The Clean Energy Council has provided a submission to the Department of Climate Change, Energy, the Environment and Water (DCCEEW) on the draft catalogue of measures to avoid and mitigate collisions of birds and bats with wind farms (Catalogue of Measures).
Our comments focus on ensuring there is clarity regarding how the Catalogue of Measures will be integrated into the EPBC Act approval process, to avoid a scenario where proponents are expected to adopt all available mitigation measures rather than applying them proportionately based on project-specific risks. The introduction of a risk-based decision matrix, and the development of model conditions would support consistent and transparent approvals. In addition to the interaction with the EPBC approval process, the Catalogue of Measures should clarify the interaction with the Australian Collision Risk Framework (ACRF).
More broadly, the Catalogue of Measures would benefit from clearer direction on the appropriate use and commercial implications of curtailment; greater recognition of data limitations and cumulative impacts; improved alignment with regulatory, safety and planning constraints; and greater incorporation of emerging technologies.
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