This week, the Queensland Government announced the update to State Code 23 for wind farms. We have been working with conservation groups throughout Queensland (particularly QCC and CAFNEC) to strengthen the renewable planning frameworks, and we welcome this progress. We will all continue to work hard for further reforms with the next Queensland Government to secure better outcomes for nature, communities and First Nations people.
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Overview (provided by Clare Silcock, Energy Strategist with QCC)
This is a good step. The final State Code 23 will improve erosion control, decommissioning and rehabilitation requirements, and noise monitoring. It will send a stronger signal to avoid areas of environmental significance. The draft Renewables Regulatory Framework also has several good ideas, e.g. to standardise assessments of solar, bring renewables under the Environmentally Relevant Activity banner, and set up financial assurance for decommissioning.
However, our work isn’t over yet, and we remain concerned that the statewide biodiversity planning we need to build new transmission and generation with the least environmental impact is too slow, and that developers will still not be required to do community engagement and consultation on a project level.
State Code 23
The draft updated State Code 23 was published for consultation in August 2023 and proposed more detail on assessing environmental impacts, as well as erosion control, worker accommodation, transport routes and decommissioning. QCC’s submission to this draft is here. The final Code has taken the following recommendations from our submission on board:
- The environmental performance outcome in the code no longer explicitly mentions “minimising” impacts, signalling an intent to comply with the mitigation hierarchy
- High ecological value has been defined as Matters of State Environmental Significance
- Rehabilitation has been defined, and projects will be required to submit a preliminary rehabilitation plan as part of the assessment
- An End of Construction Decommissioning Management Plan will be required to remove all construction structures and waste
Additionally, the final Code attempts to address concerns around community engagement and hazards such as bushfires by:
- Requiring Bushfire Management Plan, prepared with QEFS
- Requiring a Complaint Investigation and Response Plan with toll free number, and clear complaints process
- Requiring a Construction Environmental Management Plan for biosecurity etc.
- Requiring a Noise Monitoring Plan and Reports to ensure compliance with the acoustic requirements of operational wind farms
However, the following concerns were not addressed:
- Protected areas were not defined as a sensitive land use, so continue not to require a setback
- A full decommissioning plan is still only required prior to decommissioning, not as a condition of approval
- No further guidance is provided to ensure that free prior and informed consent and self-determination are upheld for First Nations of Country proposed to be impacted
Renewables Regulatory Framework
The Government has released a draft Renewables Regulatory Framework. More analysis of this will follow but some the broad ideas proposed are to:
- Consider other energy infrastructure such as solar
- Expand the role for the state environment agency including a review of identified Environmentally Relevant Activities
- Set standards on lifecycle planning including financial assurance for decommissioning
- Expand the role of the Energy and Water Ombudsman to include landholder and community complaints
- Increase access to information about projects through an online portal, guidance materials, and independent analysis.
QCC is broadly supportive of these but will work with our regional conservation councils and other stakeholders to ensure that proposed changes allow a high degree of involvement and decision making power from the local councils. This framework is open for submissions until 6 December 2024.
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