The EES requires proportionate and robust investigation of alternate feasible options

Proportionate Investigations or Risk Failure of the EES Process

Is there a genuine risk that the EES process won't be in AusNets favour?

The Environmental Effects Statement (EES) process is the most rigorous environmental impact assessment process in Victoria. The purpose of the EES is to ensure that major projects are designed, constructed, and operated to avoid, minimise (if avoidance is not possible) or manage adverse impacts on environment and community, in that specific order.

To fulfil the requirements of the EES, rigorous and transparent investigation of potential environmental impacts is essential. The EES should proportionately document the likely environmental effects of feasible alternatives, particularly where these offer a potential to avoid or minimise adverse environmental effects whilst meeting the objectives of the project.

So, what are feasible alternatives?

Route selection should try to avoid, minimise, or offset impacts on important environmental, social, cultural, landscape values and strategic land use conflict by utilising existing rights-of-way as a priority. Replacing overhead HVAC with HVDC on existing infrastructure and deployment of underground HVDC technology should also be considered as a preferred transmission option to avoid community and environmental impacts.

This is the way transmission should be built — in an environmentally responsible manner that respects landowner rights and can be replicated across the country to building the grid of the future.

1. Leveraging Existing Right-of-Way Corridors

Today, electricity networks are rapidly changing, both on the generation and demand side. The future sees a highly variable generation mix of large power sources, including renewables, plus considerable input from distributed energy sources such as consumer solar power, together with a less predictable demand.

The need for a reliable, resilient, secure, robust and efficient transmission network will be required to transfer energy generated in often remote renewable energy zones to the countries power grid. A well-conceived plan for the future is crucial. Rather than construct transmission infrastructure the same way we did decades ago, we must figure out how we can use land more efficiently, and whether that’s transportation right of ways or existing transmission right of ways that could have more throughput, we need to open up these opportunities and take progressive approaches to how we undertake transmission planning.

According to chief executive of Citipower and Powercor, Tim Rourke “we need to carefully balance that by making sure we’re maximising the infrastructure we’ve got in place from a cost perspective for customers, because once you build that, it’s there for a long time”. “So, while there will be a need for new transmission lines, we need to build the bare minimum, augment the existing assets as well as squeeze the last bit of capacity out them. Not only does this keep costs down, but it speeds up the time for renewable connections.”

2. Converting existing transmission infrastructure to HVDC

A sustainable electricity grid will likely need to move large amounts of low-carbon bulk power as part of a strategy to reduce emissions. That will require expansion of transmission capacity, and changes in the topology of the system, even as the use of distributed generation increases. In many cases, maximizing the capacity of existing transmission corridors may best be done by conversion to high-voltage direct current (HVDC). While typically not included in planning tools, such conversion is surprisingly cost-effective, even over relatively short distances, and, in some cases, may be the only way to achieve dramatic increases in the capacity of existing corridors.

HVDC transmission systems offer feasible solutions to the existing right-of-way challenges. One HVDC transmission system deployed overhead can prove to be more reliable than a double circuit AC transmission line. An HVDC infrastructure can improve the electricity transient efficiency by using insulated HVDC cables in underground and subsea applications, which can accelerate the right-of-way permitting processes. Moreover, HVDC transmission systems can also be installed adjacent to or on the existing AC lines, reducing the needs for right-of-way land use.

Converting existing transmission infrastructure to HVDC is an overlooked option for increasing transmission capacity.

3. HVDC transmission

HVDC transmission systems are emerging as the bedrock upon which the new energy system based on renewable sources is being developed and implemented. Renewable energy systems, such as solar and wind power projects, are often highly volatile and located in remote areas. The ever-evolving HVDC technology is gaining ground in the new energy economy with long-haul HVDC transmission lines that can transport power with maximum efficiency and power minimal losses.

The needs for building new power stations can be deferred with the deployment of HVDC transmission systems, as it interconnects different power systems to operate more efficiently. The new power system can attain greater economic and environmental gains coming from large hydroelectric resources, which replace thermal generation systems in traditional power systems through HVDC transmission lines.

HVDC transmission has become power superhighway for large-scale integration of renewable power resources to offer interconnected grids, which are reliable and flexible enough to address the challenges of the new renewable energy economy. HVDC transmission grids enable load balancing between HVDC power superhighways and sharing of lines and converter stations in solar projects and offshore wind power stations. Thereby, deployment of HVDC transmission systems is considered as an economically viable way of providing redundancy and reliability in such power networks.

