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Expert Witness Statement of David Fuller

Expert of Cherry Tree Wind Farm Pty Ltd

In the matter of Cherry Tree Wind Farm Pty Ltd v Mitchell Shire Council

11 JANUARY 2013

VCAT Application No P2910/2012

Proponent: Cherry Tree Wind Farm Pty Ltd

Prepared for

Cherry Tree Wind Farm Pty Ltd

Surface water, Groundwater and Erosion Expert Opinion

c:\documents and settings\david_fuller\my documents\a cherry tree wind farm\expert statement d fuller cherry tree wind farm.docx

Project Manager:

Dr Belinda Lovell Snr Associate Scientist

URS Australia Pty Ltd

Level 6, 1 Southbank Boulevard Southbank VIC 3006 Australia T: 61 3 8699 7500 F: 61 3 8699 7550

Principal-In-Charge:

…………………………… David Fuller Senior Principal

Author:

…………………………… David Fuller Senior Principal

Date: Reference: Status:

11 January 2013 12345678/12345678/1 FINAL

Document copyright of URS Australia Pty Limited.

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permitted unless and until they are the subject of a written contract between URS Australia and the

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of the Commonwealth Electronic Transactions Act (ETA) 2000.

Where an electronic only version is provided to the client, a signed hard copy of this document is held

on file by URS and a copy will be provided if requested.


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Table of Contents

A. Expert Opinion .................................................................................................. 1

1. Name and address............................................................................................ 1

2. Area of expertise .............................................................................................. 1

3. Scope ................................................................................................................ 1

3.1 Instructions ....................................................................................................... 1

3.2 Process and Methodology ............................................................................... 1

3.3 Persons assisting with this work .................................................................... 2

4. Findings ............................................................................................................ 2

4.1 Summary of Opinions ...................................................................................... 2

4.2 Hydrogeological Setting .................................................................................. 2

4.3 Wetlands/Springs Context ............................................................................... 3

4.4 Impact from Turbine Foundations ................................................................... 4

4.5 Impact on Groundwater Recharge .................................................................. 4

4.6 Impact on Surface Water Runoff ..................................................................... 4

4.7 Salinity and Leaching from Concrete.............................................................. 4

4.8 Erosion .............................................................................................................. 5

4.9 Response to Key Submissions ....................................................................... 5

5. Declaration ........................................................................................................ 6

B. Limitations ......................................................................................................... 7

Appendices

Appendix A Curriculum Vitae - David Fuller


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A.

A. Expert Opinion

1. Name and address

David Allan Fuller

C/o URS Australia Pty Ltd

Level 6, 1 Southbank Blvd, Southbank, VIC 3006.

2. Area of expertise

(a) I hold the degrees of Bachelor of Science (Physics/Mathematics), Diploma in Statistics, and

Master of Business Administration. I have also successfully completed the Masters level Post-

graduate Course in Hydrology at the University of New South Wales.

(b) For the past 30 years I have been involved in engineering hydrology, water quality,

environmental hydrology, water management and the environmental impacts of developments

across Tasmania, Victoria, South Australia, New South Wales and Queensland.

(c) My qualifications and experience are detailed in Appendix A.

3. Scope

3.1 Instructions

URS Australia Pty Ltd (URS) was formally engaged by letter on 18 December 2012.

I have been commissioned by Cherry Tree Wind Farm Pty Ltd to give my opinion on whether there is

potential for the Cherry Tree Wind Farm to impact on groundwater, surface water, erosion, salinity and

the hydrology of existing wetland systems.

3.2 Process and Methodology

In conducting this assessment and forming my opinions:

1. I visited the proposed development site on 17 December 2012;

2. I have taken into consideration the following:

(a) State Environment Protection Policy (Groundwaters of Victoria) 1997;

(b) State Environment Protection Policy (Waters of Victoria) 1997;

(c) Water Act 1989;

(d) Policy and Planning Guidelines for Development of Wind Energy facilities in Victoria (July

2012).

