Key documentary issue

K15aa Background Sound Record

The reference-location record for the southern noise-sensitive receiver group associated with the Elaine section of the Lal Lal Wind Farm.

Record pathway

How this evidence page should be read

This page applies the record method explained in the Framework and Documentary Verification pages: identify the governing requirement, trace the disclosed record, and allow the reader to test the documentary pathway.

Technical terms used here are explained once in the Glossary, including background sound, Noise Compliance Testing Plan, NZS 6808:2010, commissioning and Freedom of Information.

Plain English

Why K15aa matters

K15aa is not presented as a single-dwelling issue. It is presented as a reference location within the endorsed noise compliance framework for the southern noise-sensitive receiver group. Individual receiver references, including J14aa, are included only where they appear in source documents or are needed to explain the methodology.

Fact

K15aa was a reference location used in the documentary record for background sound relationships and operational noise limits.

Why it matters

Background sound is a foundation for operational noise limits. The NZS 6808:2010 definition refers to measurement before wind turbines are installed.

Evidence

The detailed record is in Annex A, the Supporting Record, the NCTP, DTP and Council FOI material, and the Documentary Verification Schedule.

Pre-construction acoustic assessments

The K15aa background record should also be read with the earlier pre-construction acoustic pathway. The Sonus assessment and AECOM peer review identify the Marshall Day background material, while later SLR documentation expressly records the K15aa background-data qualification and supplementary monitoring.

Open pre-construction pathway

Concise documentary summary

Key documented points

Issue	Concise record	Evidence
Planning Permit / NZS location definition	Condition 23(a) requires wind farm sound levels to be determined in accordance with NZS 6808:2010 at noise sensitive locations “as defined in the Standard”. The NZS definition includes any point within the notional boundary of relevant buildings; the Standard separately defines the notional boundary as 20 metres from the dwelling or other building used for a noise sensitive activity, or the legal boundary where this is closer.	Planning Permit Condition 23(a); NZS 6808:2010
NZS definition	Background sound is addressed by reference to the A-frequency-weighted L90 centile level measured before wind turbines are installed in an area. The Standard is used as source material only and is not reproduced on this website.	NZS 6808:2010; Annex A; Verification Schedule
NZS definition – Notional boundary	A notional boundary is described as a line 20 metres from any side of a dwelling or other building used for a noise sensitive activity, or the legal boundary where this is closer to such a building. The Standard is used as source material only and is not reproduced on this website.	NZS 6808:2010; NCTP; Annex A; Verification Schedule
October–December 2017 second survey	The monitor was relocated to the front / eastern side of the dwelling, identified as the only alternative position in accordance with NZS 6808:2010. The second-survey data was still recorded as affected by local sources and not suitable for deriving noise limits or assessing post-construction compliance.	Marshall Day Background Noise Monitoring Report; Annex A
NCTP pre-operation requirement	The NCTP recorded that, before commencement of operation, an updated background noise report was to be submitted to the Responsible Authority detailing the K15aa monitoring results.	NCTP; Annex A; Verification Schedule
1 December 2022 SLR letter	SLR recorded the operator's position that pre-construction baseline monitoring at K15aa was completed in approximately October 2018. This is recorded in the record as part of the K15aa chronology for the southern receiver group.	SLR Elaine Wind Farm – Noise Compliance letter; Annex A
October 2024 operator correspondence	The Beneficiary identified the February 2021 SLR K15aa Baseline Noise Monitoring Report and asked the operator to verify the updated background report submitted to the Responsible Authority before operation. The operator had stated that all reports required under the planning permit were submitted to the relevant authority.	Operator correspondence, 14–15 October 2024; NCTP; DTP FOI CS015467
DTP custody	DTP is the Responsible Authority for the permit noise compliance framework. In FOI CS015467, DTP advised it did not locate documents recording submission of the February 2021 SLR baseline report and stated that baseline studies are typically background input material not generally provided to the Department.	DTP FOI CS015467; Annex D; SRAM
DTP Part 4 enquiries	DTP's supplementary clarification dated 4 August 2026 records that, following relevant enquiries, the Department was unable to locate any documents in response to Part 4 of FOI CS019200. Part 4 sought documentary authority for identified departures from the NZS 6808:2010 definitions of background sound level and notional boundary.	DTP FOI CS019200 decision and supplementary clarification
EPA FOI custody	The EPA FOI-100-2025 request also sought documentary material relating to the K15aa background sound record. The Notice of Decision does not identify a decision or released document specifically addressing that component of the request. The record records this as part of the documentary custody pathway for K15aa.	EPA FOI-100-2025 Notice of Decision; Annex A; Annex D

Reading discipline

How to read this page

This page gives the reader the essential pathway only. The detailed chronology, documentary reconciliation and agency custody analysis are contained in the Supporting Record and Analytical Memoranda, Annex A, Annex D and the Verification Schedule.

