MOD 2 - Project Layout Changes

Please find attached a letter from Independent Member for Wagga Wagga, Dr Joe McGirr

16th May 2022
Department of Planning
Objection to Walla Walla Solar Project modification

I lodge my objection to the project based the same grounds as my original objection quoted below but with additional neglect for the considered, consulted approval by the community by adding works not well considered in the primary application.

‘Genuine Social Licence’ based on genuine community equity and expectations, based on
real community acceptance and inclusion within ‘top down-bottom up decision making’,–based on real
benefit sharing for the community and respect for the physical and mental wellbeing of the community.

There are a set of protocols developed for the Responsible Energy Development in New England. As such the broad definitions like Genuine Social Licence apply to Renewable energy development across the nation.
Protocol 1 refers to genuine social licence.
My well-considered view is that the prospectors for Walla Walla Solar project have adopted a widely utilised strategy to selectively inform residents, hosts, and neighbours to effectively split the community. Once the community is fractured they proceed to selectively inform individuals of ‘select’ information that has no real basis of truth. Therefore the subsequent information is in conflict to the original advice and information between residents, is flawed, inconsistent and disempowering. We understand how debilitating these actions are on individuals, causing stress, distress and a whole range of mental health issues for constituents.
The degree of mental health impact imposed upon the residents within the Walla Walla project is indicative of fabrication, bullying and misrepresentation of the truth facilitated by a lack of conclusive research to reveal the real outcome over the lifetime of the project. Policy clearly says the infrastructure is to be placed where it is accepted. It cannot be accepted on the basis of lies and lack of evidence as a substitute for genuine approval.

An application lodged after the initial application is evidence of deliberately withholding an intent from the original application. From my experience this activity can be deliberately excluded from the original application, because it may have jeopardised that application. It seems as it is a “soft application”, to swing off the original and merely vary the size, the additional clearing and the additional roadworks in a subsequent application. Has the company seen this as an easier pathway to achieve their goal, being one that side steps their intent from the community consultation processes.


Yours sincerely
(Mrs) Beth White

RE: Walla Walla Solar Farm-Mod 2
To Whom It May Concern:
I respectfully submit that I object to the Project. The area where the Project is proposed is excellent farming/agricultural land, and more consideration must be given to developments that have the potential to impact Australia's productive agricultural areas. Better State and Federal Government planning and regulation around renewable energy developments needs to be put in place before projects such as this are allowed to proceed.
Additionally the Project is located in catchment for the Murray River: Back Creek & Middle Creek are ephemeral tributaries of Billabong Creek traversing the site. The proposed construction of an additional vehicle crossing over Back Creek within the project site, and the clearing of an additional 0.137 ha of native vegetation, to accommodate this crossing will have potential for detrimental impacts and pollution to the Murray catchment area, as well as negative impacts on flora and fauna in the Project area.
I also object to the proposed increase in the solar array and development footprint, of approximately 15.4 ha, within the existing project boundary = a further 50,000 Solar panels - Totalling 700,000. This significantly increases the potential risk of leakage/site contamination from faulty or damaged solar panels. Hailstorm damage is an example - there are documented cases of severely damaged panels and environmental contamination from hailstorms: https://www.pv-magazine.com/2021/03/19/storm-season-has-the-us-solar-industry-looking-to-protect-assets-from-costly-hail-damage/ . Further to this, the fire risk and danger of toxic air pollution from fires onsite is highly concerning. Fire Brigades are told to completely avoid the carcinogenic, Teratogenic Smoke Hazard & only attempt to fight Solar & BESS fires from the perimeter as they are highly toxic.
An increase in the peak daily total number of heavy vehicle numbers accessing the site from 45 to 110 is another modification to the Project that I object to. This more than doubles the amount of vehicle traffic, thus increasing risk of vehicle accidents, loss of local fauna to vehicle strikes, and also air and noise pollution in the local area from increased traffic.
Overall, I feel that the potential long-term cumulative impacts from this Project will be disastrous for not only the local flora, fauna and farming communities, but the the entire local area, and Murray River Catchment.
Finally, Walla Walla Solar should be subject to conflict of interest investigations. The original Planner & Environmental
Assessment Officer, Rob Beckett, suddenly (within approx 4 - 6 weeks) changed jobs, and began engaging with local objectors as FRV's Solar Project Developer Manager.
He had previously told locals that the DPIE did not have the resources to do the research into the detrimental impacts raised - they were just trusting the developers...
This is a typical example of the "revolving door policy" that seems to plague Environmental Assessment departments everywhere - local officers are offered lucrative jobs with Developers and suddenly approach Projects like the above from the other side of the fence. This destroys public trust in the system of assessment, and can only lead to further compromise of environmental values in areas where such projects are allowed to proceed.
I respectfully submit the above without ill-will, vexation, or frivolity.
Regards
Allan Hayward
16 May 2022