(e) The relevant Erosion Planning Scheme Overlay Accessed online at

http://planningschemes.dpcd.vic.gov.au/mitchell/home.html

(f) North East Planning Referrals Authority, Guidelines for the Protection of Water Quality, 2001.

Accessed online from www.gbcma.vic.gov.au January 2013

(g) Goulburn-Broken Catchment Management Authority, Regional Catchment Management

Strategy, 2012. Accessed online from www.gbcma.vic.gov.au January 2013


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(h) Goulburn-Broken Catchment Management Authority, Regional Catchment Management

Strategy, 2003. Accessed online from www.gbcma.vic.gov.au January 2013

(i) Victorian EPA, Environmental Guidelines for Major Constructions, EPA Publication 480, 1996

(j) Victorian EPA, Construction Techniques for Sediment Pollution Control, EPA Publication 275,

1991

3. I have reviewed and relied upon the following documents:

Aurecon Australia (2012). Cherry Tree Wind Farm Geology and Hydrology Assessment Report,

Prepared for: Infigen Energy Development Pty Ltd, 23 April 2012

Azizian, M.F., Nelson, P.O., Thayumanavan, P. & Williamson, K.J. (2005). Environmental Impacts

of Leachate from Portland Cement Concrete (PCC) with and Without Plasticizer in Highway

Construction, The Handbook of Environmental Chemistry, Volume2, Springer

Coates, F., Tolsma, A., Cutler,S. & Fletcher, M. (2010). The Floristic Values of Wetlands in the

Highlands and Strathbogie Ranges, Arthur Rylah Institute for Environmental Research,

Department of Sustainability and Environment, Heidelberg, Victoria

DPI (2012). Victorian Resources Online, Groundwater Management Area Map, created October

2012. Accessed 08/01/2012 at www.dpi.gov.au

Mitchell Shire Council (2012). Special Council Meeting Minutes, Thursday 25 October 2012

Parsons, S., Evans, R. & Hoban, M (2008). Surface-groundwater connectivity assessment; a

report to the Australian Government from the CSIRO Murray-Darling Basin Sustainable Yields

Project. CSIRO, Australia. 35pp.

Stewardson, M, Western, A. & Wallis, E. (2009). The Hydrology of Wetlands in the Highlands and

Strathbogie Ranges, Department of Civil and Environmental Engineering, University of Melbourne

3.3 Persons assisting with this work

In preparing this Expert Witness Statement, I have been assisted by Mr Bryan Chadwick (Senior

Principal Hydrogeologist) and Mr Yuva Adhikary (Principal Water Engineer) employed by URS. I have

reviewed the work undertaken on my behalf and consider it to be of an acceptable standard. The

views presented in this report reflect my opinions.

4. Findings

4.1 Summary of Opinions

URS was not involved in the initial study or statement. Aurecon (2012) was engage to report on

geology and hydrology issues and it is noted that few impacts were identified based on their analysis.

It is also noted that mitigation measures in accordance with relevant engineering and environmental

standards were identified in that report.

4.2 Hydrogeological Setting

Cherry Tree wind farm (the site) is located in the Mitchell Shire of central-east Victoria, 120km north

east of Melbourne, approximately 5km north of Kerrisdale township and an adjacent state forest.


A Expert Opinion

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The site is located on an elevated plateau in Victoria’s central highlands (Cherry Tree Range), and at

a regional level is contained within the River Murray catchment. Locally, the site is bounded by the

Goulburn River to the south and Whitehead River to the north. Mount Eaglehawk is approximately

3km to the south east of the site at an elevation of 527mAHD.

The surface geology within the Site Area Boundary (as defined in Figure 4.1 (Aurecon ,2012)) includes

the following:

Quaternary aged fluvial alluvium;

Upper Devonian aged Trawool Granite; and

Lower Devonian aged Monty’s Hut Formation which comprises thinly bedded sandstone and

siltstone.

All the wind turbines are located on the Trawool Granite. Trawool Granite is an identical unit to the

Strathbogie Granite. Texturally, the granite varies between fine grained, cordierite-rich granite,

medium grained granite with minor cordierite, and coarse grained tourmaline rich granite. Fresh,

unweathered, granite outcrops across the area, with little apparent soil cover across most ridgelines.

