Sender: Trustpower
Address:
Private Bag 12023
Tauranga Mail Centre
Tauranga NZ 3143
Tel: +64 07 574 4754
Fax: +64 07 574 4825
Web: trustpower.co.nz
To: The Hon. Lily D’Ambrosio MLA
Minster for Energy and Resources
Victorian Government
Melbourne
By email: renewable.energy@ecodev.vic.gov.au
30th September 2015
Dear Minister
Submission to the Victorian
Renewable Energy Roadmap
Thank you for the opportunity to provide this submission to the Victorian Renewable Energy
Roadmap (Roadmap).
Trustpower Limited (Trustpower) generally supports the principles outlined in the
Roadmap. In particular, Trustpower welcomes the commitments of the Victorian
Government to further incentivise the growth of renewable energy and to open Victoria up
to additional renewable energy investment. However, Trustpower submits that the Victorian
government could go further to support the development of renewable energy in Victoria.
Overview
Trustpower is New Zealand’s fifth largest electricity generator and retailer and sits within the
top 15 companies by market capitalisation on the New Zealand Stock Exchange. Trustpower
owns and operates an Australian and New Zealand generation portfolio which is primarily
powered from renewable sources.
Trustpower is one of the most experienced wind farm developers and operators in
Australasia and our involvement in wind energy dates back to 1999 (New Zealand’s Tararua
Wind Farm). Trustpower has a strong track record of asset development, enhancement,
operation and maintenance and has led the wind energy industry in lowering costs and
improving reliability.
Trustpower in Australia
Trustpower has been active in Australia for the past 11 years. Trustpower oversees a
growing generation portfolio with a wind energy project pipeline of over 1,000 MW. When
fully developed, these projects will constitute an investment of approximately $2 billion in
Australia.
Trustpowers’ growing wind energy portfolio includes three established and four proposed,
including the Dundonnell and Salt Creek Wind Farm proposals in Victoria. The table below
summarises Trustpowers’ current and proposed wind projects.
Wind Energy Project
Crookwell Wind Farm,
Goulburn, NSW
Blayney Wind Farm,
Carcour Lake, NSW
Snowtown Wind Farm,
Snowtown, South
Australia
Palmer Wind Farm
(Proposed), East of
Adelaide, South
Australia
Rye Park Wind Farm
(Proposed), Rye Park,
NSW
Salt Creek Wind Farm
(Proposed), Woorndoo,
Victoria
Dundonnell Wind Farm
(Proposed)
Turbines
8
Installed Capacity
4.8 MW
Annual Output
8 GWh
15
9.9 MW
18 GWh
138
370 MW
1,335 GWh
114
375 MW
1,300 GWh
109
327 MW
1031 GWh
15
30 MW
100 GWh
104
312 MW
1,000 GWh
Trustpower in Victoria
Trustpower has two proposed wind energy projects in Victoria. The Dundonnell Wind Farm,
north- east of Mortlake and the Salt Creek Wind Farm near Woorndoo. Both of these
projects will constitute a significant investment into South West Victoria.
When operating, Dundonnell Wind Farm is expected to power the equivalent of 150,000
average Victorian homes. The three year construction phase is estimated to employ 200
direct and 100 indirect full time jobs and contribute $309 million to Gross State Product. An
additional ten direct and six indirect jobs will be required to operate and maintain the wind
farm.
Dundonnell Wind Farm is currently awaiting a planning panel hearing (October 2015) to
consider the project’s Environmental Effects Statement (EES) and planning permit
application. The planning panel will provide recommendations to the Minister for Planning as
to whether the project should be approved.
When operating, Salt Creek Windfarm is expected to power the equivalent of 30,000 homes
and will contribute $30 million through operating costs to the economy of the life of the
project.
Response to Victoria’s Renewable Energy
Roadmap
1.
A Roadmap for renewable energy in Victoria
1.5
HOW SUCCESS WILL BE MEASURED
The Government’s aim to produce 20% of Victoria’s electricity from renewable sources is
noted.
To establish and maintain the confidence of the renewable energy sector Trustpower
submits that the Victorian Government should consider aspirational renewable electricity
generation targets of at least 25% by 2020 and 40% by 20251. These targets are consistent
with interstate and international targets. This target needs to be expressed as generation
capacity to ensure a fixed target, as opposed to total energy use which continually shifts.
Equally important are the policy and legislative mechanisms to enable targets to be met with
the lowest cost to the consumer and the taxpayer. Trustpower submits that these targets
should be legislated as a combination of measures such as:
1

shortfall VRET based on current electricity demand projected forward. This would
operate in a similar way to the Commonwealth’s Large Scale Renewable Energy
Target (RET) but would make up for the recent reduction in the Commonwealth
target;

reverse renewable energy auction, similar to the ACT wind auction and linked to a
long term 25 plus years, feed-in tariff entitlement for successful projects,

legislated Victorian Government purchase of electricity generated by renewable, see
3.3 below; and

