The Biodiversity Council welcomes the opportunity to provide feedback on Victoria’s approach to managing the biodiversity impacts of renewable energy, including the Draft Handbook for the development of renewable energy in Victoria (the Handbook) and the Discussion Paper - A better approach to managing the biodiversity impacts of renewable energy (the Discussion Paper).

The Handbook has been developed to provide detailed guidance on how to best manage biodiversity impacts while facilitating renewable energy development and to inform planning and environmental assessment requirements under the Planning and Environment Act 1987 and the Environment Effects Act 1978. The Handbook primarily focuses on the biodiversity impacts from the operation of wind turbines on birds and bats.

In the Biodiversity Council's assessment we found that the approach is not a significant improvement from the current approach to managing impacts of bird and bat collisions with wind turbines. In our submission we outline our concerns and recommendations that would deliver better outcomes for managing impacts of bird and bat collision with wind turbines and provide greater clarity to proponents. We seriously doubt the new approach will deliver “no net loss” and we cannot see any method by which no net loss is guaranteed unless the government embarks on a series of population viability analyses for vulnerable taxa.

Our submission presents key concerns and recommendations in the following areas:

• Determining biodiversity risk
• Managing biodiversity risk
• First Nations