In the matter of the Dundonnell Wind Farm EES Planning Panels Victoria Proponent: Trustpower Australia Holdings Pty Ltd

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1 Page 1 In the matter of the Dundonnell Wind Farm EES Planning Panels Victoria Proponent: Trustpower Australia Holdings Pty Ltd Expert Witness Statement of Christophe Frederic Delaire Expert of Trustpower Australia Holdings Pty Ltd

2 1 Name and address CHRISTOPHE FREDERIC DELAIRE Associate Marshall Day Acoustics Pty Ltd 6 Gipps Street, Collingwood. Victoria 3066 Dundonnell Wind Farm Environmental Effects Statement Page 2 2 Area of expertise For over 13 years I have worked in the field of acoustics and noise control. I have a special interest in environmental noise and gained extensive experience in the noise assessment of wind farms since 2005 My qualifications and experience are detailed in Annexure A. I am sufficiently expert to make this statement because I have been involved in environmental noise impact assessments for major environmental projects such as power stations, wind farms and other industrial plants. My experience extends to all aspects of wind farm noise, including predictions, background noise monitoring and post-construction noise monitoring. This is demonstrated by my involvement in over fifty (50) projects across Australia, providing expert witness evidence for ten (10) Victorian wind farms and multiple papers presented at international conferences. 3 Scope 3.1 Instructions Marshall Day Acoustics Pty Ltd (MDA) was commissioned by Trustpower Australia Holdings Pty Ltd (Trustpower) to assess noise impacts associated with the proposed Dundonnell Wind Farm and associated transmission line and substations. The scope of the commission was to provide construction and operational noise information in response to the Environment Effects Statement (ESS) scoping requirements. The assessment of the proposal was presented in the MDA report Rp001 R ML Dundonnell Wind Farm - EES Noise Impact Assessment, dated 2 September 2014 (the MDA EES Report). I have been instructed by Herbert Smith Freehills (HSF) on behalf of Trustpower to prepare this witness statement and give expert evidence to the panel inquiry. The MDA EES Report was exhibited as Annex O of the Dundonnell Wind Farm EES dated April 2015 and I adopt it as the basis for my expert witness statement and evidence. Since the issue of the MDA EES Report, I have been instructed to consider an alternative ninety-six (96) turbine layout comprising of the removal of eight (8) turbines and the relocation of eight (8) turbines. The alternative layout is provided in Annexure B. This statement provides a summary of the MDA EES Report, noise predictions for the alternative turbine layout and a response to key submissions raising issues relating to noise. 3.2 Reports reviewed to prepare initial study or statement The documents I have reviewed and referenced in the MDA EES Report and this statement are listed in Annexure C.

3 3.3 Persons assisting with this work Dundonnell Wind Farm Environmental Effects Statement Page 3 My colleague Justin Adcock has assisted with the review of calculations, noise monitoring results, the MDA EES Report and this statement of evidence. Justin is an associate at MDA and holds a Bachelor of Mechanical Engineering from the University of Adelaide. He has worked in environmental assessment for over seventeen (17) years, including wind farm noise assessments since 2004 in the UK, France, Ireland and Australia. 3.4 ESS scoping requirements In January 2013, the Victorian Minister for Planning determined that an EES for the proposed Dundonnell Wind Farm would be required under the Environment Effects Act In September 2013, the Department of Transport, Planning and Local Infrastructure (DTPLI) specified the potential environmental impact to be investigated as part of the EES in a document titled Dundonnell Wind Farm Project Environment Effects Statement - Scoping Requirements (the Scoping Requirements). Section 4.5 Amenity of the Scoping Requirements states the following evaluation objective: To avoid or minimise adverse noise, visual and other amenity effects on nearby residents and local communities, to the extent practicable. The noise related items detailed in the Scoping Requirements are reproduced in Annexure D. 4 Summary of MDA EES Report 4.1 Operational noise Assessed receivers In accordance with the applicable policies and standards, the assessed receivers comprise sensitive locations that exist before the development of a wind farm. Noise sensitive receiver locations include residential dwellings, temporary accommodation and educational facilities. Residential dwellings are separately considered according to whether or not they are participating in the development of the proposed wind farm, by way of land ownership or formal agreement with the developer. Trustpower has identified nine (9) residential properties within 2km of the proposed turbines comprising of five (5) participating landholders and four (4) participating neighbours. Another eighteen (18) residential properties were identified between 2km and 5km of the proposed wind turbines, including one (1) participating landholder and one (1) participating neighbour Operational wind farm noise criteria The assessment of operational noise from the proposed Dundonnell Wind Farm was carried out in accordance with the New Zealand Standard 6808:2010 Acoustics Wind farm noise (NZS 6808:2010) as required by the Victorian Government's Policy and planning guidelines for development of wind energy facilities in Victoria dated July 2012 (the Victorian Guidelines). NZS 6808:2010 is also listed as a relevant document in the Scoping Requirements Operational substation noise criteria Noise from the substation associated with the proposed wind farm was assessed in accordance with the Victorian EPA publication 1411 titled Noise from Industry in Regional Victoria Recommended maximum noise levels from commerce, industry and trace premises in regional Victoria (NIRV).

