Victorian Transmission Plan and Guidelines: impact on dairy farms 

Joseph and Anna Conheady’s submission to the Government’s (Stage 1) Renewable Energy public submission process.

Some background info:

In order to grow their dairy farming enterprise Joseph and Anna need worker accommodation.

But the Victorian Labor Government and the Wind Industry have ganged up on all Victorian Farmers to stifle the expansion of farms.

In 2021, the Vic Govt introduced a planning provision (Victoria Planning Provisions 35.07-6 Decision guidelines (13/10/2021 VC212)) to prevent farmers from building worker accommodation within 1km of the boundary of the wind farm.

The Planning Provision gives wind farms standing to object to any development within 1km of the boundary of their wind farm.

The cost of fighting the wind farm at the Victorian Civil and Administrative Tribunal (VCAT) is enormous, so much so that another local farming family gave up the fight, and instead of developing a prime acreage, with manager and manager’s accommodation, they did not defend their planning approval at VCAT and relegated this farm to the status of an out paddock.

Their long-time neighbours, now Hosts, are also party to the destruction of this prime dairy farming community.

As you read their submission, you will understand the gravity of the impact this useless wind farm and other useless wind farms will have on the Garvoc and the wider farming community.

(((( o ))))

24 August 2024

VicGrid

To whom it may concern

The Victorian Transmission Plan and Guidelines

The Draft Victorian Transmission Plan Guidelines aim to identify Victoria’s renewable energy zones (REZs), being the most suitable locations to host generation and transmission from an economic or ‘least cost’ point of view.

Final decisions are to be informed by:

• datasets including renewables/agriculture compatibility; and

• local and regional information and feedback.

Objectives of the Victorian Transmission Plan include the delivery of transmission services consistent with a least-regrets development pathway.

Vic Grid’s Commitment

Vic Grid is committed to incorporating industry and community views in its approach in order to make decisions that minimise negative impacts.

Our Key Message

The Draft Victorian Transmission Plan Guidelines appear to designate the strategic South West Victorian Dairy Farming Zone primarily as tier 1 and tier 2, without considering the significant, and long term cost to the core primary industry of the region, natural resource management and sustainability, key worker housing, economic development and employment, and land use compatibility.

Our primary concern is that the guidelines be updated to ensure that decision makers appreciate the value of South West Victoria’s Strategic Dairy Farming Zone, including its ability to produce and manufacture carbon efficient food locally, and be held accountable for the associated risks of prioritising renewable energy over the dairy industry in this unique zone.

Importance of Protecting South West Victoria’s Strategic Dairy Farming Zone

High-output agricultural regions like South West Victoria’s dairy zone are vital for Australia’s future food security and sustainability. To foster investment and enhance the efficiency of our supply and processing industries, it’s crucial to protect these prime agricultural areas.

Dairy production relies on specific areas, whereas renewable energy can be deployed across broader, less critical lands. Therefore, it makes sense to prioritise agriculture in these essential zones and avoid placing renewable energy projects there due to their significant land use impact.

The South West Victorian dairy region around Warrnambool regularly produces around 25% of Australia’s milk, benefiting from premium quality soil and high rainfall. Key points about this region include:

• Economic Impact: The dairy industry of Western Victoria generates approximately $4.5 billion of economic activity annually (direct and flow on) to the local economy and $2.2 billion to the Gross Regional Product (GRP). The majority of this is derived from the southern Corangamite and Southern Moyne dairylands centred around Warrnambool.

• Farms and Output: Approximately 1,000 dairy farms operate here, therefore generating on average $4.5 million per farm in economic activity annually. The average herd size is around 300 cows.

• Local Processing: Dairy grown from this region is also processed and manufactured locally, supporting a specialised trade and service industry that has developed over generations. To ensure the sustainability of this vital supply chain, the Government must prioritise the dairy industry in this unique zone. Protection from disruptive impacts of incompatible encroaching industries including renewable energy projects should be a key part of national climate strategy, in order to incentivise private investment in local dairy.

With stricter environmental regulations in dairy on the horizon, we must ensure that our most naturally conducive growing zones are reserved for growing food.

Impact of Wind Farms on Key Worker Housing

The Victorian Planning Framework supports building worker housing on farms to boost land sustainability and productivity. Under current rules, such housing can be built without a planning permit if certain conditions are met.

However, if a wind energy facility exists or is proposed within 1 km of the farm, the exemption for worker housing no longer applies. Farmers must then apply for a planning permit, and wind farm developers can object to the key worker housing plans. This is the case even if the wind farm’s approval is uncertain or if changes occur in the wind farm’s design, size or location.

Our Story

The direct impact of the Proposed Swanson’s Lane Wind Farm on our dairy farm

In February 2022, we hired a local builder to construct worker accommodation for our dairy farm. Since the accommodation met the Farming Zone’s permit exemption requirements, we did not need to apply for a planning permit. Construction occurred offsite to be trucked in once complete.

However, in May 2023, we learned about the planning application for the Swansons Lane Wind Farm in Garvoc, which affected our exemption rights. The usual protocols of community consultation were ignored by the proponents, blindsiding the community.

As a result, we were required to submit a planning permit application to Moyne Council, since most of our 680-acre farm, including all suitable locations for the worker accommodation, is within 1 km of the Proposed Swanson’s Lane Wind Farm boundary (which follows the roadside).

By November 2023, the accommodation was completed and fully paid for. After we agreed to a new location of the accommodation to mitigate impacts both from and to the proposed windfarm, Moyne Shire Council decided to approve our permit in mid-2024. Despite our compromise, the wind farm proponent is currently challenging this decision at VCAT. They have also previously challenged a similar planning application for worker housing near their proposed Mumblin Wind Farm in South Ecklin, another key dairy area. In this case the owner decided to sell the land before a decision was made.