The alluvium deposits form in topographical low areas along the floodplain of the Goulburn River and

creek courses. Alluvial deposits are known to typically consist of sand, silt, clay and gravel.

Consistent with the geology, the groundwater beneath the Site Area Boundary will lie within the

fractures and joints of the granite. The aquifer is unconfined to semi-confined, depending on the extent

and connectivity of fractures within the granite.

The granite outcrops are likely to provide the main recharge areas to the local groundwater system,

with groundwater flow largely following the topography. However, regional groundwater will flow

towards the Goulburn River. The Goulburn River within the Site Area Boundary has been classified as

a moderately gaining stream (Parsons et al., 2008), meaning it is contributed to by groundwater.

Furthermore, the Bureau of Meteorology’s Atlas of Groundwater Dependent Ecosystems

(http://www.bom.gov.au/water/groundwater/gde/map.shtml) indicates that in this area of the Goulburn

River the potential of groundwater interaction with vegetation, and possible Groundwater Dependent

Ecosystems, is low-moderate.

Depth to groundwater will be variable within the Site Area Boundary. It varies from 50m to near

surface, depending on distance from the Goulburn River. Immediately beneath the wind turbine towers

groundwater would be expected to be greater than 20m below ground.

The salinity within the granites is likely to be towards the lower end of the range stated by

Aurecon (2012), with values potentially less than 500 mg/L, given the geology and its vicinity to

recharge areas.

The site is not within a regulated groundwater area. The nearest is approximately 30km north, which is

the Mid-Goulburn Groundwater Management Area that regulates groundwater along the Goulburn

River north of Seymour (DPI, 2012).

4.3 Wetlands/Springs Context

During the site visit, a number of wetland/spring systems were observed. These systems were located

on the Goulburn River slopes of the Cherry Tree Hill range and arose approximately 20 – 50m below

the highest level of the plateau. Each of the wetlands was delineated by wetland


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grasses/sedges/reeds with little surface water. Wetlands were contained within a ‘circque’ or roughly

circular to elliptical topographic depression. Wetland beds were probably shallow peat and sloped

towards a defined outlet downslope. At or downstream of these outlets small rivulets were observed

with variable surface water flows.

I walked to one of the wetlands approaching from downstream following a streamline crossed by a

track. It was evident that flows at the track crossing were approximately 3-4 litres/second. Flows at the

outlet of the wetland (approximately 75m long and 25m wide) were very much lower than this,

suggesting additional groundwater inputs in the incised valley between the wetland and the road

crossing. Small fish were observed on the downstream side of the track crossing.

The expression of surface water at these wetland locations is consistent with the description of the

fractured rock geology of the area.

4.4 Impact from Turbine Foundations

There is unlikely to be any direct impact on the groundwater system from turbine foundations, since

groundwater levels are expected to be at least 20m below the plateau. Consequently, there is no

likelihood of changes in groundwater flow directions or volumes arising from foundations. I would

reach the same conclusion if it was decided during detailed design that rock bolts were required to

secure the turbines instead of concrete foundation slabs.

4.5 Impact on Groundwater Recharge

The total footprint of the foundations, sealed access tracks and ancillary infrastructure, is

approximately 0.5% of the principal recharge area. Any rain falling on the impervious areas would be

managed under accepted engineering design practices to infiltrate locally. This suggests that little or

no reduction in net recharge volumes to the groundwater system would occur. Some slight increase in

net recharge may occur due to the impervious surfaces.

4.6 Impact on Surface Water Runoff

Under current engineering design practices stormwater would be managed locally therefore infiltration

would be the main mechanism for managing stormwater runoff from impervious areas. It is not

expected that there would be any significant change in runoff volumes into valleys either side of the

plateau. During detailed engineering design stormwater volumes will be quantified and managed to

minimise runoff.

4.7 Salinity and Leaching from Concrete

Given the small footprint of the towers compared with the local landscape and the small volumes of

salt within concrete compared with the salt balance in the remainder of the catchment, there is no risk

of increased salinisation downstream.