4 4.1.4 Operational wind farm noise limits Dundonnell Wind Farm Environmental Effects Statement In accordance with NZS 6808:2010, the operational noise from turbines at noise sensitive locations should not exceed 40dB L A90 or the background noise (L A90 ) by more than 5dB, whichever is the greater. Review of land zoning surrounding the proposed site indicated that alternative noise limits intended for high amenity zones, detailed in Section 5.3 of NZS 6808:2010, are not applicable. Page 4 As required by the Victorian Guidelines, separate noise limits have been derived for the 24 hour and night-time periods based on background noise levels measured at six (6) properties between 25 January and 27 February 2013 correlated with wind speeds extrapolated at hub height. At all but one (1) monitored properties, the NZS 6808:2010 base noise level is the controlling noise limit at all wind speeds due to low background noise levels during the night-time period. In addition to general agreements established with participating landholders and neighbours, agreements concerning noise have been signed with six (6) properties. The definition given in NZS 6808:2010 of noise sensitive locations specifically excludes dwellings within the wind farm site boundary. For these properties, it is typical practice to use the recommendations outlined in the final report by The European Working Group on Noise from Wind Turbines (ETSU-R-97) which allows for an increased baseline noise limit of 45dB L A90 in lieu of the 40dB L A90 minimum noise limit. As an indication of the use of this document in Australia, the South Australian EPA s guidelines specifically refer to ETSU-R-97 as a suitable approach to address noise at properties where a noise agreement has been reached. This approach has also been applied to past Victorian wind farm proposals. Accordingly, at the six (6) properties where a noise agreement has been signed, the base noise limit has been increased (with the neighbours consent) to 45dB L A90 based on ETSU-R-97. The noise limits detailed in Table 1 for each of the residential properties within 2km of the wind farm apply to all wind speeds and are not dependent on background noise results. Table 1: Applicable noise limit, L A90 db House Distance to nearest turbine (m) MDA EES Report Alternative layout 1 (PN) (PL) (PL) 1,214 1, (PN) 1,780 1, (PN) 1,003 1, (PL) 1,011 1, (PL) 1,132 1, (PL) 1,727 1, (PN) 1,887 1, (PL) Participating Landholder (PN) Participating Neighbour Applicable noise limit, db At other noise sensitive locations beyond 2km from the location of a proposed turbine, the base noise limit of 40dB L A90 applies Operational substation noise limits Noise from ancillary equipment, such as the substation, should comply with the night-time NIRV noise limit of 34dB L eff at all nearest affected residential properties.