Some benefits of a HVDC system are:

  • Only two conductors are required to transmit HVDC, whereas AC systems require three (to support three transmission phases), which saves cost and potentially land
  • HVDC energy transmission losses may be lower than 3% per 1,000 km, which is 30% – 40% lower than losses for HVAC at an equivalent voltage, for several reasons
  • AC suffers from a skin effect whereby only the outer part of the cable conducts current, which is avoided in DC transmission – the result is that for a given conductor size and energy losses, HVDC systems can transmit higher current over longer distances
  • HVDC lines operate continuously at peak voltage (which is determined by the design of the transmission line insulators and towers, among other things), whereas HVAC is sinusoidal – and while the crests of the sine wave are naturally at peak voltage, the effective average voltage (and corresponding current) are the root mean square value (RMS), which is only 0.7 times the peak voltage; the net effect is to increase the power transmission capacity of an HVDC system relative to HVAC;
  • DC carries only active power, whereas AC transfers both active and reactive power
  • HVDC interconnections are asynchronous, enabling interconnection of unsynchronised power sources, such as two grids operating at different frequencies, phases, or voltages: and
  • HVDC is the only feasible option for undersea cables.

HVDC Alternative Scoping Report - Moorabool Shire Council

In June 2021, the Moorabool Shire Council commissioned an independent ‘High-Level HVDC Alternative Scoping Report1’. This report presented a feasible alternative that offers significant potential for superior environmental outcomes. The HVDC underground option showed the least adverse impact against all other options based on the assessment criteria, while the AC overhead transmission line has the highest adverse impact in total.

SOO Green HVDC Link

One project that is setting the new benchmark for renewable energy transmission is the is the SOO Green HVDC Link. SOO Green is the first transmission project in the US, that is going to be co-located underground along railroads and highways for its entire 350-mile route. the project consists of two slender HVDC cables that are buried in existing rights-of-way. Each cable is no greater in diameter than a wine bottle. It’s out of sight and out of mind. Underground construction avoids landowner opposition, and it expedites the planning and approvals process because there are no land use, socioeconomic or environmental conflicts. What that means is it can be built fast. Co-location in existing corridors provide the advantage of speed in development, and speed is key, because as we know, everything in the climate and energy world is rapidly evolving and renewable generator investors are ready to get started. The weather is changing, technology is changing, and our future grid is changing.

This is the way transmission should be built — in an environmentally responsible manner that respects landowner rights and can be replicated across the country to building the grid of the future.

Proportionate Investigations of Feasible Alternatives

As mentioned in the opening, the EES should proportionately document the likely environmental effects of feasible alternatives, particularly where these offer a potential to avoid or minimise adverse environmental effects whilst meeting the objectives of the project. If all potential corridors or feasible alternatives are not rigorously and proportionally investigated, Energy Grid Alliance is concerned the WVTNP risks failure of the EES process.

In a recent story by ABC News in relation to compensation plans for landowners, AusNet insists it's not a 'done deal' – encouraging landholders to continue discussions with the company. Speaking to Nicole Chvastek on ABC Victoria's Statewide Drive Program, executive project director Stephanie McGregor said technical surveys would continue as AusNet prepares the EES.

"There is a genuine risk in that process that it won't be in our favour," Ms McGregor said.

"We're required to look at both overhead and underground as part of the EES process the compensation process itself is agnostic of the actual physical solution," she said.

How proportionate have the investigations been?

It is encouraging to hear that undergrounding will in fact being investigated as to date, there does not appear to be any evidence to indicate that investigation of alternatives, whether underground HVDC or alternate corridors, has been rigorous or proportionate. As accurate information can only be obtained through detailed field studies, Energy Grid Alliance sought clarification from AusNet Services as to why further detailed assessments were not conducted on the proposed southern corridor, existing easements or an underground HVDC alternative, using existing rights-of-way. There has been no response to this request to date.

Following review of the WVTNP single corridor selection presentation, webinar series and on-on-one discussions it has become apparent that the level of technical investigation conducted by associated specialists on alternate corridors and technical options, such as undergrounding HVDC has not been proportionate.