Source sequence

Documentary record

The K15aa pathway is best understood as a sequence of source documents. The extracts below are included to orient readers to the key documentary points. The full source documents remain available through the published document library.

1. Planning Permit Condition 23 — noise sensitive location as defined by NZS 6808:2010

Planning Permit Condition 23 requires operation of the wind energy facility to comply with NZS 6808:2010 at noise sensitive locations. Condition 23(a) makes the location requirement explicit: wind farm sound levels are to be “determined in accordance with the Standard at noise sensitive locations (as defined in the Standard)”.

NZS 6808:2010 defines a noise sensitive location as the location of a noise sensitive activity associated with a habitable or education space in a building not on the wind farm site. The definition expressly includes “any point within the notional boundary” of buildings containing the specified noise-sensitive spaces.

The Standard separately defines notional boundary as a line 20 metres from any side of a dwelling or other building used for a noise sensitive activity, or the legal boundary where this is closer to such a building.

Governing location pathway: Condition 23(a) directs the compliance assessment to the NZS location definition. Read with Item 4 below, the endorsed NCTP then records that operational measurements are to occur within 20 metres of the dwelling and as close as practicably possible to the background monitoring location. EPA's later correspondence reproduced the NZS notional-boundary definition and explained how the incorporated NCTP measurement-location pathway is treated under Regulation 131B.

Open Planning Permit Read NZS 6808 page Read NCTP page

Planning Permit Condition 23 extract requiring wind farm sound levels to be determined in accordance with NZS 6808:2010 at noise sensitive locations as defined in the Standard — Planning Permit Condition 23(a): wind farm sound levels are to be determined in accordance with NZS 6808:2010 at noise sensitive locations “as defined in the Standard”.

2. NCTP requirement for an updated K15aa background report

The Minister-endorsed Noise Compliance Test Plan recorded that K15aa data was not presented in the NCTP and that, before commencement of operation, an updated background noise report was to be submitted to the Responsible Authority detailing the K15aa monitoring results.

Open NCTP PDF Read NCTP page

Noise Compliance Test Plan extract recording the requirement for an updated K15aa background noise report before commencement of operation — NCTP extract: K15aa data not presented in the NCTP; updated background noise report to be submitted before commencement of operation.

Public professional statement

SLR Public Information Session — K15aa noise limit subsequently derived

In a public information session, SLR acoustician Gustaf Reuterswärd presented the Noise Compliance Test Plan and stated that it did not include a noise limit for reference location K15aa. The presentation slide records that K15aa was subsequently monitored and that an appropriate limit was derived by SLR.

Documentary significance: This is a public statement by the acoustician responsible for relevant SLR work. It is placed beside the NCTP requirement and later K15aa monitoring record so readers can compare the public explanation with the primary documents. The excerpt does not itself determine whether the later monitoring or derived limit complied with the Planning Permit, NZS 6808:2010 or the endorsed NCTP.

SLR Public Information Session excerpt — Gustaf Reuterswärd discussing K15aa and the later derivation of a noise limit by SLR.

Read the NCTP context Open Professional Standards context

3. Marshall Day second survey position for K15aa

The Marshall Day background noise report explains the relocation of the K15aa noise monitor for the second survey and records that the alternative position was identified as the only alternative position for placing the monitor in accordance with NZS 6808:2010.

Open Marshall Day report

Marshall Day extract describing receiver K15aa measurement data summary second survey — Marshall Day extract: second K15aa survey position and continuing statement that the second-survey data was not suitable for deriving noise limits or assessing post-construction compliance.

4. NCTP operational measurement location requirements and EPA regulatory context

The NCTP identifies K15aa as one of the preferred operational noise measurement locations and records that measurements are to occur within 20 metres of the dwelling and as close as practicably possible to the background monitoring location.