5 4.1.6 Assessment of operational wind farm noise Dundonnell Wind Farm Environmental Effects Statement Page 5 The noise emissions of the proposed turbines have been represented using sound power level data for Vestas V117 candidate turbine. The specific make and model of turbine to be used at the site will not be determined until much later in the project. A candidate turbine was therefore used as a means of representing the emissions for the types of turbines which may be considered for the site. The sound power level data was sourced from the Vestas document No V00 titled V MW-IEC2A Third Octaves according to General Specification and dated 7 June At the time of preparing the MDA EES Report and this witness statement, octave band levels were not available for the Vestas V117 turbine and therefore, the spectral values presented in the Vestas document were estimated based on measured sound power levels for a similar turbine (Vestas V112-3MW). Furthermore, tonal audibility ( L a,k ) levels determined in accordance with IEC were not provided in the technical information provided by Vestas for the Vestas V117 and therefore, for the purposes of this assessment, it was assumed that the considered turbine model will have similar tonal audibility levels ( L a,k ) as the Vestas V112-3MW. Tonality is not a common feature of modern variable speed turbine of this class, as evidenced by the tonal audibility levels reported below -1dB for the Vestas V112-3MW, and therefore no penalty for special audible characteristics was added to the predicted noise levels. The available data for the candidate turbine is considered to be consistent with the typical values achieved by modern pitch regulated variable speed turbines of comparable size and power rating. This data is therefore considered suitable for the purpose of assessing the viability of the proposed wind farm layout in accordance with the Victorian Guidelines. Prior to the selection of a final turbine model for the site, revised noise predictions should (in line with usual practice) be carried out to demonstrate compliance with NZS 6808:2010 on the basis of actual test data. The sound power level data for the Vestas 117 provided the basis for calculating operational noise levels at distant receiver locations using the prediction methodology detailed in ISO :1996 Acoustics Attenuation of sound during propagation outdoors Part 2: General method of calculation (ISO :1996). Section of NZS 6808:2010 states that predicted time-average (L eq ) wind farm sound levels occurring at receiver locations shall be taken as the predicted L 90 wind farm sound level. Therefore predicted wind farm noise levels throughout the MDA EES Report and my statement have been reported as L A90. The highest noise levels predicted at each of the nine (9) assessed residential properties are provided in Table 2 for the one hundred and four (104) turbine layout detailed in the MDA EES Report and the alternative ninety-six (96) turbine layout, together with the applicable noise limit and an assessment of compliance. Table 2: Compliance assessment House MDA EES Report L A90, db Alternative layout L A90, db Applicable noise limit, db 1 (PN) Yes 2 (PL) Yes 41 (PL) Yes 46 (PN) Yes 47 (PN) Yes 49 (PL) Yes 50 (PL) Yes 51 (PL) Yes 52 (PN) Yes (PL) Participating Landholder (PN) Participating Neighbour Compliance with noise limits?

6 It can be seen from Table 2 that predicted noise levels from the proposed wind farm comply with the relevant base noise levels at all wind speeds at each of the assessed residential properties. Wind farm noise at all other identified residential properties further than 2km from the proposed wind farm are predicted to be 5dB or more below the 40dB L A90 base noise level and therefore also demonstrate compliance with NZS 6808:2010 at all wind speeds Assessment of operational substation noise The proposed substations associated with the Dundonnell Wind Farm are located within the site boundary and at the Mortlake Gas Power Station (MOPS). It is noted that transformers typically display tonality at 100Hz, therefore a correction of +2dB has been applied to the predicted L Aeq noise levels to obtain the effective noise levels (L eff ). Page 6 Using the ISO :1996 methodology, the operational noise levels from the on-site substation is predicted to be 16dB L eff at the nearest residential property (participating landholder). The operational noise level from the off-site substation is predicted to be 24dB L eff at the nearest residential property located approximately 1.1km to the south east. Noise from both proposed substations associated with the Dundonnell Wind Farm is predicted to comply with the night-time NIRV noise limit of 34dB L eff. In the time since the EES was prepared, consideration was also given to the cumulative noise of the MOPS and the off-site substation to be located near to the MOPS. In this respect, the off-site substation is predicted to be 10dB below the night-time NIRV noise limits applicable to the combined noise of the substation and the MOPS. Accordingly, not only does the off-site substation achieve the night-time NIRV limit, its contribution is considered inconsequential to the compliance status of the MOPS (i.e. the predicted contribution of the off-site substation is negligible) Assessment of operational transmission line noise Corona and Aeolian noise can be generated by the interaction of high voltage overhead power lines in specific atmospheric conditions. The proposed transmission line corridor is at least 500m away from the nearest noise sensitive location. Based on past experience of modelling studies in close proximity to these types of transmission lines, considerations relating to Aeolian tones or Corona noise represent a low risk at the proposed separating distances, particularly at the low to moderate wind speeds that are most relevant to this type of noise source. The occurrence of these types of effects during the operation of the project can also be reduced during the detailed design phase of the project through the selection of appropriate cable characteristics to avoid inherent resonant frequencies that are most important to Aeolian noise. 4.2 Construction noise Construction noise criteria Section 2 Construction and Demolition Site Noise of EPA Publication 1254 Noise Control Guidelines recommends noise limits and controls for construction noise. Although EPA Publication 1254 specifies that, during the night period, construction noise is to be inaudible within a habitable room of any residential premises, it allows for flexibility where it is not possible to avoid construction activities during the night. Unavoidable works include, but are not limited to, the following construction activities: Delivery of large size items such as wind turbine blades due to the risk of traffic hazard Turbine erection and assembly is dependent on appropriate wind conditions to minimise safety risks For such works, the guidelines require that affected premises should be notified of the intended work, its duration and times of occurrence.

