Summary of Site Selection Process Paper

The New Eastern Terminal Proposal

The Site Selection Process

THE NEW EASTERN TERMINAL PROPOSAL

What's changed - how is the new ET proposal different?

From 1998 to March 2008, Western Power has consistently outlined plans for an Eastern Terminal substation. This would be constructed in stages, the first stage being a switchyard requiring 4 hectares of land. Over time the facility would be developed into a full 20 hectares for a substation with transformers and additional transmission lines, as described elsewhere on this site.

In the Western Power workshops in Kalamunda in October 2007, on their website and in numerous publications, media statements and statements by the Minister for Energy, it was explained that the purpose of the Eastern Terminal substation was to serve expected development and meet growth in demand for power in the metropolitan area. The community was told that the facility was not specifically for the Hills area.

Suddenly, Western Power has announced that only a switchyard is required, and that the need for development into a full substation is extremely unlikely. The reason given is that expected land development and electricity load forecasts for the Hills region do not indicate the need for a substation. The basis for planning appears to have been dramatically changed.

However, even though a switchyard only requires 4 hectare of land, Western Power still intends acquiring 20 hectares (the area required for a full terminal substation).

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Why has Western Power made this change?

We can only guess. Western Power has offered no rational explanation. Has Western Power's planning over the past 10 years been wrong? It's inconceivable that their comprehensive planning could get it this wrong.

But we can speculate. The community workshops in October 2007 were a community relations disaster for Western Power. Since then, community opposition to an Eastern Terminal substation has been fierce. Has Western Power suddenly changed the purported basis for its planning in an attempt to abate community opposition?

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Should we believe Western Power?

NO! Why not?

Over the past ten years Western Power’s flip-flop planning has been erratic and inconsistent, and appears to be based on unreliable planning data and assumptions. There has been inconsistency concerning (a) the need for an Eastern Terminal facility, (b) its location, and (c) whether it should be a substation or a switchyard.

In summary:

  • 1998: Long range planning indicated that the construction of an Eastern Terminal substation located in Hacketts Gully was necessary.  Extensive negotiations with Hacketts Gully residents ensued.
  • 2002: The 1998 plans were abandoned. “Following a review of the long term electrical load requirements for the east metropolitan area...a terminal substation will no longer be required at Location 3897 Mundaring Weir Road, Hacketts Gully. We also have no intention to acquire an alternative site in areas close to Hacketts Gully...” (9 May 2002 Letter to Hacketts Gully residents from Western Power).
  • Mid 2007: The 1998 plans were resurrected. Contrary to the 2002 letter, Hacketts Gully residents were advised that an Eastern Terminal substation located in Hacketts Gully was necessary.
  • October 2007: Kalamunda community forums were told that of eight available options, one option (Option 6 – the Eastern Terminal substation) must be constructed, but its location could be anywhere in a broad study area east of Kalamunda. The planning basis for the substation was explained by the Minister as follows: "The Eastern Terminal substation is proposed as part of the transmission network reinforcement program to improve power supplies and meet the forecast growth in demand for electricity within the whole of the Perth metropolitan area". (Minister's reply on 14/11/07 to questions in the Legislative Assembly).
  • 7 February 2008: Media release announced that it had now been determined that two terminal substations were required: the South East Terminal at Byford (Option 1) and the Eastern Terminal (Option 6). The Eastern Terminal substation was now less urgent and would be delayed by four years, and the South East Terminal substation would be built first.
  • 15 May 2008: Revised website states that an Eastern Terminal substation is not required, but a switchyard is: “current electricity forecasts indicate that it is extremely unlikely that the switchyard would be developed into a substation”. The planning basis is changed, and is now focused on land use in the local area and electricity load forecasts for the hills region.

Western Power’s Eastern Terminal planning is now totally lacking in credibility and cannot be believed.

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So why does Western Power need 20 hectares of land?

Good question!

While a switchyard only requires 4 hectares, Western Power wants to acquire 20 ha of forest – the area required for a 2007-style full blown substation. In assessing the proposal, we must assume that a full substation may eventually be built – even though Western Power say they don’t intend doing so at this time. Otherwise, why would they wish to acquire 20 ha?

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Why has Western Power sent their letter to so many people and organisations in Kalamunda, Mundaring and Roleystone?

Western Power’s 2007 proposal for an Eastern Terminal substation had the potential to result in massive forest clearing (400 hectares or more) and a web of new transmission lines, which might affect people in those localities. But most residents were not informed at that time. We complained about this on your behalf. The result is that Western Power is starting again and improving their process by expanding the range of stakeholders contacted.

THE SITE SELECTION PROCESS

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What is the proposed process?

In essence, there would be four steps:

  1. Western Power's consultants (ERM) would select a number of site options within the study area. This selection would be based on previous research including the analysis of sustainability principles and constraints. Options would be evaluated in terms of technical, economic, environmental and social criteria (‘Sustainability principles’) and ‘feasibility criteria’. Certain areas would be ‘no-go’ areas and excluded from consideration. These include Reservoir Protection Zones (RPZ), National Parks, a Perth Observatory buffer area, and a residential property buffer area (but these buffer areas are not defined).
  2. ERM would prepare a site options paper showing the identified site options and the reasons for their selection.
  3. The site options paper would be made available to stakeholders. Stakeholders would have 4 weeks to comment. During this 4 week period ‘information sessions’ would be held to explain the sites selected.
  4. The results would be analysed by Western Power and ERM and a final site selected.

