Chief Executive Officer

Powerlink Queensland

PO Box 1193

Virginia Qld 4014

Dear Mr Jardine,

Re: Woolooga to Eerwah Vale Power Line and Substation Project

Whilst appreciating Powerlink has a large number of transmission line acquisition projects, it nevertheless is now approaching 12 months since your site visit to Cooroy on 12 July 2010 as part of Powerlink’s CID application process to the above named project.

PAGE remains keen to see the aims of both Powerlink and the community met in regard to the issues unveiled during the EIS and CID processes. We appreciate that Powerlink must maintain the infrastructure capabilities to carry energy to where demand requires it in a timely manner. Our consultations with both sides of politics have established, however, that all agree that Powerlink’s needs must be met in a manner that also preserves the environment and sensitive habitat of areas for future generations.

This is especially so when lower impact and lower cost alternatives can strategically deliver similar security of supply over what is currently proposed by your organisation in the EIS and CID. A key question that Powerlink has never answered remains: Why impact one of the last pristine habitat and healthy koala colonies when existing infrastructure corridors should be utilized avoiding environmental destruction when a viable alternative exists?

The complexities and difficulties of the approach Powerlink is seeking to impose on the Ridgewood and Eerwah Vale areas could be clearly gauged from the extended time and effort being taken by Powerlink to address the issues raised by the community and PAGE Inc. Unfortunately, it has become clear that this extra time has been spent simply attempting to justify Powerlink’s original position and countering and devaluing the merits of the PAGE alternative, rather than adopting a positive ‘let’s see if this approach works’.

This dismissive and counterproductive attitude is further evidenced by the fact that Powerlink has declined to engage with PAGE to ensure that there is no repetition, in the CID application to the Minister, of the significant errors and distortions by Powerlink of the community’s submission, which resulted in the flawed evaluations and costings in the final EIS document.

In addition to this “in bad faith” approach, you have also declined to provide the Powerlink review of PAGE’s electrical consultant’s report tendered as part of our final EIS submission, and which was requested during our meeting on 12 July 2010. Mr Jardine, will you now please arrange for the Powerlink review of that electrical report to be provided to PAGE so that the engineering consultant can evaluate and address any incongruities, as is required in an open and transparent process?

In addition to the consistent misrepresentation by Powerlink of essential points raised in community submissions, there are a number of other important issues that warrant a re-evaluation of your proposed CID application before it is presented to the Minister. For example:

Issues:

1. The present Powerlink proposal does not provide a true long term solution to the short term energy limitation identified. Additional network augmentation will be required to correct those limitations in the future, contrary to Powerlink statements made in the EIS documents.This will necessarily result in significant additional costs and environmental impacts not disclosed in the EIS.

2. The Powerlink proposal does not adequately support the Palmwoods substation for the long term, the real hub from where future energy growth will be supplied to Caloundra South, Palm View, and the main areas projected for greenfield population growth by the State Government.

3. Many important points in the EIS are incorrect and/or out of date, invalidating Powerlink’s conclusions supporting their CID. Some of the more glaring errors include:

a. The basis for the works to be ‘needed’ by 2014 should now be revised to indicate a more appropriate updated schedule, as per AER specifications.

The effects of the Global Financial Crisis (GFC) have resulted in dramatic slowing on the northern Sunshine Coast area supported by the Energex network being addressed. The major section (viz. the Noosa area) had been significantly slowing even prior to the GFC.

b. The alternate proposal from PAGE is not evaluated or costed fairly – case in point, Final EIS, App U re Powerlink named options G1, and G2.

c. Information given to PAGE by you, Mr Jardine, on 12 July 2010 supports the PAGE proposal suggesting the augmentation required needs to be to the Palmwoods substation as part of the long term strategic energy solution for the Sunshine Coast.

d. The EIS does not include important indigenous cultural heritage issues involving impacting the Ridgewood Eerwah Vale view-shed, which Powerlink were informed of during the initial consultations in 2007.