7 4.2.2 Construction vibration guidelines Dundonnell Wind Farm Environmental Effects Statement There is no standard or regulation that specifies criteria for the control of construction vibration levels in Victoria. However, in New South Wales, a document by the Department of Environment and Climate Change (now EPA NSW) titled Assessing Vibration: A Technical Guideline dated February 2006 (the NSW Vibration Guideline) presents preferred and maximum vibration criteria for use in assessing human response to vibration Construction traffic noise guidelines There is no Victorian guidance document in relation to the assessment of construction traffic noise levels on public roads. The significance of changes in traffic volumes associated with construction activities has therefore been assessed having regard to the guidance contained in a document by NSW Department of Environment Climate Change & Water (now EPA NSW) titled Road Noise Policy dated March 2011 (RNP). The RNP does not specifically preclude direct application to temporary changes in noise levels associated with construction traffic, however the document is predominantly focussed on longer term or permanent impacts associated with completed road projects Airblast criteria The Scoping Requirement specifies that airblast from quarry operations should be assessed. Guidance for assessing the environmental effects of blasting in Victoria are provided in a document by the Department of Economic Development, Jobs, Transport and Resources Department (formerly the Department of State Development, Business and Innovation) titled Environmental guidelines Ground Vibration and Airblast Limits for Blasting in Mines and Quarries (the DSDBI Guidelines). Additional guidance is provided by Australian Standard :2006 Explosives Storage, transport and use, Part 2: Use of explosives (AS :2006); however, it should be noted that the reference criteria presented in the standard are less stringent than those recommended by the DSDBI Guidelines Assessment of construction noise Noise emissions for the proposed construction equipment have been determined based on guidance and data sources including Australian Standard AS 2436:2010 Guide to noise and vibration control on construction, demolition and maintenance sites (AS 2436:2010), and noise level data from previous projects of a similar nature. Construction noise levels for the proposed wind farm have been calculated using the prediction methodology detailed in ISO :2006. Page 7 Given that the precise equipment selections and methods of working would be determined during the development of a construction plan, and that the noise associated with construction plant and activity varies significantly, the predicted noise levels are provided as an indicative range of levels which may occur in practice. Construction noise levels were predicted up to 60-65dB L Aeq at participating landowner dwellings and up to 50-55dB L Aeq at participating neighbour and local landholder dwellings. While the EPA Publication 1254 does not specify noise limits for daytime construction activities, predicted noise levels have been presented for informative purposes. The predicted noise levels also indicate that noise should be considered in the development of the construction management plan for the project. Based on background noise levels measured in the vicinity of the proposed wind farm, construction activities, including the quarry, would not be able to operate during the evening period without additional noise control measures.

8 Page 8 As it is proposed to operate the quarry during both the day and evening periods (Monday to Sunday hrs), a detailed noise assessment of the quarry noise levels should be prepared to determine appropriate noise control measure to achieve the evening construction noise guideline. It is recommended that the quarry operations be restricted to the daytime period (Monday to Friday hrs and Saturday hrs) until such an assessment is submitted to the relevant authority. Provided that the potentially affected residents are notified in advance, unavoidable works such as turbine erection and delivery of large size items, may be undertaken during the evening and night periods, together with low noise works Assessment of construction vibration Construction activities have been predicted to result in vibration levels that are below the thresholds defined for the onset of adverse reaction at all nearby residential properties, with the exception of a participating receiver location where the predicted vibration levels marginally exceed the threshold range for certain activities related to the construction access roads. This type of construction activity will occur for limited periods and the prediction method is generally conservative. It may however be necessary to notify the residents of times when access road construction will occur in close proximity of their property. It should be noted that these predicted vibration levels are well below the levels associated with minor cosmetic damage of structures. Considering the separating distance between the proposed quarry operations and the nearest residential property (approximately 1.3km), it is unlikely that vibration levels from such activities exceed the vibration limits. Furthermore, it is unlikely that vibration levels from construction activities of the wind farm exceed the acceptable vibration dose values for intermittent vibration Assessment of construction traffic noise It is proposed that the preferred access to the site will be gained via Woorndoo-Streatham Road. Based on the information provided in the report No. CG prepared by Cardno Victoria Pty Ltd and dated 16 January 2014, the existing and construction related traffic noise levels have been predicted at dwellings most likely to be impacted by changes in traffic conditions. The noise levels as a result of construction related traffic have been predicted to comply with the proposed RNP criterion at the nearest affected residential property (participating landholder). The increase in traffic noise level is also below the recommended threshold Assessment of airblast Airblast levels have been predicted below 110dB L Zpeak at the nearest participating neighbour and below 90dB L Zpeak at the nearest local landholder. These levels comply with the relevant DSDBI Guidelines Construction management plan It is recommended that a Construction Noise Management Plan (CMP) be prepared subsequent to the determination of this project by the Relevant Authority. Construction works may need to occur outside of standard working hours on some occasions. Examples of activities where this may be required include delivery of oversize plant or structures, including turbine nacelle, blades, tower and transformers in addition to erection of these structures based on weather constraints. The CMP should include details of working methods and times, including any requirements for work outside of the day period defined in EPA Publication 1254.