The following table illustrates an understanding of the level of investigation that was conducted by Tetra Tech Coffey2 on potential corridors within the broader area of interest. The purpose of these desktop investigations was to identify a preferred final corridor.

TABLE 1

Evaluation Northern Corridor Southern Corridor Underground HVDC
Cultural heritage Desktop analysis Desktop analysis Dismissed
Biodiversity Desktop analysis Desktop analysis Dismissed
Landscape and visual Desktop analysis Desktop analysis Dismissed
Planning and land use Desktop analysis Desktop analysis Dismissed
Agriculture Desktop analysis Desktop analysis Dismissed
Length Desktop analysis Desktop analysis Dismissed
Constructability Desktop analysis Desktop analysis Dismissed

There is no clear evidence to suggest that proportionate detailed assessment of feasible alternatives has been considered.

The following diagram summarises the outcomes of the investigations listed in Table 1. The key points raised in the presentation were:

  • Conflicting or competing land uses and controls are inevitable
  • No perfect route
  • All routes have ‘pinch points’ with high constraints
  • High constraints need to be managed

DIAGRAM 1

Single Corridor Selection

It is clear through this evaluation that both the northern and southern corridor options are highly constrained and offer no perfect route. It is important to note that while there is minimal difference in the overall assessment of constraints, the northern corridor was shortlisted as the least-worst solution (preferred corridor) to undergo further detailed investigation to establish a final transmission route.

It is important to note that during the one-on-one webinar discussions with technical specialists it was indicated that:

  • The work required to conduct detailed studies on alternate corridors was too great, so the focus has been on the preferred corridor only. (Energy Grid Alliance note that this approach cannot produce an effective and proportionate assessment of the least-impact solution as is required by the EES process. Not conducting rigorous and proportionate assessments because the volume of work is 'too great' will not produce a superior environmental outcome).
  • The reason technical field studies are required on the preferred corridor is that a lot of information is not documented, meaning constraints or impacts are not able to be accurately determined through desktop analysis alone and that [we] would be surprised at what has been found to date. (Energy Grid Alliance note that as accurate information can only be obtained through detailed field studies, excluding alternate feasible options from this assessment will not produce an effective and proportionate assessment of the least-impact solution).

According to the EES Scoping Requirements4, where a feasible option provides a distinct opportunity for superior environmental outcomes, this should be investigated and documented in the EES. Detailed assessment of particular alternatives is necessary where alternatives have the potential to deliver suitable social, environmental and economic outcomes.

The following table illustrates an understanding of the level of investigation, that has or is soon to be conducted along the final preferred corridor (least-worst option), compared to alternate corridors, existing easements and underground alternatives. This assessment criteria has been extracted from AusNet Services ‘Environmental and key project approvals’ fact sheet3.

TABLE 2

Evaluation Preferred Corridor Dismissed Corridors Underground HVDC
Agriculture and farming Field Studies No further studies Dismissed alternative
Air quality Field Studies No further studies Dismissed alternative
Aviation and aerial fire-fighting Field Studies No further studies Dismissed alternative
Biodiversity Field Studies No further studies Dismissed alternative
Bushfire risk Field Studies No further studies Dismissed alternative
Electronic interference Field Studies No further studies Dismissed alternative
Historic heritage Field Studies No further studies Dismissed alternative
Human health Field Studies No further studies Dismissed alternative
Landscape and visual Field Studies No further studies Dismissed alternative
Noise and vibration Field Studies No further studies Dismissed alternative
Project alternatives Field Studies No further studies Dismissed alternative
Socioeconomic Field Studies No further studies Dismissed alternative
Surface water and groundwater Field Studies No further studies Dismissed alternative
Traffic and transport Field Studies No further studies Dismissed alternative

Once again, there is no clear evidence to suggest that proportionate detailed assessment of feasible alternatives has been considered.

Requirements of the EES

The following information has been extracted from the EES Scoping Requirements (December 2020) for the purpose of understanding requirements for investigation and assessment of feasible alternatives including underground High Voltage Direct Current (HVDC) transmission as a project alternative.

The primary purpose of the EES process is avoiding environmental impact. Underground HVDC seems to be the technical solution of choice due to the decreased socioeconomic and environmental impact. If not proportionally investigated, AusNet Services should be required to apply the EES process again or risk failure of this process. To date, AusNet Services have not provided evidence that investigation of alternatives, whether underground HVDC or alternate corridors, has been proportionate.

