Feedback on the Advisory Notes to complement the Handbook for the development of renewable energy in Victoria

The Clean Energy Council (CEC) welcomes the opportunity to provide a submission to the Department of Energy, Environment and Climate Action (DEECA) on the following: 

• Onshore Renewable Energy Development in Victoria: Guidance for proponents on engaging with DEECA to seek pre-application advice (Pre-Application Advice Note) 
• Consultation Draft Advisory Note 1: Unmapped Brolga flocking areas (Brolga Note); 
• Consultation Draft Advisory Note 2: Unknown Bent-wing Bat roosting sites (Bent-wing Bat Note); 
• Consultation Draft Advisory Note 3: Demonstrating the application of a risk-based approach for onshore renewable energy (Risk Framework Note); 
• Consultation Draft Advisory Note 4: Monitoring, reporting and adaptive management (Monitoring, Reporting and Adaptive Management Note); •Consultation Draft Advisory Note 5: Developing compensatory measures (Compensatory Measures Note); and 
• Consultation Draft Advisory Note 6: Community engagement and biodiversity values (CE Note).

Together, the Advisory Notes. These Advisory Notes complement the Handbook for the development of renewable energy in Victoria: Guidance to avoid, minimise, mitigate and compensate for impacts on threatened bird and bat species (the Handbook). 

We commend DEECA on the work that has gone into preparing the Advisory Notes and appreciate that comments from industry consultation and preliminary feedback have been thoughtfully considered. The CEC supports the intent of the Advisory Notes and welcomes DEECA’s efforts to provide clearer guidance for proponents. 

Our recommendations focus on: clearer and more proportionate survey expectations, stronger recognition of project-specific evidence, and practical guidance on implementation matters such as compensatory measures, adaptive management and trigger-based conditions. 

The CEC also supports DEECA’s intention to update these Advisory Notes to ensure consistency with: 

• the draft catalogue of measures to avoid and mitigate collisions of birds and bats with wind farms (Catalogue of Measures); 
• the draft Australian Collision Risk Framework (ACRF); and 
• the reforms being undertaken by the federal Department of Climate Change, Energy, the Environment and Water (DCCEEW) to the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act).