9 Page 9 5 Response to Key Submissions I have reviewed key submissions that raise issues relating to noise. The main issues relate to the following: Issue raised Amplitude modulation Infrasound Low Frequency Noise Health Comment Comment CB3.1 of NZS 6808:2010 states that, by the very nature of wind turbine blades passing in front of a support tower, some amplitude modulation will always be present in the sound of a rotating wind turbine. Amplitude modulation (which is a variation in the emitted noise level) is a fundamental characteristic of wind turbine noise and is a characteristic which is taken into account in the objective criteria specifically developed for wind farms. Therefore the 5dB penalty for special audible characteristics does not apply to amplitude modulation that is a normal feature of a correctly functioning wind turbine. A higher than usual level of amplitude modulation has been reported to occur for brief periods at a small number of wind farm sites in other countries which lead to significant research by Renewable UK as detailed in Section 8.5 of the MDA EES Report. Since the preparation of the MDA EES Report, the UK Institute of Acoustics (UK IOA) has established a working group to investigate amplitude modulation. The aim of the group is to review the available evidence, and to produce guidance on the technical aspects for the assessment of amplitude modulation in wind turbine noise. While the group has published a discussion paper in April 2015, research is ongoing to establish appropriate methods of assessment. Notwithstanding the above, it is expected that a consent for the project would require compliance monitoring in accordance with NZS 6808:2010, which includes requirements to evaluate the presence of Special Audible Characteristics, including amplitude modulation. Section of NZS 6808:2010 states that although wind turbines may produce some sound at (ultrasound and infrasound) frequencies considered to be outside the normal range of human hearing these components will be well below the threshold of human perception. Further discussion is provided in Section 8.4 of the MDA EES Report. Section of NZS 6808:2010 states that claims have been made that low frequency sound and vibration from wind turbines have caused illness and other adverse physiological effects among a very few people worldwide living near wind farms. The paucity of evidence does not justify at this stage, any attempt to set a precautionary limit more stringent than those recommended. Further discussion is provided in Section 8.4 of the MDA EES Report. Health related issues are outside of my area of expertise. Effects of wind farm noise on nearby residents are discussed in Section 8.3 of the MDA EES Report, based on the views of government and peak health bodies in relation to the health effects of wind farms. The consensus advice from the publications referred to in Section 8.3 of the MDA EES Report is that there is no reliable evidence to support a relationship between wind farm noise and direct adverse effects on human health. Furthermore, the Standard notes that the consensus view of the committee responsible for the development of NZS 6808:2010, including New Zealand representatives from the Ministry of Health and Institute of Environmental Health, was that the Standard provides a reasonable way of protecting health and amenity at nearby noise sensitive locations, without unreasonable restricting the development of wind farm.