an installed capacity target of project approvals. Such a target could be inserted into
the Victoria Planning Provisions.
1 Other state and national renewable energy targets include, California 50% by 2030, New Zealand 90% by
2025 and Germany 40-45%by 2025. (REN 21 (2015) Renewables 2015 Global Status Report. Paris: REN21
Secretariat). South Australia 50% by 2025 (RenewEconomy (2015) South Australia sets 50% renewable energy
target for 2025. RenewEconomy, NSW).
Additionally, increasing renewable energy targets should go hand in hand with legislated
targets for the significant reduction in greenhouse gas emissions from the electricity sector
before 2025.
3.
Transforming Victoria’s generation stock towards
renewable energy
3.1 ADVOCATE FOR A STRONG FEDERAL GOVERNMENT POLICY ON
RENEWABLE ENERGY
Over the last few years Trustpower has invested heavily to purchase development options,
secure landowner agreements and undertake expensive approvals processes. However, the
pace at which Trustpower has been able to progress its projects through to construction has
slowed considerably in recent years, due to the uncertainty over the RET and restrictive
planning laws in Victoria.
Although strong global investment in clean energy continues to grow at an average of 20%
per annum since 20042, over the past 24 months Federal RET changes have had a
significant detrimental impact on large scale renewable investment and clean energy jobs in
Australia.
The need for Federal Government leadership is apparent. Trustpower supports the Victoria
Government in advocating for an enhanced RET to enable Victoria to exploit its natural
advantages for renewables, particularly wind.
Trustpower also notes that in the past, Victoria has taken a leading role in promoting the
growth or renewable energy at times where Federal leadership was lacking.
3.2
REFORM OF VICTORIA’S WIND FARM PLANNING LAWS
Trustpower welcomes recent planning reforms relating to wind energy in particular, the:

return of the Minister for Planning as the responsible authority considering all new
wind energy proposals; and

removal of the prohibition of wind turbines within two kilometres from dwellings
(unless landholder consent is obtained).
Restricted areas
Trustpower notes that some of the restrictive wind energy policies remain. For example,
wind energy bans (introduced by the previous State government) exist over large parts of
Victoria. These bans prohibit access to excellent wind resources. Trustpower submits that
the bans should be reconsidered.
Changing permits
From time to time wind energy proponents may wish to make changes to their planning
permits. The process for making changes to permits in Victoria can be complex. Additionally
the process to change a Council issued permit differs from a permit issued by the Minister
for Planning. For example, if an amendment to the Salt Creek Wind Farm was required, the
changes would be assessed by Council and the amendment would be exempt from an
2
UNEP & Bloomberg (2015). Global Trends in Renewable Energy Investment 2015. Frankfurt School UNEP
Collaborating Centre for Climate and Sustainable Energy Finance
objector’s appeal to the Victorian Civil and Administrative Tribunal3. Alternatively if the
Dundonnell Wind Farm needed to be changed at a future date, it is likely that the
assessment process would need to be repeated and reconsidered by a full planning panel.
Trustpower submits that greater flexibility should be introduced to the Victorian planning
system to enable reasonable changes to be made to existing wind energy permits without
unnecessary delays and associated expenses.
Permit expiry
Many wind farm permits in Victoria have short expiry timeframes. Often, wind energy
proponents are given around three years to commence construction of a wind farm and
another three to complete it. When planning for multimillion dollar infrastructure projects,
such timing is restrictive and limited time is available for detailed design, grid connection
design, obtaining finance and investment. While planning permits can be extended, this is
not guaranteed, therefore short expiry periods introduce significant project uncertainty.
Trustpower submits that planning permits for wind energy facilities should only expire if the
development of the wind farm has not commenced within 10 years or is not completed
within 4 years following commencement of the last stage. Precedent exists in Victoria for
permit expiries to be reflective of the special characteristics of the industry. For example,
stone extraction permits are general issued for the life of the stone resource.
3.3 USING GOVERNMENT ENERGY PURCHASING TO SUPPORT
RENEWABLES
Trustpower supports the concept of the Victorian government purchasing electricity from
renewable energy sources. The development of renewable energy generation in the State
could be supported by large public power users (such as Public Transport Victoria and
infrastructure administrators such as Corrections Victoria) purchasing all of their electricity
requirements from renewable energy sources.
This has occurred previously with the Melbourne Water renewable energy tender. This
tender facilitated the construction of the MacArthur Wind Farm and the Oaklands Hill Wind
Farm to power Melbourne Water’s assets such as the Wonthaggi Desalination Plant.
6.
Government role in facilitating the uptake of renewable energy
6.2 PROVIDING INFORMATION TO SUPPORT RENEWABLE ENERGY
UPTAKE
Initiative 1 - Develop Industry Development Plans
Trustpower submits that the Victorian Government should set bold renewable energy targets
and supporting mechanisms and let technologies compete in the market to provide
electricity at the lowest cost to consumers and taxpayers.
Specific industry assistance seems to be more aligned with the Australian Renewable Energy
Agency (ARENA).
3
So long as addition turbines are not being proposed or turbines are not being moved towards dwellings.
6.3
RENEWABLE ENERGY PROJECT FACILITATION
Initiative 1 - Reinstate co-ordinated renewable energy project facilitation
Trustpower supports the need for coordinated renewable energy project facilitation.
The need for such facilitation became evident during the assessment process for the
Dundonnell Wind Farm. A need exists for an agency to coordinate advice and feedback and
work both across government and within government departments and agencies. Such a
facilitation role should report to the Minister for Energy and Resources and have the ability
to:

establish timeframes for consultation, applications and approvals;

provide advice for proponents and the community; and

ensure consistency in the assessment of projects.
Conclusion
Trustpower welcomes the commitments of the Victorian Government to grow renewable
energy in Victoria and looks forward to working with the Victorian government as our wind
energy projects develop.
We hope our comments are helpful in the development of Victoria’s’ Renewable Energy
Action Plan Trustpower would welcome the opportunity further participate in the
development of and related initiatives.
Please contact the undersigned should you have any questions regarding Trustpower’s
submission.
Yours faithfully,
Trustpower Limited
Peter Calderwood
General Manager - Trustpower Australia