Environmental Impact Statement (EIS)

EIS Terms of Reference (TOR) document

The community were invited to review and comment on the draft Terms of Reference (TOR), which outlines the issues that must be addressed in the Environmental Impact Statement (EIS) for the proposed development project installing 275kv transmission lines from Woolooga to Eerwah Vale and installation of a electrical substation 3 kilometres north of the historic town of Eumundi.

The Powerlink Draft TOR can be downloaded from the link below:

Powerlink's draft Terms of Reference

The Draft TOR will be replaced by the Final TOR when all comments received have been assessed by the environmental consultants and any necessary inclusions or changes made. The Final TOR is expected to be available from late February/early March onwards, and will guide the preparation of the Draft EIS for the project, which is expected to be released for public comment in mid 2008.

PAGE's submission to the draft Terms of Reference

A copy of PAGE's full and detailed submission to Parsons Brinkerhoff can be found on the link below:

PAGE Submission to Draft Terms of Reference

We have included below the covering letter and the first section of the submission, and would urge you to download the full submission to better understand the issues involved in the proposed development. Please also do not hesitate to fowward it onto friends, family, neigbours and other parties whom you think will be interested or can help.

Covering Letter

Ms Woodland
Project Manager
Parsons Brinckerhoff
Reply Paid 2907
Brisbane
Queensland 4001

24 January 2008

Dear Ms Woodland

Draft Terms of Reference for EIS Woolooga to Cooroy Transmission Line and Cooroy South Substation Project

Introduction

Powerlines Action Group Eumundi Inc (PAGE) is a community group formed to ensure that the wider community interests are served when considering how to provide energy for sustainable development on the Sunshine Coast. With this in mind PAGE wish to work constructively with the Queensland State Government and its Agencies to deal with the two key issues facing the Sunshine Coast with respect to provision of energy:

• 1. Existing Short-term constraints within the Powerlink / Energex network and
• 2. Provision of energy in a manner that is consistent with sustainable and ethical development on the Sunshine Coast.

This submission addresses the general issues noted above and also specific points within the draft Terms of Reference (ToR). In the specific comments table extracts from the Draft Terms of Reference are in black and PAGE’s comments are in blue.

We trust you will give our comments due consideration and we look forward to receiving the EIS Terms of Reference in due course.

Yours faithfully

Graham Smith
Coordinator
Powerlines Action Group Eumundi

cc: Jo-Anne Bragg, Environmental Defenders Office
cc: Australian Electricity Regulator

Items Relating To The Whole Document

Throughout the document the word “should” and “may” are used. Clear and concise wording such as “will” and “shall” are more acceptable and give a clearer indication of what is to be included in the EIS. We recommend that ambiguous language is removed from the terms of reference.

Where legislation, plans, guidelines or other official documents are referred to, quoted or in any other way relied upon, provide the page and section reference to enable a reader to easily find and understand the relevance and importance of the particular reference.

Part 2 – Project Needs and Alternatives General Comments

State Purchasing Policy (SPP) and Financial Administration and Audit Act 1977 (FAA)

The FAA clearly states the Charter of social and fiscal responsibility must be based upon the following principles:

"(c) there must be equity relating to the raising of revenue, delivery of government-funded services and allocation of resources, and between present and future generations;
(d) there must be prudent management of risk".

The proposed project is questionable on both grounds noted above and PAGE requests that the ToR address the issues raised under the FAA. The project is a significant investment to fix a short term constraint within the Powerlink network and also to provide significant future capacity (undefined by Powerlink) over a time horizon of 50 years. Given the significant regulatory uncertainty surrounding the Electricity Generating sector at the present time PAGE contends that:

• Investing over the 50 year time horizon is not prudent management of risk, where the probability of stranded infrastructure is increasing due to the increasing awareness of the impacts of climate change and the policies that will be required to combat this issue (Mandatory Renewable Energy Targets - MRET – of 20% by 2020, carbon pricing and emission caps from 2010, Post Kyoto negotiations, energy efficiency and demand management). A more prudent approach would propose a staged approach to infrastructure deployment - a solution that resolves the short-term network constraints in the next two regulatory periods and provides more time to analyse the regulatory and market changes occurring in the short to medium term.
• A project of 50 years has a capital cost that is amortised over the life of the project, which spreads the cost between the generations benefiting from the infrastructure. Given the level of risk associated with stranded infrastructure in the medium term this results in a single generation bearing the cost of the investment in the transmission infrastructure and the cost of replacement technology in the medium term. This is clearly inequitable.

