NGT has been drawn into a complex and contested issue: A poorly-sited renewable energy project, putting one of our most successful restoration projects at risk

Introduction

After thinking it over quite deeply for the past few weeks, I’ve decided to bring you – our monthly newsletter subscribers – into our confidence, for a candid appraisal of a subject that seems to be largely escaping the attention of the mainstream media and general public. I write this article being aware that it is a departure from our normal style of ‘good news’ content, but for reasons that will become apparent as you read on, we are at a critical juncture and this is a complex topic that needs careful consideration.

The timing is especially important because in rural and regional Australia, we currently sit on the cusp of an explosion in renewable energy developments, and the mining of raw materials required to build them, but the question of precisely where those developments (and mines) should be located in the landscape has not yet been satisfactorily resolved.

In the current political climate, and encouraged by government policies now setting rapid transition targets for renewable energy, for-profit companies have been pushing ahead, seeking to propose and progress projects in the places that (for a variety of reasons) make the most financial sense to them.

I can hear many of you saying, “if Australia is going to transition away from fossil fuel power generation, isn’t that a good thing, so precisely what is the problem?”

Defining the problem: the potential conflicts between biodiversity and renewable energy infrastructure

Getting the market to solve an environmental problem by incentivising renewable energy development, with no stringent geographic constraints, is certainly effective at stimulating lots of speculative activity by developers. Of course, everyone would also be aware that – given the policy direction Australia has now adopted – these developments will have to go somewhere.

But where exactly?

This is the question that quickly exposes two key issues that are driving the potential for ongoing environmental conflict:

Issue 1: The scale and size of renewable energy infrastructure

It is worth remembering that large-scale industrial solar and wind energy facilities occupy a large footprint and require a lot of built infrastructure. This is as a result of their spatial configuration and layout which, by necessity, is vast to collect these diffuse forms of energy.

Issue 2: The demonstrated impact of renewable energy infrastructure on biodiversity

If we take wind energy infrastructure as an example, the international scientific research is now unequivocal that wind turbines (in large numbers, with their fast spinning turbine blades) pose a significant risk to a wide range of highly mobile species, in particular bats and birds. That risk appears to be expressed in two main ways: (1) the risk of direct collision, and (2) the risk of spatial avoidance (i.e. excluding species from areas of former habitat, or the interruption of movement corridors between habitats).

With these two issues as a backdrop, and because there are very few (if any) rural areas outside of public land that have been pre-nominated by state governments as ‘no-go zones’ to strategically protect biodiverse landscapes from renewable energy developments, we’ve now reached a critical juncture and decision point – where the complexity and magnitude of this conflict is being laid bare. This is because proposals which were not guided by any type of government-led strategic landscape environmental assessment – to determine at the outset if they are suitable to be placed in a chosen location, based on biodiversity values and wider landscape attributes (such as movement corridors for birds and bats) – are now working their way through the planning system.

With key environmental issues or threats not considered up-front, and then not being fully assessed until much later in the planning process – after vast sums of money have been spent by developers who become increasingly wedded to their plans – major conflicts between renewable energy development and biodiversity protection are now proving inevitable.

The Victorian State Government, via VicGrid, appears to recognise this problem and is trying to catch up, by making an attempt to better coordinate / guide the spatial layout of renewable energy and transmission infrastructure across this state in the future. While not without its problems, this approach is at least seeking to proactively encourage future developments of this type to be concentrated within a series of proposed “Renewable Energy Zones”, that are predominantly situated away from the largest areas of public land, including Parks Victoria reserves. To learn more about the progress and status of the 2025 Victorian Transmission Plan, please follow this link.

The VicGrid Transmission Plan is expected to be finalised later in the year, but will not be retrospective and, even under the new policy framework, my understanding is that proposals will not be strictly prevented outside of the proposed “Renewable Energy Zones”.

This means that any proposals already in the planning system situated outside of the identified zones are continuing to progress, and new projects in other locations (even if no longer encouraged) will presumably continue to be brought forward.

Needless to say, if we were trying to be strategic, by anticipating and avoiding unnecessary conflicts between renewable energy development and biodiversity protection, this is not an ideal situation that we now find ourselves in.

A current case study that highlights this conflict

In case you were wondering, the potential conflict I have just described is not just hypothetical.

In fact, it is playing out right now, as an Inquiry and Advisory Committee (IAC), established to advise the Minister for Planning under the Environmental Effects Act 1978 in Victoria, has just completed several weeks of public hearings to review submissions on the Environmental Effects Statement (EES) for the “Kentbruck Green Power Hub” wind farm. To learn about this process and its current status, please visit this page.

After the IAC delivers its recommendations to the Minister for Planning in a couple of months’ time, what happens next will be critical, because this has now become a test case that will likely set a precedent for how the State and Commonwealth governments will approach conflicts with biodiversity when a wind farm is proposed in a highly sensitive location, with State and Nationally-listed threatened species at risk, adjacent to National Parks and Internationally significant (Ramsar-listed) wetlands.