Azizian et al. (2005) investigated the environmental impacts of leachates from Portland Cement and

found no impact on a range of biota in the immediate vicinity of concrete provided plasticisers were not

used. Plasticisers are rarely required in Australian conditions. Even where plasticisers were used,

Azizian et al. (2005) found that soil processes and biodegradation ameliorated any impacts within a

few metres. It is therefore considered that there will be no detrimental impacts on surface waters or

groundwaters arising from the use of concrete in the proposed development.


A Expert Opinion

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4.8 Erosion

There is potential for ground disturbance and erosion associated with roadworks, waterway crossings,

and construction activities associated with turbines and ancillary infrastructure.

The footprint of the turbines and most other ancillary infrastructure is on the Cherry Tree plateau which

is typified by undulating low slopes, shallow soils, granite outcrops and grasses. Management of

erosion from the plateau is unlikely to affect areas downslope provided appropriate controls, including

sediment fencing and swales, are used to control any runoff. The grassy areas would also provide a

significant buffer, outside the immediate works area, that would reduce mobilisation of soils.

Engineering designs for waterway crossings require approvals from the Goulburn Broken CMA, and

normal design practice and standards (for example, sediment fencing, minimisation of disturbance,

rock beaching) are expected to control erosion at these points.

During construction, temporary stockpiles of material or staging may be required. Engineering design

of runoff from these areas should conform with current standards (for example, the use of bunds and

sediment fences) to minimise erosion and sediment runoff.

From field observation, the design of road access from the valley to the escarpment is of particular

importance in ensuring appropriate control of erosion, since these roads traverse some steep country

and erosion is evident on exposed surfaces of existing cuttings and tracks (as shown on Figure 12a

Infrastructure Crossings in Amended Plan, November 2012) . Some of the existing tracks may need to

be widened or realigned and/or sealed. In my view detailed engineering design can mitigate erosion in

accordance with current practice utilising swales and other devices to limit changes in runoff volumes

and velocities. Relevant EPA documents include Environmental Guidelines for Major Constructions,

EPA Publication 480, 1996; and Construction Techniques for Sediment Pollution Control, EPA

Publication 275, 1991.

4.9 Response to Key Submissions

In the table below I have summarised those submissions which relate to surface water, groundwater,

aquatic ecosystems, erosion and salinity, and I have provided a specific response to the issues raised.

Summary of Submission(s) Submission Response

Concerns regarding erosion arising from creek crossings, construction compound, and increased runoff from the plateau; Concerns regarding increased salinisation down grade; Concerns regarding leaching of salts from concrete

31 Aug 2012 GP and AP Belton Addendum to Objection to Planning Proposal P306963/12

Industry standards applied to the management of erosion and sediment runoff during and post construction mean that it is unlikely that any significant changes in erosion will arise from the proposed development; Leaching from concretes will not cause environmental issues downstream.

Leaching of lime or salt or other minerals from concrete turbine foundations and potential impacts on soil, plant and animal life in creeks adjacent to the development site and the Goulburn River

14 Aug 2012 R.M. Lilley Objection to Planning Proposal P306963/12

Leaching from concretes will not cause environmental issues downstream.

Impacts on aquatic fauna including native fish and invertebrates;

2 Nov 2012 F. Smith Statement of Grounds VCAT Ref

Leaching from concretes will not cause environmental issues downstream.


A Expert Opinion

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from concrete turbine foundations and potential impacts on soil, plant and animal life in creeks adjacent to the development site and the Goulburn River

P2910/2012 No significant change in surface water or groundwater hydrology is expected.

Adequacy of proposed buffers along waterway and drainage lines to protect geomorphology of wetlands, aquifers, and seasonal and permanent creeks; Potential impacts of structural arrangements for turbines on wetlands and creek systems flowing to the Goulburn River; Existing condition of watershed and wetland systems given the observed presence of Mountain galaxias

18 Nov 2012 F. Smith Attachment to Email to [email protected], [email protected], [email protected], Subject: Victorian Civil and Administrative Tribunal Reference: P2910/2012 – statement relating to expert witness to be called by Fiona Smith

Adequacy of buffers along waterways (refer Figure 4.1, Aurecon(2012)) are a matter for Goulburn Broken CMA that has recommended the distances. There will be no impact of structural arrangements for turbines on the wetlands and creeks. Visually, the existing condition of the wetland systems on the escarpment appears healthy. However, detailed scientific study would be required to verify this. No relevant scientific information on the current condition of these specific wetlands was found in a literature search.