Open NCTP PDF

Read with Item 1: Planning Permit Condition 23(a) requires sound levels to be determined at noise sensitive locations “as defined in the Standard”. NZS 6808:2010 includes points within the notional boundary and defines that boundary by reference to 20 metres from the dwelling or relevant building, or the legal boundary where closer. EPA later reproduced that NZS definition and explained that Regulation 131B allows the incorporated NCTP to modify procedures in the relevant Standard, including where measurements are taken. The documentary question is therefore how the K15aa monitoring positions used in the later record are reconciled with that governing framework.

Noise Compliance Test Plan extract identifying K15aa as an operational noise measurement location and measurement siting requirements — NCTP extract: preferred operational measurement locations and siting requirements.

EPA correspondence explaining Regulation 131B, the Lal Lal Wind Farm Noise Compliance Test Plan and the NZS 6808:2010 notional boundary definition — EPA correspondence: Regulation 131B, the incorporated NCTP measurement-location pathway, and the NZS 6808:2010 definition of a notional boundary.

5. SLR 2021 supplementary baseline monitoring report

The SLR Baseline Noise Monitoring report records the 2019 noise survey details for K15aa, including that the monitoring campaigns were conducted by reference to the Planning Permit and NZS 6808:2010, and shows the 2019 monitoring location in relation to the two 2017 measurement locations.

Read with earlier evidence:

Item 1 records the Planning Permit requirement that sound levels be determined at noise sensitive locations as defined in NZS 6808:2010, together with the NZS notional-boundary definition.
Item 3 records the Marshall Day explanation that the second 2017 monitoring position was identified as the only alternative position in accordance with NZS 6808:2010.
Item 4 records the NCTP operational measurement-location requirements and EPA's later explanation of the notional-boundary and Regulation 131B pathway.

Open SLR 2021 report Open Annex A

SLR 2021 Baseline Noise Monitoring extract showing 2019 K15aa noise survey details and monitoring locations — SLR 2021 extract: 2019 noise survey details and K15aa monitoring locations.

6. SLR 2022 technical response and J14aa reference pathway

The 1 December 2022 SLR technical response explains that the endorsed NCTP nominates reference receptors surrounding the wind farm for which NZS 6808:2010 noise limits are determined from background noise monitoring. The response identifies K15aa as the relevant reference location for receptor J14aa and records SLR's statement that pre-construction baseline noise monitoring was completed at K15aa, with the relevant noise limits subsequently determined.

Read with earlier evidence:

Item 1 establishes the Planning Permit / NZS location-definition pathway, including the notional boundary.
Item 2 records the NCTP requirement for an updated K15aa background report before commencement of operation.
Item 3 records the Marshall Day explanation of the second 2017 monitoring position.
Item 4 records the NCTP operational measurement-location requirements and EPA's later regulatory explanation.
Item 5 records the 2019 SLR supplementary baseline monitoring and the relationship between the 2019 monitoring position and the earlier Marshall Day locations.

Open SLR 2022 letter Open Appendix H re-analysis

SLR 1 December 2022 technical response explaining that NCTP reference receptors use NZS 6808:2010 noise limits determined from background noise monitoring and identifying K15aa as the reference location for J14aa — SLR technical response, 1 December 2022: the NCTP reference-receptor pathway, NZS 6808:2010 noise limits derived from background monitoring, and K15aa as the reference location for J14aa.

7. October 2024 enquiry concerning submission of the updated K15aa report

The operator stated that all reports required under the planning permit were submitted to the relevant authority in accordance with the planning conditions. The Beneficiary then identified the February 2021 SLR K15aa Baseline Noise Monitoring Report, referred to the endorsed NCTP requirement, and asked the operator to verify the updated background report submitted to the Responsible Authority before operation.

Documentary significance: The correspondence connects the NCTP submission requirement, the operator's stated position and the later agency-custody record. It records a request to identify the report; it does not assert that no report existed.

Open correspondence Open correspondence context

8. Operational status during commissioning — CRG Minutes, 1 October 2019

The Community Reference Group Minutes dated 1 October 2019 provide a contemporaneous record of the operational status of the Lal Lal Wind Farm during the transition from construction to commissioning. The minutes record that construction of all turbines had been completed, while reliability testing and commissioning were continuing at Elaine.