It has been noted in other reviews that as an organisation Powerlink shows “no humility” in their dealings with the community. It is certainly PAGE’s experience that community consultations have been little more than lip-service, with a more environmentally sensitive and cost effective alternative dismissed out of hand. This characteristic approach of old-style bureaucrats does not adhere to the spirit or letter of Government and community expectations regarding genuine community consultation in the 21st century, and appears to reject out of hand the prospect that any option other than Powerlink’s original position could be the better option.

PAGE’s and the local community’s unfortunate experience with Powerlink is reinforced by the information that is provided in response to individuals’ letters to the Minister, which is so clearly self-serving misinformation that it defies belief that any senior officer in Powerlink could possibly have checked and approved this for the Minister’s signature. This is in strong contrast with PAGE and Noosa Biosphere’s experience in their dealings with Energex and that organization’s willingness to be open and transparent in their dealings with community groups.

We believe that a positive approach and appraisal of PAGE’s alternative, by Powerlink, would result in a win-win situation for all, as Powerlink would deliver the necessary energy needs and equally protect important environmental habitat areas. This in turn benefits the Queensland government as it would demonstrate that it actively supports its ideals of delivering power at cheapest cost and protecting the environment in the planning and construction of such projects.

PAGE is available to assist Powerlink in resolving and completing a proposal that meets both Powerlink criteria and community expectations of 21st century solutions.

Yours Sincerely

Jack Connolly

President, Powerlines Action Group Eumundi (P.A.G.E.)

Dear Stuart,

I am writing on behalf of PAGE members in anticipation of the upcoming EIS.

As part of the EIS process we would like to see, either included as part of the EIS itself, or as a separate document or as an appendix, detailed information pertaining to the justification of the proposed transmission line project.

While not an exhaustive list, we would like the following details, at the very least, to be available for perusal:

• analysis of all costs comprising the project budget of $100m+;
• detailed assumptions leading to the decision for the need of the project;
• information on how the Noosa Strategic Plan’s population cap of 62,500 has been factored into the project forecasts;
• exact figures used for population growth projections in the project, and over what period;
• projections and/or assumptions made in relation to electricity usage, electricity pricing and related costs that have been used in the analysis for the project;
• how the current economic recession has been factored into project justification;
• the relative figures and percentages used in calculations relating to business and residential usage requirements respectively;
• how project calculations have been adjusted to take into account the increased use of energy efficient appliances;
• specific analysis on air-conditioning take up reaching saturation levels and the impact on expected demand;
• how project calculations have been adjusted to take into account the behavioural change impact of demand management and initiatives such as the state government’s ClimateSmart program, the Sunshine Coast Regional Council’s sustainable development, climate change, peak oil and renewable energy initiatives, new building development codes making for more energy efficient housing to name a few;
• what impact is forecast on energy consumption due to the Carbon Pollution Reduction Scheme;
• how specifically will the goals set out by the government in Q2 (reducing Queenslanders energy consumption by 1/3) affect this project.

Given the size of this project and the allocation of costs and resources that will be supported by tax payers funds, we expect that it is perfectly reasonable that all these factors and any other assumptions that you have made in the project calculations which may not be listed above be available in detail for the community to examine.

If any of this information is not provided at the outset of the EIS, then we would have no choice than to request an extension for the EIS period which we understand will be six weeks. And to such time as this information is made public.

We care for what is happening in our environment and therefore want to ensure that we are able to give our full support to the EIS process by being able to read and comment appropriately and with the due diligence that I am sure Powerlink would want us to.

Regards
PAGE

Dear Stuart

As you are aware, the residents in the Eerwah Vale and Ridgewood community take the preservation of the environment very seriously and are deeply concerned with the impact that the proposed transmission lines will have on the local flora and fauna. This is clearly identified by the number of Land For Wildlife signs in the area, the catchment programs currently run by Land For Wildlife, the number of trees planted by residents and local council, as well as the recent documented sighting of the Richmond Birdwing butterfly to name a few.