Potential adverse impacts on springs, aquifers, creeks, ecosystems and wildlife; Presence of native fish in creek systems; Protection of property under conservation contract with DSE; Crown reserve areas including Horseshow Lagoon and the Goulburn River No consideration of reports: “The hydrology of wetlands in the Highlands and Strathbogie Ranges” and “The Floristic Values of Wetlands in the Highlands and Strathbogie Ranges”

31 Aug 2012 F. Smith Letter to Statutory Planning Unit, Mitchell Shire Council Reference: Planning Application Reference Number P306960 3/12: Cherry Tree Wind Farm Development Objection

No adverse impacts are expected on creeks, springs, aquifers or aquatic species. Native fish were observed in on creek system immediately downstream of a wetland. The Crown Reserve at Horseshoe Lagoon will not be directly impacted by construction. As no change in water quality or flow is expected from the wind farm development, no indirect impacts are expected on Horseshow Lagoon. Review of the reports mentioned in the Submission did not identify any matters that contradict or change my opinions.

5. 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.

10 January 2013


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B.

B. Limitations

URS Australia Pty Ltd (URS) has prepared this report in accordance with the usual care and

thoroughness of the consulting profession for the use of Cherry Tree Wind Farm Pty Ltd and only

those third parties who have been authorised in writing by URS to rely on this Report.

It is based on generally accepted practices and standards at the time it was prepared. No other

warranty, expressed or implied, is made as to the professional advice included in this Report.

It is prepared in accordance with the scope of work and for the purpose outlined in the contract date

18 December 2012.

Where this Report indicates that information has been provided to URS by third parties, URS has

made no independent verification of this information except as expressly stated in the Report. URS

assumes no liability for any inaccuracies in or omissions to that information.

This Report was prepared between 19 December 2012 and 11 January 2013 and is based on the

information reviewed at the time of preparation. URS disclaims responsibility for any changes that may

have occurred after this time.

This Report should be read in full. No responsibility is accepted for use of any part of this report in any

other context or for any other purpose or by third parties. This Report does not purport to give legal

advice. Legal advice can only be given by qualified legal practitioners.

Except as required by law, no third party may use or rely on this Report unless otherwise agreed by

URS in writing. Where such agreement is provided, URS will provide a letter of reliance to the agreed

third party in the form required by URS.

To the extent permitted by law, URS expressly disclaims and excludes liability for any loss, damage,

cost or expenses suffered by any third party relating to or resulting from the use of, or reliance on, any

information contained in this Report. URS does not admit that any action, liability or claim may exist or

be available to any third party.

Except as specifically stated in this section, URS does not authorise the use of this Report by any third

party.

It is the responsibility of third parties to independently make inquiries or seek advice in relation to their

particular requirements and proposed use of the site.

Any estimates of potential costs which have been provided are presented as estimates only as at the

date of the Report. Any cost estimates that have been provided may therefore vary from actual costs

at the time of expenditure.


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A

Appendix A Curriculum Vitae - David Fuller

Curriculum Vitae

David Allan Fuller

Senior Principal (Water & Catchments)

Areas of Experience

Water balance and demand modelling including multiple use reservoir

systems, yield estimation and drought management.

Flood hydrology including extreme flood estimation, development of regional

estimation procedures, flood frequency analysis and stochastic data

generation.

Water quality and ecosystem health monitoring and modelling including

environmental flow estimation

Water allocation systems, management and planning.

Managing trade-offs between resource managers, users, and the

environment.

Evaluation of water resource investment strategies and programs.

Development and review of water management policies and strategies.

Integration of technical and non-technical programs.