From an environmental perspective, this proposal has pretty much every high-risk ingredient you could imagine.

To summarise those risks, if the proposed Kentbruck wind farm were approved in this location, it would:

– place several highly threatened EPBC and FFG listed species at ongoing risk of collision, or reduced habitat availability (through spatial avoidance) over a very large area beyond the development footprint, in a highly sensitive landscape;
– undermine the biodiversity values of multiple adjacent Protected Areas beyond the development footprint, and in doing so, set a risky precedent for all future wind farms proposed immediately adjacent to (or in between) high value biodiversity assets and/or Protected Areas in Victoria; and
– compromise the biodiversity values and conservation status of the adjacent Glenelg Estuary and Discovery Bay Ramsar site, and in doing so, set a risky precedent for wind farm developments proposed in close proximity to Ramsar-listed Wetlands of International Importance, not only in Victoria, but across Australia.

However, from NGT’s perspective, this is not all.

The Kentbruck wind farm is also proposed to be built within hundreds of metres of one of NGT’s longest-running and most successful, community-led wetland restoration projects, the Long Swamp Restoration Project, as shown below.

This important restored wetland is now providing confirmed drought-refuge habitat for a wide range of species, including nationally listed species (such as the nationally endangered Australasian Bittern) that are known to make episodic movements through the proposed field of turbines and are considered to be at high risk of collision.

The ecological outcomes achieved in Long Swamp also resulted in NGT jointly winning the Society for Ecological Restoration Australasia (SERA) Award for Restoration Excellence (for large-scale projects), as reported in the NGT newsletter back in 2018.

The difficult choice facing NGT

As people who work with NGT (or follow our news) will know, we are not a public activist organisation, and we’re not “anti-development” or “anti-renewables”.

Given that our staff live and work across the agricultural landscapes in south-eastern Australia that produce the food, fibre and other natural resources that support our community, we are much more interested in identifying common-ground and working with people to achieve lasting, positive environmental outcomes. Our track-record of restoring habitats, by working pragmatically alongside those people and industries for the past 13 years clearly demonstrates this.

However, in this instance, we have found ourselves drawn into a situation where the hard-won outcomes of our ecological restoration work at a highly significant site, in a remote location, are potentially under direct threat – noting that there are not many areas left in the landscapes where we work that have the ecological attributes, nor international status, of the reserves in Discovery Bay. Put simply, these are values that need to be protected from future harm.

Additionally, against the backdrop of the current political push to rapidly transition to renewable energy production, there is a growing sense that public agencies, systems and mechanisms which were designed to deter or prevent inappropriate development from sensitive locations, are no longer fit for purpose.

Given these factors, NGT took the rare step of deciding to participate in the EES process.

How did NGT participate, and what happens next?

The most recent phase of the process commenced with the public advertising of the EES documents in January.

NGT wrote our initial submission back in March, during the public comment phase, and we indicated that we may wish to appear in person before the IAC Hearing. There were 214 submissions, and the majority of these were strongly against a wind farm proceeding in this location. You can see those submissions here, noting that NGT’s is Submission #124.

The IAC Hearing commenced on Monday 26th May 2025 and ran over a period of eight weeks, concluding on Thursday 24th July 2025.

Due to our other work and commitments, NGT was unable to participate in the hearing on a daily basis, but we did attend and present a more detailed in-person submission on the 7th July 2025, outlining our concerns with the proposed development. Although the wind farm proposal raises many issues, NGT mainly limited our submission to specific concerns related to biodiversity values. As expert practitioners with applied, local knowledge of the behaviour and habitat use of the key species likely to be impacted, NGT was able to provide a considered, independent perspective on these matters to the IAC.

On the same day, three other non-government parties also presented and shared their concerns about the proposal: the Victorian National Parks Association, Birdlife South East SA and Birdlife Australia.

If you are interested to read what NGT’s three speakers (myself and two NGT volunteers: Dr Matthew Herring and Dr Emma Bennett) had to say about the proposal, you can download a copy of the submission here, or view it in the pdf reader below.

It is a solid read, with lots of information and detail, so you might like to make yourself a cuppa first!

As you can see from the material provided here, we have done our best to ensure the IAC would have access to NGT’s independence, knowledge and experience to inform their assessment, but what will happen next remains highly uncertain.

The IAC will provide advice to the State Minister for Planning (under the EES Act 1978) and the Commonwealth Minister for Environment (under the EPBC Act 1999) on whether this development should be permitted to proceed, and if approved, what conditions should apply. However, the IAC has no power of direction, and the final decision will rest with these Ministers alone.

The Discovery Bay environment is a truly special place worthy of protection for future generations, and we simply hope that – as required under the relevant State and Commonwealth legislation – the precautionary principle is fully applied and upheld by both Ministers, to prevent damage to the natural values of this internationally significant ecosystem.