1.2 Minister’s requirements for this EES

In the procedures and requirements, the Minister identified broad key matters and environmental risks that the EES should investigate and document:

  • alternative corridors, alignments, site locations, designs or other options for the planning, construction or operation of the project;

3.2 Content and style

The EES should provide a clear, objective and well-integrated analysis of the potential effects of the proposed project, including proposed avoidance, mitigation and management measures, as well as feasible alternatives. Overall, the main report should include:

  • responses to issues, including alternative options, raised through public and stakeholder consultation;

 3.4 Project alternatives

The EES should document the proponent's design development process leading to the proponent’s preferred form of the project as presented in the EES. The EES should explain the proponent’s criteria for evaluating the feasibility of potential alternatives and explain how specific alternatives were shortlisted or rejected for evaluation within the EES. The EES should document the likely environmental effects of feasible alternatives, particularly where these offer a potential to avoid or minimise adverse environmental effects whilst meeting the objectives of the project.

The referral of the project under the EE Act presented the project in terms of an area of interest rather than a proposed alignment. Alignment selection can be a very important way of avoiding or minimising adverse impacts for linear infrastructure projects. Key aspects of the project, for which the EES will need to demonstrate consideration of feasible alternatives, include:

  • the rationale for the preferred mode of construction (overhead or underground, including potential for partial underground construction); and
  • other feasible alternatives raised through feedback from the community or other stakeholders

The process for identification and analysis of the project alternatives will need to be documented in the EES including:

  • assessment and comparison of the technical feasibility and environmental implications of alternative options considered;

While the assessment of environmental effects of site selection, alignment and design alternatives must address the matters set out in these scoping requirements, the depth of investigation of alternatives should be proportionate to their potential both to minimise potentially significant adverse effects and to meet project objectives. References to “the project area of interest” are to be read as applying iteratively to potential corridors or alignments for the project as they emerge within the project area of interest.

What if a project alternative costs more?

It’s important to remember, with any large-scale linear infrastructure project, there will always be planning scheme, policy and framework conflict. One conflict worth noting is that the RIT-T is not allowed to consider socioeconomic or environmental disbenefits in net benefit calculations. The EES on the other hand is only concerned with superior environmental outcomes and does not consider project costs. Nowhere in any EES documents or Ministerial referrals are project costs mentioned as a factor to be considered.

So when alternatives are dismissed purely based on cost without proportionate investigation, this contravenes the purpose of the EES process.

Risk of genuine failure of the EES process

If feasible options, that deliver superior environmental outcomes, are not proportionately investigated, the proponent risks material project delays while these alternatives are investigated and documented. The alternate outcome is failure of the EES process.

The EES should investigate and document:

  • alternative corridors
  • alternative alignments
  • site locations
  • designs or other options for the planning, construction or operation of the project
  • alternative options, raised through public and stakeholder consultation
  • mode of construction (overhead or underground, including potential for partial underground construction)
  • re-stringing existing transmission infrastructure using HVDC
  • undergrounding HVDC

Energy Grid Alliance agree with Ms McGregor that there is a genuine risk in the EES process that it won't be in favour of AusNet Services.

These risks will continue to exist until proportionate investigations are carried out on alternative corridors, alignments, site locations, designs or other options for the planning, construction or operation of the project.

The option that delivers superior environmental outcomes is the only acceptable option.

REFERENCES

  1. WVNTP - High-Level HVDC Alternative Scoping Report https://www.moorabool.vic.gov.au/files/content/public/about-council/large-projects-impacting-moorabool/western-victoria-transmission-network-project/wvtnp-high-level-hvdc-alternative-scoping-report.pdf
  2. Tetra Tech Coffey - Single Corridor Selection Presentation, 13 July 2021 https://www.westvictnp.com.au/52677/widgets/339677/documents/212981
  3. Fact Sheet - Environmental and key project approvals https://www.westvictnp.com.au/62122/widgets/312640/documents/207514
  4. Scoping Requirements Western Victoria Transmission Network Project Environment Effects Statement https://www.planning.vic.gov.au/__data/assets/pdf_file/0020/506504/WVTNP-EES-Scoping-Requirements-final.pdf

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