10 Page 10 Issue raised Stable air conditions Findings of the Acoustic Group report titled The results of an acoustic testing program Cape Bridgewater Wind Farm dated 26 November 2014 Proposed permit condition by the Moyne Shire Council. Comment During periods of stable air conditions, the difference between wind speeds near ground level and the wind turbine hub height may be greater than occurs in other conditions. The direct effect of this meteorological condition is that for a given hub height wind speed, the wind generated background noise levels at ground level may be reduced. In such a case, though the noise emission from a wind farm does not change, there may be an increase in audibility at ground level due to lower levels of background masking noise. This potential effect of stable atmospheric conditions has been addressed in the MDA EES Report by relating all background noise levels and wind turbine predictions to wind speeds at hub height, in lieu of wind speeds measured at 10m height. In addition, stable atmospheric conditions can influence sound propagation from the wind farm. This potential effect has been addressed in the MDA EES report by using a prediction method which assumes that the atmospheric conditions simultaneously favour (i.e. increase) the propagation of sound from each turbine to all receiver locations. Stable atmospheric conditions may also be relevant to the conditions in which amplitude modulation may occur. This is discussed separately above and in Section 8.5 of the MDA EES Report As a member of the Association of Australian Acoustical Consultants (AAAC) Wind Farm Subcommittee, I was involved in the preparation of review of the Acoustic Group report which was presented at the recent Select Committee on Wind Turbines. The review provides the following conclusions: The level of infrasound measured is similar to the level previously measured by others The claimed "pattern" between high severity sensation and modes of operation is not based on a statistical analysis and ignores contradictory occurrences The hypothesis that there is a link between "sensations" and infrasound is based on excluding data that do not support the hypothesis. A copy of the AAAC Review is provided in Annexure E. The Acoustic Group report was commissioned in response to ongoing concerns from six (6) local residents in the vicinity of the Cape Bridgewater Wind Farm, but did not assess whether the wind farm complied with its planning approval requirements. The findings of this report are therefore specific to the experience of these residents during the study and the noise environment at their dwellings. I endorse the AAAC Review and, considering that the Acoustic Group report does not present any new credible scientific evidence, it is my opinion that it is not relevant to the noise and vibration assessment of the proposed Dundonnell Wind Farm. It should be noted that the Joint Statement issued by the Acoustic Group and Pacific Hydro on 16 February 2015 states that the report does not recommend or justify a change in regulations. In its submission, the Moyne Shire Council requested that any permit issued should require a revised noise impact assessment to be prepared, peer reviewed and approved prior to erection of any turbine as a condition. It is my opinion that this type of condition is reasonable. This is reflected in the draft proposed conditions. A draft proposed Condition proposed by Trust Power reads as follows: Before the wind energy facility starts operating, a Noise Compliance Assessment, including a Tonal Audibility Assessment, must be undertaken to reflect the final turbine layout. The Noise Compliance Assessment shall be prepared by a suitably qualified and experienced independent acoustic engineer to demonstrate compliance with the noise limits specified in condition 13, and must be to the satisfaction of the responsible authority. All compliance reports should be publically available

11 5.1 Moyne Shire Council Peer-review Dundonnell Wind Farm Environmental Effects Statement I have reviewed the peer review commissioned by the Moyne Shire Council, prepared by SLR Consulting Australia Pty Ltd and dated 24 August 2015, and provide the following responses. Page 11 Issue raised EES Scoping requirement relating to the assessment of potential for construction and operation of the project to increase noise levels and/or vibration at sensitive receptors Operational noise criteria for ancillary equipment Assessment at residential properties owned by the proponent and participating landowners Background noise monitoring Comment A representation of baseline conditions was established on the basis of background noise monitoring conducted at six (6) properties in the vicinity of the proposed wind farm as detailed in Section 6.0 of the MDA EES Report. Furthermore, predicted noise level information is presented in Section 8.0 of the MDA EES Report. This combined information indicates that there will be periods when the wind farm noise levels will be above the background noise levels which may result in the wind farm being audible at times. As per the requirements of NZS 6808:2010, listed as a relevant policy document for this EES, an assessment of the potential increase in wind farm noise was undertaken on the basis of the wind farm adhering to a limit not higher than 5dB above background, except in low noise level conditions (as specified by the Standard) in which it is no longer necessary to remain within a certain margin of the background to provide an adequate level of amenity protection. The above comments relate to noise. Operation of the wind farm will be negligible in relation to vibration levels as detailed in Section 8.4 of the MDA EES Report. An assessment of transient vibration levels associated with the construction of the project is presented in Section of this statement. The applicable noise limits for ancillary equipment has been determined in accordance with NIRV as detailed in Section 3.3 of the MDA EES Report. These limits have been determined with regard to the land zoning of the both the proposed substation and nearby residential properties together with the proposal to develop a wind energy facility. Specifically, as detailed in Section 1.1.b of the Victorian Guidelines, wind energy facilities are classified as utilities for which separate guidance is detailed in NIRV. Section 3.1 of NIRV specifies a night-time noise limit of 34dB during the night-time period as detailed in Section 3.3 of the MDA EES Report. As detailed in Section 7.1 of the MDA EES Report, the definition given in NZS 6808:2010 of noise sensitive locations specifically excludes dwellings within the wind farm site. Furthermore, as explained in Section of the MDA EES report, NZS 6808:2010 is not intended to be applied to noise sensitive locations outside the site boundary where a noise agreement exists between the occupants and the proponent of the development. It may be appropriate for these noise agreements to be incorporated into Section 173 agreements associated with the project. The mention of LA95 within Appendix E2 of the MDA EES Report is a typographical error. I confirm that LA90 noise levels have been used for this assessment. The sentence following Table 29 of the MDA EES Report contains a typographical error and should read: [O] only 858 were included in the night period regression analysis [O]. The low correlation coefficient values presented in Appendix E4 are consistent with the low background noise levels across the monitoring locations. Although the background noise levels show little dependence on hub height wind speeds, the measured noise levels are representative of the low noise environment during the time of the monitoring campaign. As detailed in Section 7.3 of the MDA EES report, the relevant base noise limits, independent of background noise, have been used to assess compliance with NZS 6808:2010. This approach is deemed conservative.

