Uncertainty remains for the Discovery Bay Ramsar site, due to the highly contested Kentbruck Wind Farm proposal
The proposed Kentbruck Wind Farm has passed the Victorian environmental assessment process despite its siting within a highly sensitive landscape surrounded by nature conservation reserves. NGT has expressed our objections to the siting of the project via the inquiry process and has recently explained our position publicly through ABC media coverage.
OVERVIEW
Since my update in November last year, an ABC News story that I flagged may be forthcoming was published in late December 2025. If you missed that story, called “When green energy threatens what it is meant to save“, you can read it here – or click on the image shown.
As it turns out, it was only a week and a half later that the Victorian Government announced the conclusion of its Environment Effects Statement (EES) process, and released two lengthy documents that (a) informed, and (b) confirmed, its position on the project. You will find more of my thoughts on these documents a little later in this update.
In short – and contrary to the advice of many independent environmental scientists and the wishes of the majority of the local Nelson community – the state government are backing the project to proceed in this location, despite being situated in a highly sensitive landscape, which is around 100 km west of the nearest government endorsed “Renewable Energy Zone“.
There are still many matters that need to be addressed before the project can proceed, with final permits yet to be issued. There is also the key matter of federal government approval under the EPBC Act.
These and other discussion points came up in two ABC radio programs I was asked to participate in, over the days following the announcement. You can listen to those full segments below, noting that my interviews on behalf of NGT start about half way through each recording.
ABC Melbourne Drive Program – 7th January 2026:
ABC South East SA Breakfast – 8th January 2026:
These segments were followed by the publication of a further article by ABC News, which you can also read by clicking on the image below, and also an article in Renew Economy, which you can read here.
THE DETAIL
If you are interested to dive into a little more of the detail, then below are links to the two key documents released by the Victorian Government, and a few of my thoughts on each.
The first document: The IAC Report
The first document, which you can download here, is the report prepared by the Inquiry and Advisory Committee (IAC) that informed the government’s position. At more than 400 pages long, its length should give you some indication as to how many complex issues are raised when a major development is proposed to be sited in a sensitive landscape, immediately adjacent to – indeed surrounded by – National Parks and Reserves, including a Ramsar Wetland of International Importance that supports migratory species and nationally threatened species of birds and bats.
In this report, the IAC stated it “agrees with submitters that from a biodiversity perspective the location is less than ideal for a wind farm.” Yet the structure of the EES process (which is fully funded by the developer, but administered by the Department of Transport and Planning, and Planning Panels Victoria) was not really geared towards firstly determining whether or not the project should be permitted to occur in this location, based on site selection alone – that is, ensuring the correct application of the principle of “avoidance” of impacts under the Mitigation Hierarchy.
As a result, and from my observation, the IAC did not sufficiently question the proponent’s choice of siting. Hence, having accepted it as a given, the process then began breaking down (in a reductionist way) all of the many issues that this siting choice inevitably raised, line by line. The IAC then worked through these with the proponent’s representatives and other parties during the hearing, in an attempt to make the project’s environmental impact “acceptable” (i.e. the EES definition of “acceptable”), while appearing to be cautious to not significantly impact its financial viability.
As outlined at length in our submission (which you can read in this story from last July), NGT strongly disagrees with the opinion ultimately formed by the IAC. They decided that biodiversity impacts in such a sensitive location can be effectively minimised, mitigated and/or offset.
Due to limited survey effort, the level of uncertainty and data deficiency is great, and knowledge of the precise movements and behaviours of threatened and migratory species is poor. Further, proposed mitigation measures are untested in the project setting (where very large turbines would be situated above a pine forest), and the ability to confidently detect mortalities (i.e. birds and bats killed by turbines) is low. As a result, managing wind turbine impacts on birds and bats in this location, with a high degree of rigour and confidence – including those impacts that are known / anticipated and others that are currently unforeseen – will be a very complex and expensive, ongoing undertaking. This is the ‘price’ of proposing major developments in the most sensitive landscapes for biodiversity.
Many of these issues are reflected in the conditions and requirements outlined in the IAC report, but from NGT’s perspective they fall short and fail to see the bigger picture, cumulative risks that emerge, when considered in their entirety.
Of note, the very rules of the EES process itself ensured that the IAC’s findings on ecology matters were more heavily influenced (i.e. “weighted”) by ecological opinions submitted in the form of “evidence” by the proponent’s representatives at the hearing. Given that we were simply unable to participate in the 8-week long hearing (held during business hours) in this way, due to cost and time constraints, and the demands of our other work, NGT had identified this as a risk prior to the commencement of the hearing. So we asked the IAC if it would exercise its powers to call independent expert witnesses to ensure that the most relevant and reputable expertise available, would be heard as evidence, to ensure balance. That request was refused, and hence the only ecological opinions provided to the IAC as “evidence” originated from for-profit consultants employed by the proponent of the development.
According to IAC procedural rules in Victoria, this material was then given more “weight” in the IAC’s deliberations than lengthy submissions made by NGT, other NGOs and threatened species recovery teams, whose material included information provided by a number nationally recognised experts on key species and matters that are at risk from the wind farm proposal.
This procedural limitation has major ramifications because, of note, the IAC also stated in its report that: “If the IAC had considered residual biodiversity impacts could not be appropriately mitigated or offset, this would have impacted its overall findings about whether the Project is acceptable.” Yet the IAC’s discussion of ecology matters heavily references, and ultimately relies upon, opinions provided to it as “evidence” by for-profit consultants employed by the proponent, which actively downplay the many risks highlighted in other parties’ submissions. At NGT, we think this is problematic and will negatively impact public confidence in the EES process and its outcomes.
The second document: The Minister’s Assessment
The IAC report however is not the end of the EES process. It is simply a report that is provided to the relevant state Minister, who then considers the report before making a determination on the EES – on behalf of the State Government – about whether the project can proceed, and, if approved, what conditions should be applied. Interestingly, the EES process is overseen by the Planning Minister in Victoria, not the Environment Minister. Under a bilateral arrangement with the Commonwealth, this assessment is also provided to the Australian Government to inform its assessment under the EPBC Act.
You can download this second document, the Minister’s Assessment, here. This report is then relied upon by the various bodies that will be required to issue permits to the project under various state legislation, if it does proceed.
At almost 200 pages long, the Minister’s Assessment is also a lengthy document, and heavily relies upon the IAC report to form the basis of its recommendations.
Although NGT disagrees with the position now adopted by the State Government under the Environment Effects Act, by not simply disallowing the development in this sensitive location, it is still worth noting that the State’s endorsement is conditional and would require a great deal of further work to be completed (and ongoing measures put in place) to meet the stated requirements.
Finally, and perhaps most importantly, although the EES process informs the federal Environment Minister under the EPBC Act, this remains a separate step that will need to demonstrate the full and correct application of Commonwealth law when reviewing Matters of National Environmental Significance (a much narrower focus than the EES process). We now await the outcome, and hope the Australian Government apply the level of precaution required by law, to protect our nationally threatened species and Ramsar sites, and consider the risky national precedent that would be set if a project of this scale were to proceed in this highly sensitive location.