The SPP states that it is a Queensland Government priority to:

• protect Queensland’s unique environmental and heritage assets
• promote sustainable development through responsible use of the State’s natural resources
• encourage the development of environmentally sustainable industries and jobs
• protect Queensland’s diverse plants and animals

PAGE contends that this development does not achieve any of the above priorities. In some senses it undermines them, as it facilitates the increased usage of Greenhouse Gas (GHG) intensive fuel sources for the supply of energy and precludes the development of environmentally sustainable industries and jobs in the renewable energy and energy efficiency areas of the economy. PAGE requests that the ToR address the issues raised under the SPP.

Climate Change and Future Electricity Demand

The development of the Powerlink proposal connecting the Sunshine Coast to the Central Queensland coal fired power stations is providing the ability, at a minimum, to increase electricity consumption by 5 times in the Sunshine Coast area. Powerlink’s own figures are for a 30 per cent increase in electricity demand over the next 7 years, and up to 100 per cent in the next 20 years. Using Powerlink’s own demand forecasts it is estimated that by 2020 they will be facilitating the increase in annual greenhouse gas emissions of over 400,000 t Co2-e in the Sunshine Coast area alone. An estimated 59% increase over today’s levels. Powerlink need to explain in detail how this proposed project advances Government priorities set out in the Queensland Government’s Climate Smart 2050 policy document consisting of:

• reducing our greenhouse gas emissions by investing in technological innovation in clean coal and renewable energy sources.
• supporting Queenslanders to lower their emissions and conserve water at home, at work and in their local communities.

Advancing Government priorities is a key objective of the SPP.

Given the urgent recommendation of the United Nations IPCC that nations must take immediate action to reduce the emission of greenhouse gases, it is irresponsible corporate behaviour to facilitate such an increase, rather than take an integrated least cost planning approach to the issue. That is, understand the demand drivers, assess the costs and benefits of managing demand and look at alternative solutions to the energy supply - demand issue, rather than assume that the current methods of power generation and distribution will be environmentally and economically sustainable in the short to medium term.

The demand forecast information issued by Powerlink can be summarised as follows:

• In this period [last 40 years] electricity demand in the region has grown by around 500 per cent.
• …forecasts indicate electricity demand will grow by about 30 per cent over the next 7 years, and by as much as 100 percent in the next 20 years.
• Queensland Government forecasts indicate the population of the whole area is expected to grow by 1.8 per cent per annum over the next 10 years.
• The average household today consumes 70 per cent more electricity than a mere 10 years ago!
• Demand for electricity… is increasing at 4% pa and is expected to do so into the future.

The implications in these statements are that demand will continue to grow in the same way that it has in the past. The solutions of the past were to simply increase the supply to meet the ever increasing demand. The 21st century demands a change in approach. A more prudent approach to spending tax payer funds (and therefore meeting Powerlink’s requirement to provide the least cost option) is to assess what is the lowest cost set of actions that can be undertaken to meet forecast demand, given the anticipated external factors affecting the market. These factors include global policy drivers (e.g. Kyoto and post Kyoto negotiations), likely national policy (e.g. MRET of 20% by 2020, Emissions Trading Scheme and caps), State and Local Government Policies. PAGE request that the ToR require the provision of the analysis that proves that the “solution” is least cost option available.

It is unclear from the information provided to date why the “solution” is required within the study corridor selected. The SEQ Regional Plan and discussions that PAGE have undertaken with representatives of both Noosa and Maroochy Councils reveal that the main area of expected population growth and development is the area directly to the North of the region covered by the SEQ regional plan e.g. Gympie and Cooloola area. Population growth within the area defined within the plan being well below the population growth figures issued by Powerlink. It appears that the estimated demand is not supported by the approved SEQ Regional Plan and requires significant detailed analysis to be provided to the community to accurately substantiate the demand forecasts noted by Powerlink.

From the very limited information made available to the community, it is clear that the demand forecasts do not take into account the more recent policy changes impacting the electricity market, with very low weighting of probability (12.76%) being ascribed to the impacts of Greenhouse policy options and their effect on demand (or supply). Powerlink has ascribed no or very little weight to demand side initiatives or to the expected growth in embedded generation in the forecasts it has relied upon.

The result of this process is a proposed solution that makes a significant and highly risky assumption that demand driven capital expenditure is required over a 50 year time horizon. This is the business as usual philosophy that has served the industry well in the past. This is not a sustainable model for the future and therefore PAGE contends that the demand projections upon which the project is based are flawed and need to be revisited and recalculated based upon the current and projected circumstances.

Specific Comments

Details of these comments are in the pdf that can be downloaded here. We will endeavour to get the whole of the submission document online but in the meantime there is the pdf document and we trust this has provided you with more understanding of the project and our concerns.