12 Page 12 Issue raised Application of high amenity noise limit Construction noise Comment The definition of a high amenity area provided in NZS 6808:2010 is specific to New Zealand planning legislation and guidelines. A degree of interpretation is therefore required when determining how to apply the concept of high amenity in Victoria. Consistent with its application in New Zealand, the determination of whether a high amenity area noise limit should be considered in the context of the Victorian planning legislation is based on the following test: Does the planning schedule relevant to the location of non-involved residential properties where the predicted wind farm noise level is at or above 35dB require a high level of amenity? If the relevant planning schedule requires a high level amenity, is the high amenity area noise limit justified based on the application of a calculation method detailed in Comment C5.3.1 of NZS 6808:2010? As detailed in Section 7.2 of the MDA EES Report, the land zoning (Farming Zone) of neighbouring residential properties in the vicinity of the proposed wind farm does not justify the application of the high amenity noise limits. Furthermore, this approach to the high amenity standard provisions of NZS6808:2010 mirrors the findings of VCAT in the Cherry Tree Wind Farm case. While VCAT in that case considered an earlier version of the Victorian Guidelines, the text within the Victorian Guidelines relating to the high amenity area requirements is identical to the 2012 version of the Guidelines (referenced in the Scoping Requirements) and the current version of the Guidelines. It is therefore not required, in my view, to conduct the subsequent objective analysis procedures. Traffic noise levels associated with construction activities have been predicted in general accordance with the methodology detailed in the UK document Calculation of Road Traffic Noise (CoRTN), primarily for the purpose of estimating the change in noise level. The list of nine (9) construction scenarios includes construction of the offsite substation. Predicted construction noise levels presented in the MDA EES Report only relate to construction activities occurring on or near the wind farm development site. The calculation of estimated airblast levels were based on the assumption of a maximum instantaneous charge of 2.07kg. 6 Declaration I have made all the inquiries that I believe are desirable and appropriate and no matters of significance which I regard as relevant have to my knowledge been withheld from the Planning Panel. Signed.O.OOOOOOOOOOOO. Dated 23 September 2015

13 Page 13 Annexure A Qualifications Qualifications M.Eng Masters Degree in Engineering (French Equivalent), France 2001 Professional associations MAAS Member of the Australian Acoustical Society Employment history and achievements Present - Associate Consultants in acoustics and noise control. Marshall Day Acoustics Pty Ltd, Melbourne, Australia. Responsibilities include consulting work in industrial noise control, environmental noise impact (including wind farms) and architectural sound insulation. Noise impact assessments of Victorian wind farm developments at Bald Hills, Berrimal, Berrybank, Challicum Hills, Chepstowe, Coonooer Bridge, Crowlands, Hawkesdale, Lal Lal, Hepburn, Moorabool, Mortlake, Mt Gellibrand, Mt Mercer, Newfield, Oakland Hill, Penshurst, Portland, Ryan Corner, Sidonia Hills, Stockyard Hill, Waubra, Winchelsea, Wonthaggi and Yaloak South 2001 Vacation Employment Marshall Day Acoustics Pty Ltd, Melbourne, Australia

14 Dundonnell Wind Farm Environmental Effects Statement Page 14 Annexure B Alternative turbine layout

15 Turbine Easting Northing Turbine Easting Northing Turbine Easting Page 15 Northing T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T All coordinates in WGS84 Zone 54