More residents have asked me to request that you provide a schedule in the draft EIS of environmental studies undertaken by Powerlink/Parsons Brinkerhoff that include detail on the following information:

• date, time and length of each visit by PL/PB survey party (we will be checking with local residents and verifying this)
• area surveyed (specifically which properties)
• specific findings relating to each property
• methods of fauna surveys, and different types of trapping methods used for fauna in each ecosystem and habitat type
• what season and frequency, and whether the fauna is diurnal or nocturnal
• flora surveys assessing all vegetation in the regional ecosystems, and all microhabitats that have been searched and the floristic
• assessment including seasonal variation, including aquatic plants

As we understand, your studies have been undertaken over a short period, so please outline what assumptions have you made in relation for migratory or seasonal patterns of the fauna temporarily resident in the area for any part of the year not covered by your survey period.

We will be asking independent environment consultants to review this schedule and determine if this is satisfactory. We also seek to ensure that the  environmental studies have been completed thoroughly regardless of the statutory requirements – it would be environmentally irresponsible to know a study has been inadequately completed as a result of minimal statutory guidelines being adhered to.

We also see a clear conflict of interest between Powerlink and Parsons Brinkerhoff (where PL are paying for PB’s services) and this information would go some way to allaying residents concerns that the studies and surveys have not been undertaken thoroughly.

If the detail outlined above is not provided in the draft EIS, we make this request of you now in preparation of the release. Also, if there is a delay in getting this information to us, we expect an extension to our, and other party’s submissions, as this information is key to any submission to the draft EIS.

Regards
PAGE

Stuart,

I have been asked by a number of PAGE members to request information be included within the upcoming draft EIS relating to the legal basis upon which Powerlink is basing its right to access the proposed transmission line and the associated easement in the event that it is approved.

As you are aware, the alignment of the proposed transmission line that you have selected would present access challenges to stay wholly within the forcibly acquired 60m easement due to the difficult nature of the terrain. It follows that you have suggested that Powerlink will seek off easement access through landowner’s private property in order for Powerlink to construct the towers. In addition, will Powerlink seek ongoing off easement access over landowner’s private property? In conversations with you in the past you have stated that Powerlink prefer off easement access to be “informal agreements”. Specifically can you outline the nature of these agreements by providing general background information including answering the questions below:

• How the informal agreements negotiated and documented?
• What are the terms and conditions usually applied under these informal agreements?
• Does Powerlink pay compensation for these informal agreements?
• What is the proposed tenure of the informal agreements?
• What is the liability of Powerlink under such an agreement for damage caused by Powerlink when on private property?
• What mechanisms are in place for landowners to claim compensation if damage is caused by Powerlink?
• What liability is placed upon landowners in respect of Powerlink and its agents while on private property under these informal agreements?
• How does a landowner cancel the informal agreement?
• What happens to the informal agreement when the original landowner sells or transfers the property?
• What specific terms and conditions will Powerlink agree to?
• What specific guarantees will Powerlink provide against damage and the spread of noxious weeds for example?
• Will Powerlink respect landowners’ right to restrict access on occasion as necessary?

In the event that a landowner is uncomfortable or unwilling to enter into an “informal” agreement, with Powerlink, please state how Powerlink intend to access the proposed transmission line easement for this project proposal if it is not wholly staying within the forcibly acquired easement?

Assuming that the answer to the last question is the acquisition of yet another easement to access the first easement please state the legal basis upon which Powerlink would attempt to proceed with a secondary forced easement acquisition? Have these costs either as internal real costs for Powerlink or as externalities (yet more costs borne by the landowners, but uncompensated by Powerlink) been included within the project costings to be set out in the draft EIS?

Regards,

Graham Smith,
Coordinator
P.A.G.E.