At the conclusion of the process, information sessions would be held to explain the final site decision.

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What’s wrong with the process? 

  1. Many stakeholders were not involved in the exercise last year, as they were not invited to the October workshops. Gaining an understanding of the whole story (the switchyard, planning assumptions, the gantry, upgrade of the line from Boddington, future developments, implications for the environment, the landscape, people’s properties and businesses, etc) is essential before one can sensibly consider Western Power’s proposals. The site selection paper provides no information on most of these questions. It is essential that open information sessions be conducted as soon as possible – certainly before the closing date for submissions (June 16). Without this, Western Power’s consultation process will be deeply flawed. The SETS Group understands that such meetings have been avoided by Western Power as they don’t wish to expose themselves to the community opposition encountered last year.
  2. In most cases it will not be possible for Local Governments and other organisations to respond. Most have a monthly meeting schedule; a response period of around three weeks does not enable the matter to be researched, listed on agenda papers, considered at a scheduled monthly meeting, and a response prepared. No less than two months is required. The present deadline of June 16 will automatically exclude many or most organisations, particularly as the letters to organisations were not received until May 22 or later.
  3. A fundamental flaw is that the proposed process does not apply sustainability principles to the decision concerning the location of an Eastern Terminal in the Hills area. The whole process is based on an extraordinary contradiction: Western Power proposes applying sustainability criteria to the selection of a site, but only technical and cost factors were considered for the overall project. Environmental and social factors have not been considered at all. 
    In the absence of any consideration of sustainability principles in the decision to locate an Eastern Terminal in state forest in the study area, the site selection process is not legitimate. To say that sustainability principles are important for site selection, but not for selection of the study area, is absolutely hypocritical.
  4. Western Power intends using numerical ratings derived from participants’ responses at the Kalamunda workshops in October 2007. Because those present were not representative of the full range of stakeholders Western Power has now approached, and given the way in which each of the workshops turned into a protest session, the quality of any numerical data derived from those ratings would be very suspect. To apply such wonky numerical data to the new exercise would simply be wrong.
  5. The Action Group believes that, apart from Hacketts Gully, there are no other genuine site options. In other words, this whole “site selection exercise” is a sham. (The evidence for this is outlined in other sections of this website.)
  6. Western Power will receive and analyse people’s comments, “and the site selection process [will be] adjusted if necessary”. We won’t know what the community has said. There is no guarantee that community feedback will genuinely be taken into account. Good practice – and trust – require that truthful feedback is provided to the community.
  7. Western Power has listed the criteria they intend using in the identification of site options. (Their criteria are listed in Table 3.1 on p 9 of the site selection paper). Western Power’s criteria do not reflect the views of the community at the October workshops. It is obvious that Western Power’s criteria have been devised to suit their intentions. Their application would render virtually any technically feasible site in the study area “acceptable” – ie the “impacts” would not be a problem.

The question is whether the “definitions” of ‘high’, ‘medium’ or ‘low’ impact in this table are reasonable.

There are too many criteria in the list to deal with in detail. The following are the most important:

(a) Water Catchment. The community’s strong view is that an Eastern Terminal must not be built in P1 or P2 water catchment areas. The paper lists P1 catchment as ‘high impact’ and P2 as ‘medium impact’. P1 and P2 catchments must be ‘no go’ areas.
(b) Habitat protection/clearing impact. The paper lists total clearing of more than 25 ha as ‘high impact’ and less than 10 ha as ‘low impact’. The community’s view is that any substantial clearing of state forest would be unacceptable. A substation could involve total clearing of less than 10 ha – so it would be regarded as ‘low impact’! Any area in excess of 2 ha must be ‘high impact’. This must include clearing for transmission lines.
(c) Impact on existing businesses and residences; Noise and vibration. Any location closer than 2 km must be ‘high impact’. Imagine what it would be like to have a switchyard, and possibly later a substation, close to your house, orchard, vineyard or business.
(d) Impact on recreational areas such as picnic sites, parks, walking trails and mountain bike trails. Only if the ET location is less than 500 m from such areas is the impact rated in the table as ‘high’. But people walk into the forest from picnic areas. Any location closer than 2 km from such areas must be ‘high impact’. (Incidentally, the site in Hacketts Gully that was selected by Western Power in mid 2007 is traversed by the Kalamunda Circuit (a mountain bike trail) and the Munda Biddi Track.)
(e) Reserved lands. National Parks are listed as ‘no-go’ areas. But Regional Parks (eg Darling Range Regional Park) are ‘high impact’. Regional Parks must be ‘no-go’ areas – for a switchyard/substation and future transmission lines.

Location adjacent to a National Park or Regional Park, or within State Forest, is rated ‘medium impact’. The very strong view of the community is that all these areas must be rated ‘absolute impact’ ie ‘no-go’.

All these criteria are a matter of personal judgement. Please review the table and make your own assessment – and comment accordingly.

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What comments should I submit to Western Power

As a minimum, we urge you to insist that:

  1. Open meetings are held as soon as possible, and well before the closing date for submissions, to enable the community to be properly informed.
  2. The comment period is extended to at least 2 months.
  3. Sustainability principles are also applied to the question of whether an Eastern Terminal should be located in this study area (ie not just cost and technical factors).
  4. A complete review of the criteria listed in Table 3.1 occurs, using community workshops to enable open discussion of the criteria.
  5. Western Power publishes an accurate account of community members’ comments.
  6. And add your own particular concerns.