A significant shift for the state's wind energy sector 7 min read
From 3 February 2025, wind farm developments in Queensland will transition from a code assessable to an impact assessable application process, introducing a more rigorous assessment process. This shift reflects the Queensland Government's growing concerns over environmental impacts and community opposition and marks a significant change for the state's wind energy sector.
The revised State Code 23: Wind farm development (v.3.2) (Updated Wind Farm Code) introduces updated requirements, including stronger community engagement obligations, agricultural land protections and new infrastructure and decommissioning provisions. These updates aim to provide a more structured approach to managing the potential environmental, community and infrastructure impacts throughout the lifecycle of wind farm projects.
In this Insight, we explore the additional assessment requirements, including expanded public consultation and a broader technical review, and outline the key considerations for developers, investors and government bodies amid increased scrutiny, public engagement obligations and regulatory hurdles.
Key takeaways
- Wind farm developments in Queensland will now undergo impact assessment, leading to heightened technical scrutiny, public consultation and appeal rights for submitters.
- The transition from State Code 23: Wind farm development (v.3.1) to the Updated Wind Farm Code marks a notable policy shift, increasing regulatory scrutiny on wind farm development.
- The new requirements introduce enhanced environmental protections, agricultural safeguards and community engagement obligations.
- Infrastructure obligations have been expanded, including:
- road and transport measures to mitigate impacts on local road networks during both construction and operation, ensuring safe and efficient transportation of wind farm components and materials throughout the project lifecycle.
- financial security for decommissioning, requiring developers to provide bonds or financial guarantees to ensure the timely rehabilitation of sites and removal of infrastructure at the end of the wind farm's operational life.
- stronger community engagement requirements, including the submission of a Workforce Accommodation and Infrastructure Report to assess impacts on housing, services and local infrastructure, with a focus on consulting with local governments regarding workforce accommodation strategies and their impact on the community.
- The Queensland Government has also signalled future regulatory changes that may apply similar impact assessment requirements to large-scale solar farms and other renewable energy projects, suggesting a broader policy shift.
Changes to the assessment process
The Planning (Wind Farms) Amendment Regulation 2025 (Qld) (Amendment Regulation) effective from 3 February 2025, raises the assessment threshold for wind farms from code assessable to impact assessable,.
The shift follows the Ministerial Direction issued by the Honourable Jarrod Bleijie MP, Deputy Premier, Minister for State Development, Infrastructure and Planning, and Minister for Industrial Relations on 16 January 2025, which suspended assessments for the Wongalee, Theodore and Bungaban Wind Farms. The Queensland Government says this change is intended to bring wind farm developments into line with the approval processes required for major development projects, reinforcing its commitment to robust environmental and community impact assessments.
The increase to impact assessment represents the highest level of scrutiny under Queensland's planning framework. Wind farm projects will now:
- require more comprehensive technical assessments
- have expanded public consultation requirements
- be subject to appeal rights for submitters, which now apply to wind farm projects subject to impact assessment (and were not available under code assessment).
Wind Farm Code: key amendments
The Amendment Regulation introduces the Updated Wind Farm Code, which imposes updated assessment criteria for wind farm development applications.
Table 1: Key amendments in the Updated Wind Farm Code
| Key change | Wind Farm Code | Commentary |
| Purpose statement |
Revised purpose statement explicitly highlights the potential for adverse impacts, and emphasises the need to demonstrate that development does not result in unacceptable adverse impacts. Specifically includes:
|
The Updated Wind Farm Code emphasises greater community consultation, local government engagement and the need to demonstrate effective mitigation of adverse impacts through specific assessment parameters. It introduces a more detailed focus on the siting of developments near sensitive areas and integrates a lifecycle approach, covering all stages of development, including decommissioning. |
| Agricultural land protection | PO5: requires that wind farm development must ensure there is no significant loss of high-quality agricultural land values. This includes a focus on avoiding or minimising impacts on high-quality agricultural land, aligning with State Planning Policy definitions. | The Updated Wind Farm Code introduces the requirement for an Agricultural Land Assessment Report to be submitted as part of the application. This report must demonstrate that the development does not result in a significant loss of high-quality agricultural land values, identifying the land’s suitability for agricultural production and ensuring alignment with the State Planning Policy definitions. It includes an assessment of soils, land suitability and agricultural potential. |
| Workforce accommodation |
PO16: on-site workforce accommodation associated with the construction of the wind farm must not result in adverse impacts on surrounding communities and townships, such as overburdening services and community facilities. PO17: off-site workforce accommodation associated with the construction of the wind farm must not result in adverse impacts on surrounding communities and townships, such as overburdening services, housing supply and community facilities. |
