Consolidated Executive Overview, Conclusion and Recommendations

This forensic evaluation of the Western Renewables Link (WRL) Environmental Effects Statement (EES) has identified profound and systemic failures across all key assessment areas, rendering the EES documentation, in its entirety, unfit for the purpose of statutory decision-making. The proponent, AusNet, has not conducted the robust, transparent, or integrated investigation required by the Environment Effects Act 1978 and the project-specific EES Scoping Requirements. The critical deficiencies are not isolated technical issues but are interconnected, foundational flaws that invalidate the proponent's conclusions and demonstrate a process that is non-compliant with its legal and ethical obligations.

The key cross-cutting issues identified across all evaluated EES chapters are:

• A Foundational Flaw in Project Development: The entire EES process is built upon a flawed premise. The project's fundamental nature—an overhead transmission line—was pre-determined by the Australian Energy Market Operator's (AEMO) narrow economic Regulatory Investment Test for Transmission (RIT-T) before the EES process commenced. This "funnel of foreclosure" systematically prevented a genuine and holistic assessment of all feasible alternatives, such as full or partial undergrounding, reducing the EES to a tactical routing exercise rather than a strategic environmental assessment.
• Systemic Deferral of Assessment: A consistent strategy of "approve now, assess later" is evident throughout the EES. Critical assessment tasks—including baseline ecological surveys, geotechnical investigations, Aboriginal cultural heritage fieldwork, contaminated land investigations, and detailed noise and vibration modelling—have been improperly deferred to post-approval management plans. This subverts the core purpose of the Environment Effects Act 1978, which is to enable a full assessment of effects before decisions are made.
• Fundamentally Flawed Methodologies: The technical assessments are underpinned by invalid and unreliable methodologies. This includes the complete omission of baseline vibration monitoring; the use of unrepresentative surrogate data for air quality; a subjective "landholder sentiment" metric based on the judgment of project staff; an agricultural impact assessment that fails to assess property-level economic viability; and an economic model populated with outdated and irrelevant data.
• Inadequate and Unenforceable Mitigation: The proposed Environmental Management Framework (EMF) and its Environmental Performance Requirements (EPRs) are rendered ineffective by the pervasive use of vague, discretionary, and non-committal language such as "so far as reasonably practicable," "where possible," and "non-mandatory goals". This framework provides an illusion of control but fails to establish the specific, measurable, and enforceable environmental outcomes required by the EES process.
• A Failed Consultation Process: Despite extensive activity, the stakeholder engagement process has fundamentally failed. It did not genuinely incorporate community feedback into strategic decisions, particularly the widespread calls for undergrounding. The process has demonstrably generated profound "community distrust," resulting in a complete breakdown of social license.
• Critical Gaps in Quality Assurance: In a significant failure of due process, the proponent has not provided evidence of independent peer review for numerous critical technical reports, including Geology and Soils, Groundwater, Social Impact, Contaminated Land, and Transport. This omission, in direct contravention of the Scoping Requirements' expectation for peer review of critical components, fatally undermines the credibility and objectivity of the assessments.

It must also be stated that the scale and opacity of the EES process have made it virtually impossible for any affected resident to conduct a full review. With close to 10,000 pages of documentation — much of it highly technical — there was no realistic way to verify, cross-check, or meaningfully interrogate the information within the limited exhibition period. Over the past four years, Energy Grid Alliance has repeatedly requested access to technical reports and study material that could have informed and improved this project. On every occasion, AusNet refused to provide it, stating that such information would only become available once the EES was published. This deliberate withholding of information, when there is no legal basis supporting this, has materially compromised both community input and public trust.

Conclusion

The WRL EES is a fundamentally non-compliant and procedurally invalid document. It does not meet the legislative standards for environmental assessment in Victoria. Its foundation is compromised by a pre-determined project form; its assessments are incomplete, inconsistent, and often speculative; its mitigation strategy is vague and unenforceable; and it fails to provide the Minister or the Inquiry & Advisory Committee with the information necessary to make a lawful, informed decision.

The proponent has not demonstrated that the project’s impacts can be acceptably avoided, minimised, or managed. Nor has it secured the trust of affected communities or adhered to the principles of transparency and public accountability.

Proceeding on the basis of this flawed EES would undermine the integrity of Victoria’s environmental governance framework and expose communities and landscapes to avoidable, long-term harm.

Recommendation to the Project Inquiry & Advisory Committee and the Minister for Planning

Given the pervasive and systemic deficiencies identified across the EES, it is recommended that the Project Inquiry & Advisory Committee (PIAC) and the Minister for Planning do not proceed to project determination based on the current material, and instead:

1. Find the EES Procedurally Inadequate and Incomplete: The EES should be formally found to be procedurally deficient and non-compliant with the Environment Effects Act 1978 and the 2023 EES Scoping Requirements. The Minister for Planning, upon receiving the IAC’s report, should require a substantial supplementary EES to be submitted to rectify these deficiencies before any decision can lawfully proceed.
2. Direct the Proponent to Undertake a New, Compliant, and Integrated Assessment: The proponent must be directed to prepare a new, compliant assessment to be submitted as a supplementary EES. This new assessment must rectify all identified deficiencies and, at a minimum, must:

• Conduct a New, Unconstrained Alternatives Assessment: The assessment must not be pre-constrained by the RIT-T process. It must include a genuine, transparent, and direct comparative evaluation of the environmental, social, and economic effects of a full overhead alignment versus a full (or partial) underground alignment.
• Complete All Baseline Investigations: The proponent must complete all necessary, targeted, and site-specific baseline investigations before submitting the supplementary EES. This includes comprehensive ecological surveys, geotechnical and groundwater field investigations, baseline vibration and air quality monitoring, and property-level agricultural assessments on ALL feasible alternatives.
• Utilise Robust and Transparent Methodologies: All impact assessments must be based on scientifically robust, fit-for-purpose methodologies that are consistent with established best practice and are free of the flaws identified in this evaluation.
• Formulate Enforceable Commitments: The revised Environmental Management Framework must contain specific, measurable, and auditable Environmental Performance Requirements that establish clear, non-discretionary environmental outcomes and are free of ambiguous loophole language.
• Mandate and Publish Independent Peer Review: All critical technical assessments must be subject to a rigorous and transparent independent peer review process, with the full, unredacted peer review reports and the proponent's detailed responses made publicly available as part of the supplementary EES submission.

Final Note

This submission does not oppose the need for transmission projects. Rather, it asserts that the current EES is not a fit-for-purpose assessment upon which statutory approvals can be based.

To approve the Western Renewables Link based on the current EES would be to endorse non-compliance, enable regulatory evasion, and betray the public trust. It would establish a dangerous precedent—one that privileges administrative convenience over rigorous assessment, and private interest over public accountability.

A requirement for a substantially revised and independently verified supplementary EES is the only lawful, ethical, and defensible path forward.

This is the full submission to the Western Renewables Link EES made by Energy Grid Alliance. It will be publicly available on the Engage Victoria website once submissions are formally published by Planning Panels Victoria, but we are sharing it here now in the interest of transparency and informed public discourse.