Wind farms and dairy farms have conflicting requirements, highlighting a broader issue. In an industry that relies on worker housing to attract and retain staff, prioritising renewable energy projects over agricultural needs undermines the strategic value of agriculture for future carbon efficiency and food security.

Broader impact of the Proposed Swanston’s Lane Wind Farm on Garvoc

• 13 unrelated neighboring farming businesses adjacent to the Proposed Swanson’s Lane Wind Farm;

• 2 farms currently in tree plantation; and

• 2 additional farms owned by project hosts but not included in the project.

This map demonstrates the unacceptable impact of an application for a relatively small-scale wind farm of 6 turbines on prime agricultural land. The effects are especially severe on highly productive dairy regions, where farms are small, output is high, labour is critical and ongoing infrastructure and upgrades are vital for maintaining climate and cost efficiencies.

This contrasts sharply with larger scale, broadacre and lower input farming systems in other vast areas of Victoria and Australia, which may be more compatible with renewables and a least-regrets development pathway.

Current Land Use Conflicts

There is clear evidence of land use conflicts between wind farms and food production in intensive agricultural areas. Effective planning and zoning are crucial to prioritise and incentivise investment in key industries, ensuring that agriculture remains secure and attractive to investors.

Dairy farming, in particular, faces urgent challenges. With a 19% decline in local dairy farms and a 37% reduction in dairy jobs between 2017 and 2022, the industry struggles with labour and housing shortages. The government has responded with measures like streamlined visa programs (e.g., DAMA) and key worker housing permit exemptions to support the dairy sector.

However, wind energy projects, best suited to sparsely populated areas, exacerbate these issues. Their expansion into dairy zones introduces uncertainty and deters investment in regions best suited for climate-efficient food production.

Future Land Use Conflict

Given that wind farms have a projected lifespan of at least three decades, the current housing conflict is indicative of broader land use issues that will arise as technology, infrastructure, and standards for food production evolve.

Placing wind farms in key food-producing zones, with high population density, is problematic. This move grants the renewable energy sector significant influence in these areas for the next thirty years, potentially obstructing crucial agricultural developments needed for business growth, key worker recruitment, and the production of cost- and climate-efficient food.

Wind farm proponents could strategically challenge any developments aimed at expanding dairy operations or attracting staff, thereby exacerbating Australia’s reliance on imported dairy. This outcome contradicts Australia’s climate and food security goals.

Compounding Impact

If South West Victoria’s Strategic Dairy Farming Zone is zoned as a REZ, the compounding cost to the dairy industry, and the State, is likely to be significant.

Substantial investment and infrastructure is required to expand or run high output, carbon efficient dairy farming businesses with improving standards of animal welfare. Failing to prioritise agricultural businesses in this unique zone signals to investors that this is an insecure environment for landowners to make those investments on their own farms, let alone for corporate investment, or farmers from less productive areas to consider a move to this more conducive growing zone.

Furthermore, our current aging landholders may be offered incentive to install turbines across their lands and run a lower-productivity farming system such as beef or sheep grazing, rather than having pressure to either partner with the next generation of dairy farmers, or sell to a younger or stronger business in order to exit.

Additionally, neighbouring farms such as ours facing challenges with housing for staff may reduce their herd numbers and productivity, and install turbines themselves to make up for the lost income. This could severely disrupt the local dairy supply chain, affecting dairy processors and supporting industries. While this may tick a box for renewable energy generation, at the same time it signifies a decommissioning of our highest productivity lands from their highest output potential, disregarding responsibilities of natural resource management, carbon efficient food production and food security.

In summary, prioritising renewable energy in this key dairy zone risks a significant collapse in local dairy production and damage to the entire supply chain.

Contradiction To Climate Goals

The term ‘net zero’ should encompass all the needs of our wider society, not just energy generation.

The most productive lands in high rainfall zones are also the most climate-efficient for growing food. These require less chemicals, fertilisers, power, diesel and irrigation to grow the same unit of food grown elsewhere. Prioritising renewable energy projects above agricultural businesses in these prime agricultural zones threatens Victoria’s ability to produce food most efficiently and direct agricultural investment to the most productive areas.

An ING report highlights that, unlike the EU or New Zealand, Australia has yet to impose significant environmental regulations on its agricultural sector. Despite this, we have a notable natural advantage in producing carbon-efficient milk.

Given that food production has significant environmental impact, why are we not more seriously considering the needs of our local agricultural sector in the renewable energy rollout? Supporting agriculture is crucial to achieving our net-zero climate goals, and would be central to a sensible, holistic approach to net zero targets.

Note: Food mileage will be in addition to these figures.

Certain essential dietary needs, like dairy, are best sourced from specific regions in Australia known for their efficiency. In contrast, renewable energy can be generated across vast areas of the continent, including many lower-input farming districts that can coexist with renewables and benefit from supplementary income.

When evaluating REZs, the negative economic and climate impacts on the dairy industry should be thoroughly quantified and weighed against the benefits of proposed renewable energy projects.

Final Message

We want to make it clear that our stance is not against renewable energy but emphasises the critical need to assess priorities in strategic food production zones. Just as we value reliable and carbon-efficient electricity, we must also recognise the importance of maintaining a reliable, cost-efficient, and carbon-efficient food supply, as well as economic prosperity.

Protecting prime agricultural regions is essential for ensuring that we can meet these needs effectively. We urge that food security be given equal consideration in renewables planning and decision-making processes.

We welcome the opportunity to discuss this submission further.

Sincerely,

Joseph and Anna Conheady

Joseph and Anna Conheady’s submission to the Government’s (Stage 1) Renewable Energy public submission process