The Updated Wind Farm Code requires applicants to submit a Workforce Accommodation and Infrastructure Report that details both on-site and off-site accommodation options. It includes an assessment of potential impacts on housing supply, community services and local infrastructure. Developers must assess and address the impacts of workforce accommodation on local communities and services, including commuting distances, housing demand and pressure on community facilities. The Updated Wind Farm Code places greater emphasis on consultation with local governments regarding workforce accommodation strategies and their impacts. |
| Infrastructure |
PO23: explicitly states that impacts of the development on infrastructure and services, including social infrastructure, communications networks and essential infrastructure, must be identified. Furthermore, measures to manage, mitigate and remediate any impacts must be undertaken:
|
PO23 requires wind farm developers to assess and mitigate the impact of their development on both essential infrastructure (such as water, waste, electricity and communications networks) and social infrastructure (such as healthcare and emergency services). The Workforce Accommodation and Infrastructure Report is a critical document in this assessment, detailing:
|
| Community impact | PO26: developers must identify, assess and mitigate impacts on local communities, ensuring that any adverse impacts are avoided. The mitigation strategies are explicitly required to address community concerns. This requirement reflects a proactive approach to handling community impacts. |
PO26 requires wind farm developers to identify, assess and mitigate impacts on surrounding communities and individuals. The key practical changes introduced by this Performance Outcome are:
|
| Decommissioning | PO30: introduces a requirement for developers to provide financial security mechanisms (eg bonds or financial guarantees) to ensure timely compliance with decommissioning obligations. | The Updated Wind Farm Code requires the preparation of detailed decommissioning plans after the completion of construction and the commencement of operations, as well as at the end of the project’s operational life. These plans must outline how decommissioning activities will ensure no adverse impacts on individuals, communities or the natural environment. Typically, this involves measures to ‘make good’ the land and remove infrastructure. A key addition in PO30 is the requirement for applicants to provide evidence of financial security (such as bonds or financial guarantees) to ensure timely compliance with decommissioning obligations. This aims to mitigate risks and ensure the decommissioning process is completed efficiently, with minimal impacts on landowners and government. |
The effects of the new assessment regime
- Existing development applications: wind farm development applications lodged before 3 February 2025 will continue to be assessed under the framework that applied at the time of lodgement.
- New development applications: all new wind farm applications lodged from 3 February 2025 onwards will be subject to impact assessment and must comply with the Updated Wind Farm Code. This means greater technical scrutiny, public consultation and increased regulatory obligations.
- 'Other change' applications: if a change to an existing development approval is classified as an 'other change' under the Planning Act 2016 (Qld) (Planning Act), it may trigger a new assessment under the Updated Wind Farm Code.
- Suspended projects: the Ministerial Direction issued on 16 January 2025 has temporarily paused assessments for the Wongalee, Theodore and Bungaban Wind Farms until 16 May 2025. The assessment pathway for these projects will be confirmed once the suspension period concludes.
- Potential for Ministerial call-in: the Planning Act provides discretionary call-in powers, allowing the Minister to assess or reassess development applications where a state interest is identified. If a project is called in:
- the Minister may determine which assessment benchmarks apply, including the possibility of applying the Updated Wind Farm Code.
- appeal rights available under standard development assessment processes do not apply, with judicial review being the only available legal avenue.
Next steps
Developers, investors and government bodies will need to navigate increased scrutiny, public engagement obligations and regulatory hurdles.
Key considerations moving forward:
- Regulatory preparedness: developers should carefully review the Updated Wind Farm Code to ensure their projects meet the new planning and environmental benchmarks.
- Engagement strategies: with heightened public consultation requirements and new appeal rights for submitters, early and proactive engagement with stakeholders is essential to mitigate risk.
- Financial planning: the new financial security obligations for decommissioning and site rehabilitation will require developers to assess funding provisions at the outset.
- Monitoring Ministerial intervention: the existing Ministerial Direction and call-in powers add further complexity. Developers should closely monitor regulatory developments and be prepared for increased scrutiny of wind farm projects.
- Future regulatory changes and community benefit framework: The Queensland Government has signalled its intent to expand impact assessment requirements to other renewable projects, including large-scale solar farms, while introducing a community benefit framework. Renewable energy developers should prepare for additional scrutiny on future projects, which may require demonstrating local economic benefits, job creation, or infrastructure investment as part of the approval process, similar to other major development projects in regional communities.
The evolving regulatory landscape for wind energy and other renewable projects in Queensland requires strategic planning, legal awareness and other proactive stakeholder engagement. For further advice or detailed information regarding the new planning framework and its implications, please reach out to any of the listed contacts.