This provides chronological context for the K15aa baseline monitoring pathway and the later compliance documentation addressed on this page.

Open CRG Minutes PDF Read Chronology

Community Reference Group Minutes extract dated 1 October 2019 recording that construction of all turbines had been completed and reliability testing and commissioning were continuing at Elaine — Community Reference Group Minutes, 1 October 2019: construction of all turbines completed; reliability testing and commissioning continuing at Elaine.

9. Administrative custody — DTP FOI decision, 1 October 2024

The Department of Transport and Planning Notice of Decision dated 1 October 2024 records a Freedom of Information request seeking the date on which the SLR Lal Lal Wind Farm Compliance Baseline Noise Monitoring Report 640.11872-R01 February 2021 was submitted to the Department, Minister or Responsible Authority.

The decision records that the Department did not locate documents relevant to the request and states that a baseline study is typically a background piece of work forming an input into a wind assessment and is not generally provided to the Department.

This provides administrative custody context for the February 2021 SLR Baseline Noise Monitoring Report and closes the K15aa documentary pathway from requirement, monitoring and reporting through to agency record custody.

Open DTP FOI Decision PDF Read FOI Register

Department of Transport and Planning FOI decision CS015467 extract recording that no documents were located regarding submission of the February 2021 SLR baseline noise monitoring report — DTP FOI CS015467, Notice of Decision dated 1 October 2024: no documents located relevant to the request for the date the February 2021 SLR baseline report was submitted to the Department, Minister or Responsible Authority.

10. EPA FOI-100-2025 documentary custody

The EPA Notice of Decision for FOI-100-2025 forms part of the documentary custody record for K15aa. The record notes that the request included documentary material relating to the K15aa background sound record. The disclosed Notice of Decision does not identify a decision or released document specifically addressing that component of the request.

Open EPA FOI-100-2025 Decision Read FOI Register

11. SLR Appendix H — K15aa baseline re-analysis, 20 September 2024

Appendix H records SLR's September 2024 reassessment of the K15aa baseline after commissioning records identified that limited wind turbine operation had occurred during part of the 2019 monitoring period.

The extract below records the original Marshall Day monitoring, the two 2019 SLR survey periods, the later discovery that early commissioning had already commenced, the operation of wind turbines during the monitoring period and the prediction methodology adopted for the reassessment.

Documentary reading note: This highlighted extract summarises why the reassessment was undertaken and the methodology subsequently applied. The complete Appendix H remains available for examination of the full analysis, figures and conclusions.

Open full Appendix H Open Technical Reports context

SLR Appendix H extract recording K15aa monitoring history, early commissioning, turbine operation and prediction methodology — SLR Appendix H, 20 September 2024: K15aa monitoring history, later identification of early commissioning and wind turbine operation during part of the 2019 monitoring period, and the prediction methodology adopted for the re-analysis.

12. Resonate peer review of the K15aa reassessment — 30 September 2024

Resonate undertook a peer review of selected aspects of the Stage 2 Post-construction Noise Monitoring Report, including the methodology used by SLR to reassess the 2019 K15aa baseline data.

The review records that commissioning activity during part of the 2019 baseline monitoring period was not known when the original K15aa baseline assessment was prepared. Resonate accepted the later reassessment methodology and recorded that the calculated effect on the K15aa baseline was very small — 0.2 dB or less — with a negligible effect on the Stage 1 and Stage 2 assessment outcomes.

Documentary reading note: This is a later peer review of SLR's 2024 reassessment methodology. It is not a contemporaneous verification of the original 2019 monitoring or of the information available when the original baseline assessment was prepared.

Open Resonate peer review Open Appendix H context

Resonate extract recording that commissioning information was not known during the 2019 K15aa baseline assessment — Resonate, 30 September 2024, page 2: commissioning activity during part of the 2019 K15aa monitoring period and the statement that this information was not known during the original baseline assessment.

Resonate extract addressing the K15aa reassessment methodology and stated effect of 0.2 dB or less — Resonate, 30 September 2024, page 6: peer-review comments on the K15aa reassessment methodology and the stated effect of 0.2 dB or less.

13. DTP FOI CS019200 — documentary authority enquiries

Part 4 of DTP FOI CS019200 sought any document, instrument, statutory provision, ministerial determination, approval, delegation or written authorisation relied upon by DTP as permitting or authorising identified departures from the NZS 6808:2010 definitions of background sound level and notional boundary.