Career Summary

David is an experienced surface water professional with expertise in catchment and water system modelling, ecohydrology, flood and yield assessment, water allocation, stochastic hydrology and water quality. He has experience in the design, implementation and review of multidisciplinary projects that seek to provide insights into river and wetland environments, environmental impacts arising from developments, and engineering design inputs for major structures.

David has held a number of senior positions in both the private and public sector and has developed excellent inter-personal and communication skills. He has worked in Tasmania, Victoria, New South Wales, South Australia and Queensland on a diverse range of projects.

David enjoys building close working relationships with clients and assisting them by bringing together technical and non-technical teams to deliver engineering, policy or strategic solutions to meet their needs.

Some Relevant Projects

Expert reviewer, Water Balance Modelling – Copper Mine Development, Independence Group

Expert reviewer, Water Balance Modelling –Project Nammaldi, Rio Tinto

Project Director, Water Quality and Environmental Impact Assessments for a Copper Mine Development, Independence Group

Project Director Gunbower Forest environmental watering project, North Central CMA

Expert reviewer, Water Balance Modelling, Kevin’s Corner Coal Mine, Hancock Coal

Project Director Detailed engineering design Gunbower environmental watering works & measures, Goulburn Murray Water

Project Director Hattah Lakes environmental watering project, Mallee CMA

Qualifications

BSc(Math/Physics), Cert Hydrol, Dip

Stats, MBA, MEc(in

prog)

David Allan Fuller.Senior Principal (Water & Catchments)

Project Director Lindsay-Wallpolla environmental watering project, Mallee CMA

Project Director – Multiple due diligence assessments for Commonwealth investment in irrigation infrastructure, DSEWPaC

Project Director – Development of a method for assessment of salinity impacts of environmental works and measures, MDBC

Project Director, Gladstone coal seam gas project water studies and management strategy, Santos

Consortium leader - Development of SIMRAT model to assess the salinity impacts of interstate trade in the Murray-Darling Basin, MDBC

Project Director - Review of water management and sustainability issues Latrobe Valley, DPI Vic

Leader - Independent Expert Review Lower Lachlan Groundwater Sharing Plan, Lachlan CMA.

Chair State of Environment Report - Inland Waters and Wetlands chapter, SOE Unit

Project Director, Water quality monitoring system review, West Gippsland CMA

Project Director, Data and water quality monitoring system review, North East CMA

Project Director, Great Barrier Reef Pesticide Usage Monitoring System, DEWHA

Leader Mid-term Review of Basin Salinity Management Strategy, MDBC.

Developed an evaluation framework for water management plans, NSW.

Murray Darling Basin Water Quality Objectives review, DEWHA

Project Manager, Water Quality in Irrigated Catchments Project with responsibility for water quality modelling and development of monitoring tools for irrigated agriculture throughout the Murray-Darling Basin, MDBC

Project Director, Heavy Metals in the River Murray project, MDBC

Project Director, National Chemical Monitoring Initiative, DEWHA

Project Director and lead researcher – Turbidity measurement benchmarking and assessment project, West Gippsland CMA

Manager Monitoring River Health Initiative (Tasmania) including the development of AUSRIVAS models, DIPWE

Project Director – Pesticide Usage Reporting System for the Great Barrier Reef, DEWHA

Developed and managed implementation of a risk based environmental flow assessment method based on IFIM in numerous rivers, DIPWE.

Developed a regional method for environmental flow estimation in NE Tas, DIPWE

Project Director, Habitat-based Environmental Flows Project, DPIWE

Lake Crescent and Lake Sorell water balance modelling (Carp Management), DIPWE

Professional History

URS Australia Pty Ltd, Melbourne & Adelaide, 2002 - Present

Department Primary Industries, Water and Environment, Tasmania, 1991 - 2002

Hydro-Electric Commission, Tasmania, 1982 - 1991

Registration

Australian Water and Wastewater Association

International Association of Hydrological Sciences

Member American Geophysical Union

URS Australia Pty Ltd

Level 6, 1 Southbank Boulevard

Southbank VIC 3006

Australia

T: 61 3 8699 7500

F: 61 3 8699 7550

www.ap.urscorp.com

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