Sender: WESTWIND ENERGY PTY LTD ABN 94 109 132 201 Address: Office 5, Level l , Nexus Centre, 1 2 - 1 4 Prince Street, Gisborne Vic 3437 Tel: 03 5421 9999 Fax: 03 5428 3 100 Contact: Tobias Geiger To: The Hon. Lily D'Ambrosio MLA Minster for Energy and Resources Victorian Government Melbourne By email: renewable.energy@ecodev.vic.gov.au Wednesday, 30 September 2015 Dear Minister, WestWind Energy - Submission to the Victorian Renewable Energy Roadmap Thank you for the opportunity to provide this submission to the Victorian Renewable Energy Roadmap (Roadmap). WestWind Energy Pty Ltd (WestWind) welcomes and supports the principles outlined in the Roadmap, in particular the commitments of the Victorian Government to grow renewable energy and to open Victoria up to additional renewable energy investment. Introduction WestWind is an Australian company dedicated to the development, construction and operation of renewable energy based electricity generation facilities, in particular wind energy projects. WestWind is part of the broader WestWind Group of Companies that is headquartered in Germany. WestWind has followed the invitation of State and Federal governments to establish in Victoria in 2004 . Since 2004 WestWind has had 235 wind turbines approved in the Ballarat region of Victoria (equivalent to approximately 641 megawatts of installed capacity). These projects include the: Mt Mercer Wind Farm, constructed and operated by Meridian Energy Australia; Lal Lal Wind Farm, approved in April 2009; and Moorabool Wind Farm, approved in October 2010. WestWind also has an early stage development pipeline of wind, solar and battery storage projects. Over the years, well in excess of $18 million has been invested by WestWind into the Victorian economy and we have yet to reach our full potential. The realisation of the approved projects alone represents an investment volume of close to $1 billion over the next three years. Economic benefits of our projects A 2012 study by SKM on the economic benefits of windfarms in Australia found that, for every 50 MW in capacity, a windfarm delivered the following benefits: direct employment of up to 48 construction workers, with each worker spending approximately $25,000 in the local area in shops, restaurants, hotels and other services – a total of up to $1.2 million; direct permanent employment of around five staff – a total annual input of $125,000 spent in the local economy; indirect employment during the construction phase of approximately 160 people locally, 504 state jobs and 795 nationwide jobs; and up to $250,000 per year for farmers in land rental income and $80,000 on community projects each year. Based on these figures the investment our company has made to date on our approved Victorian wind energy projects would lead to: direct employment of 432 construction workers spending up to $10.8 million locally; direct employment of 45 permanent staff spending $1.125 million locally every year; indirect employment during the construction phase of approximately 1,440 people locally,4,536 in Victoria and 7,155 nationally; up to $2.25 million per annum for farmers in land rental income and up to $720,000 on community projects each year; and council rates of app. $650,000 per annum. Response to Victoria's Renewable Energy Roadmap The need for strong targets The Victorian Government's aim to produce 20% of Victoria's electricity from renewable sources by 2020 is welcomed (Section 1.5). However, it is submitted that strong ambitious targets should be established out to 2050 to provide the certainty needed for a strong local and national renewable energy industry; an industry that operates in the energy sector, which typically has investment horizons of 25 years and more. To live up to its aspirations and be a responsible government in an increasingly carbon constraint world, we submit that 100% of Victoria's electricity is to come from renewable sources by 2050 and 50% of Victoria's electricity is to come from renewable sources by 2030. Furthermore, such targets should be enshrined in legislation to ensure they are not just aspirational and subject to constant political profiteering. Meeting these targets could be facilitated in a number of ways. For instance, the ACT's wind energy auction, that enabled projects to bid for long term feed-in tariff entitlements, resulted in one of the lowest power purchase agreements (for all forms of electricity generation) ever being entered into. Additionally a supplementary VRET could be investigated to help soften the impact of a reduced federal LRET. The direct government purchase of renewable energy could also assist in meeting these targets. A measured feed-in tariff to support smaller, mostly local and community driven projects (perhaps up to 10MW). Furthermore, to address the urgency of climate change, consideration should be given to targets and associated mechanisms which directly facilitate fossil fuel generation to leave the national electricity network. The need for a strong federal RET The Victorian Government's intention to advocate for a strong federal RET is also welcomed (Section 3.1). Companies like ours would not have invested in Australia, would not employ permanent staff here and would not bring extensive know how from overseas without the RET. Investments in renewable energy projects have been substantially undermined by ongoing policy uncertainty around the RET. This has been resolved in part, through the removal of biannual reviews. However, this is offset by our developed economy reducing its actual target for renewable energy! A strong federal RET and further reforms to planning requirements will enable Victoria to take a leading role in the development of renewable energy projects. Lack of Federal action on renewables should not be seen to be an excuse to do nothing. We note that Victoria led the way with a strong VRET when the Federal target was at 2% and this was one of the deciding factors for our company to establish in Victoria. Wind farm planning laws Planning laws introduced by the previous State government resulted in our development pipeline being 'parked' for four years, with the associated job losses. It is no surprise that WestWind welcomes some of the reforms made to Victorian planning laws (Section 3.2). In particular, the reduction in the required setback distance from two kilometres to one kilometre (unless consent is obtained). However, we respectfully submit that planning laws still do not align with the election and policy commitments of the Victorian Government. Specifically, government should consider acting on the following points: Blanket bans remain. These bans prohibit the development of wind energy from parts of Victoria - including high wind speed areas. These bans put one of our projects in the Macedon Ranges Shire on halt indefinitely; Expiry times. Planning permits have not provided enough time for projects to commence or complete their developments. While permits can be extended, the process contains an element of uncertainty which concerns potential investors. Expiry times should be significantly expanded for wind energy permits; and Amending permits. Making changes to existing planning permits can be complex where the permits have been issued by the Minister for Planning. A streamlined approach is provided for Council issued permits (no third party appeal rights) however this does not apply to the majority of wind farm permits which were issued by the Minister. This means that minor changes to permits will often require public notice and full planning panel hearings to consider submissions. This comes with significant costs, which are to be borne by developers and creates significant uncertainty for potential investors. We note the need for an appropriate level of community engagement and consultation. However, there is a need for greater flexibility to enable reasonable changes to be made to existing wind energy permits without unnecessary investment uncertainty, delays and associated expenses. Government use of renewable energy WestWind would support the Victorian government in purchasing electricity from renewable energy sources. This has worked well in the past and we note the role of the Melbourne Water tender in facilitating the MacArthur and Oaklands Hill Wind Farms. Similar models could be rolled out to other large government electricity users. In our view this would also send a positive message to the corporate sector. I hope the above comments are helpful to you in the preparation of the plan and we happily offer our further assistance. Yours sincerely, Tobias Geiger MANAGING DIRECTOR