16 Page 16 Annexure C Reports reviewed to prepare initial study or statement I have reviewed the following documents that are referenced in the study: Dundonnell Wind Farm Project Environment Effects Statement - Scoping Requirements (the Scoping Requirements). New Zealand Standard 6808:2010 Acoustics Wind farm noise (NZS 6808:2010) Victorian Government's Policy and planning guidelines for development of wind energy facilities in Victoria dated July 2012 (the Victorian Guidelines) Victorian EPA publication 1411 titled Noise from Industry in Regional Victoria Recommended maximum noise levels from commerce, industry and trace premises in regional Victoria (NIRV) Victorian EPA Publication 1254 titled Noise Control Guidelines NSW Department of Environment Climate Change (now EPA NSW) document Assessing Vibration: A Technical Guideline dated February 2006 (the NSW Vibration Guideline) NSW Department of Environment Climate Change & Water document (now EPA NSW) Road Noise Policy dated March 2011 (RNP) Department of Economic Development, Jobs, Transport and Resources (formerly the Department of State Development Business and Innovation) document Environmental guidelines Ground Vibration and Airblast Limits for Blasting in Mines and Quarries (DSDBI Guidelines) Australian Standard :2006 Explosives Storage, transport and use, Part 2: Use of explosives (AS :2006) Vestas document No V00 titled V MW-IEC2A Third Octaves according to General Specification, dated 7 June 2013 Report GLGH A-0001-B Results of acoustic noise measurements according to IEC on a Vestas V MW (mode 0) near Lem / Denmark, dated 20 August 2012 Australian Standard AS :2009 Power transformers Part 10: Determination of sound levels (AS :2009) UK Institute of Acoustics A good practice guide to the application of ETSU-R-97 for the assessment and rating of wind turbine noise (IOA GPG) dated May 2013 Final report by The European Working Group on Noise from Wind Turbines (ETSU-R-97) Victoria Planning Provisions Practice Note prepared by the Department of Sustainability and Environment titled Applying the rural zones and dated March 2007 ISO :1996 Acoustics Attenuation of sound during propagation outdoors Part 2: General method of calculation (ISO9613-2:1996) World Health Organisation (WHO) Guidelines for Community Noise 1999 (WHO Guidelines) Victorian Department of Health publication titled Wind farms, sound and health Technical information dated April 2013 Systematic review of the human health effects of wind farms 2013, Adelaide University, commissioned by the National Health and Medical Research Council (NHMRC) NHMRC Draft Information Paper titled Evidence on Wind Farms and Human Health dated 2014 Australian Medical Association (AMA) Position Statement titled Wind Farms and Health dated 2014 Institute of Acoustics Bulletin Bowdler, Bullmore, Davis, Hayes, Jiggins, Leventhall, McKenzie - Prediction and Assessment of Wind Turbine Noise March 2009 Sonus report for Pacific Hydro - Infrasound measurements from wind farms and other sources dated November 2010

17 Page 17 Evans, T., Cooper, J. & Lenchine, V., Infrasound levels near wind farms and in other environments, South Australian Environment Protection Authority, Adelaide, 2013 Health Protection Agency UK document Health Effects of Exposure to Ultrasound and Infrasound Report of the independent Advisory Group on Non-ionising Radiation, dated 2010 Victorian Department of Health document Public Statement: Wind Turbines and Health dated July 2010 NHMRC Systematic review of the human health effects of wind farms dated 2014 Renewable UK document Wind Turbine Amplitude Modulation: Research to Improve Understanding as to its Cause and Effects dated December 2013 Australian Standard AS 2436:2010 Guide to noise and vibration control on construction, demolition and maintenance sites (AS 2436:2010) UK Transport Research Laboratory s (TRL) Groundborne vibration caused by mechanised construction works dated 2000 NSW Roads and Traffic Authority s Environmental Noise Control Manual (ENCM) dated 2001 Cardno Victoria Pty Ltd report No. CG130634, dated 16 January 2014 UK Institute of Acoustics (IOA UK) Noise Working Group (Wind Turbine Noise) Amplitude Modulation Working Group Discussion Document Methods for Rating Amplitude Modulation in Wind Turbine Noise dated 22 April 2015

18 Page 18 Annexure D Noise related scoping requirements Key Issues Increase in noise levels from the project for nearby sensitive receptors (including traffic noise and vibration during construction). Priorities for characterising the existing environment Identify sensitive receptors that may be subject to the various amenity effects from the project including, but not limited to, all dwellings within 2 km of wind turbines. Characterise the ambient noise environment. Design and mitigation measures Outline and evaluate potential design and siting options that could mitigate effects on visual amenity from adjoining residences. Describe and evaluate both potential and proposed design responses and/or other mitigation measures (construction equipment, staging and scheduling of works), which could minimise noise and vibration effects on sensitive receptors. Assessment of likely effects Assess the potential for construction and operation of the project to increase noise levels and/or vibration at sensitive receptors. The assessment should include an estimation of noise (including tonal and infra-sound) from all project-related sources at different times over a 24-hour cycle to establish the likely conditions to be experienced at sensitive receptors. Assess the potential effects from the proposed on-site quarry activities on sensitive receptors (including air blast, vibration, fly rock). Approach to manage performance Outline and evaluate proposed additional measures to monitor and manage noise and vibration levels to minimise residual effects and ensure compliance with standards, where necessary.

19 Page 19 Annexure E AAAC review of the Acoustic Group report

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