On 4 August 2026, DTP issued a supplementary clarification to its 17 July 2026 decision. The Department stated that, following relevant enquiries, it was unable to locate any documents in response to Part 4.

Documentary position: This records the outcome of DTP's statutory disclosure searches and forms part of the administrative reconciliation of the K15aa pathway. It does not, by itself, determine whether an authority existed elsewhere, whether a departure occurred, or the legal or compliance consequences of the disclosed record.

Open 17 July decision Open 4 August clarification Open FOI Register

14. External DTP clarification — monitoring methodology, 12 August 2026

A Department of Transport and Planning Energy and Infrastructure Assessment response dated 12 August 2026 was later supplied to the Beneficiary by a third party. The response concerned the planning framework for pre-construction background noise assessment for another proposed wind energy facility and is published here only for the Department's stated position on the governing methodology.

DTP stated that the planning-permit application requirements under Clause 52.32 require a pre-construction predictive noise assessment conducted in accordance with NZS 6808:2010. DTP further stated that the Victorian Wind Energy Facility Turbine Noise Guideline does not supplement the requirements in Clause 52.32 and NZS 6808:2010, and that the Guideline instead provides additional guidance and information relevant to the planning-permit process.

When asked whether representative monitoring methodology derived its authority from another legislative or policy mechanism, DTP stated: “The monitoring methodology is set out in NZS 6808:2010.”

Documentary significance for K15aa: This later DTP position is read with Items 1–4 above. Condition 23(a) directs the compliance assessment to noise sensitive locations “as defined in the Standard”; NZS 6808:2010 contains the location and representative-monitoring methodology; and the endorsed NCTP records the project-specific operational measurement pathway, including measurements within 20 metres of the dwelling. The DTP response does not determine the application of Regulations 131BB or 131BC to the Lal Lal Wind Farm record and expressly directs questions about the EP Regulations to EPA.

Open redacted DTP clarification Read NZS 6808 framework Read NCTP

NZS 6808:2010 source note: This page reproduces only the limited definitions and terminology necessary to explain the location pathway expressly incorporated by Planning Permit Condition 23. The Standard is otherwise treated as source material and is not reproduced in full on this website.

Source documents

Primary source documents

This page is a guide. The detailed record remains in the executed documents and source material.

Government and regulatory record

Agency Records

The record includes a public gateway to the documentary records of EPA Victoria, the Department of Transport and Planning, Moorabool Shire Council and the Australian Energy Infrastructure Commissioner. Agency pages present the correspondence, Freedom of Information material and source documents currently available within the record.

Open Agency Records

June 2018 Sonus prediction and the later K15aa record

The June 2018 Sonus assessment S5464C11 lists K15aa among the residences considered in the planning-stage predictive assessment. Later SLR correspondence refers to the Sonus prediction for K15aa.

This predictive record is distinct from the later background-monitoring and post-construction compliance pathway. The formal PCNA and Environmental Auditor verification material identifies the Marshall Day/NCTP pathway rather than Sonus as the technical assessment used for those processes.

Sonus documentary guide Open Sonus report

Later management document

K15aa and the October 2022 NMP

The October 2022 NMP identifies the Marshall Day background monitoring report and NCTP within its stated background-noise pathway. The later SLR K15aa Baseline Report dated 16 February 2021 is not identified in that NMP reference framework.

Open NMP documentary guide

Subsequent procedural record

26 July 2026 professional clarification opportunity

K15aa, the authorising basis for the background-noise dataset and representative monitoring were among the matters included in the Trustee's later procedural-fairness Notice to the SLR Technical Director. The response status is recorded in Operational Correspondence.

Open procedural record

Further documentary development

EPA regulatory-position reconciliation notice

On 16 July 2026, the Trustee issued a Notice to the Chief Executive Officer of EPA Victoria requesting identification of the documentary pathway by which EPA reconciles its current regulatory position with the governing statutory and planning framework concerning K15aa.

The Notice draws together the Planning Permit, endorsed NCTP, NZS 6808:2010, EPA correspondence and the statutory-disclosure record. It records a procedural request for documentary reconciliation and does not itself make a compliance finding.

Open Notice