of the Central Coast.

If you have any questions, please do not hesitate to contact Deanne Frankel on 4325 8379 or
Deanne.Frankel@centralcoast.nsw.gov.au.

Yours sincerely

David Farmer
Chief Executive Officer

Reference: D15582612

Wyong Administration Building: 2 Hely St / PO Box 20 Wyong NSW 2259
P 02 4306 7900 l W centralcoast.nsw.gov.au l ABN 73 149 644 003