7th of April 2022
Dear DPIE
I would like to object to the

* I object to the visual pollution of the view shed from an important local business Orange Grove Gardens Wedding Venue. This will heavily impact their future viability, as no one will want a wedding overlooking acres of black glass. It is already an offensive imposition on the outlook from neighbour's properties as it stands, and further destruction of the local asthetic appeal is unnacceptable.


* An increase in Solar panels means further contamination of land/water in the vital Murray River catchment during operation of the Solar Works. This is a vital issue being omitted in assessments for renewable energy installations to date. Minister Ley has admitted (see below) that the panels pose a huge environment threat to our precious soils.



*Increasing peak daily vehicle numbers from 45 to 110 is unacceptable. It goes against FRV's claims to reduce emissions & reliance on fossil fuels. Maybe the proponent should use a shovel, wheel barrow and man power to do the extentions! It will help the unemployment at the very least. Think, they built the pyamids by hand so this should be a piece of cake.


And in general, Australia wide,

Who is protecting our FOOD PRODUCING land?
These solar plant developments pose a real threat to our very rich soils and our ability to feed ourselves. ENERGY SECURITY + FOOD SECURITY = NATIONAL SECURITY. Federal Environment Minister Sussan Ley also acknowledges:- "Solar is a looming contamination disaster.... where dumped panels may leak heavy-metal chemicals .....contaminating the environment & our fragile soil." Then why has she not acknowledged the deterioration/storm damage of panels over time when standing on our prime food producing land? Most panels will have to be replaced for age reasons in the life on the solar plant also. We have plenty of poor quality country they can be built on.

How can Mr Beckett suddenly change jobs from Government to a Solar Company after approving this? Was his involvement in the approval linked to a special deal with this company? This is a very serious conflict of interest. Can you tell us how this being investigated? He would have known were he was going when making this decision for the DPIE.
These companies employ consulting agents to produce very convincing documents that support the development that are not always true. We have seen it with the company we are keeping to account on A grade food producing land near our property. You need to know all the facts before making any decision!
There needs to be an immediate stop to all renewable developments until proper rules and regulations are drawn up. Food producing land needs to be protected. In the UK they rate their land A,B,C,D or E. The top two ratings, on their soils are fully protected from any other use other than food production. They have gone hungry before. Why can't we learn from overseas? That goes for the pollution, Photovoltaic heat island effect and other problems they are experiencing which has now resulted in the reopening of mothballed coal fired power plants. It is very evident here in Australia that no research is being done into the ill effects of renewable industry and that there is another agenda operating here.
Regards CedricCreed

I strongly object to this proposal as its environmental impacts are devastating on the native plants and animals!!! This land is prime agricultural and contributes immensely to our national food bowl!!! These power plants belong in the non productive areas, the constant excuse used is the distance to the power transmission lines thus resulting in voltage loss!!! Well there is plans for a Northern Territory solar power plant to supply Singapore!!!! Corporations and government have had many great ideas asbestos, dildren,DDT,carp,cane toads,insulation just to name a few!!!!! These generating plants will be no different!!! Money over the environment!!!! Regards

SUBMISSION: Walla Walla Solar - MOD 2 - Project Layout Changes

As a fourth generation Australian farmer, I object to the proposed modifications of Walla Walla Solar Electricity Generating Works. The Greater Hume farming community is a highly productive area, and with food security more vital now than ever before, it is imperative that planning and approvals of renewable energy projects take into account the importance of safeguarding Australia’s irreplaceable arable land and water resources. There is compelling evidence that the proposed project will have lasting detrimental effects not only on the land, but also on water resources, flora, and fauna in the local area.
PLEASE SEE ATTACHMENT

Both my wife Anna and I would like to strenuously object to the clearing of an additional 0.137 ha of native vegetation, to accommodate this proposed extra vehicle crossing over Back Creek we have lost native vegetation on this site already, enough is enough If it’s deemed as an extra addon what more haven't they foreseen ? it just shows lack of proper planning from the start. What other parts of the site may they want to clear as time goes by ?
Please note our objection regarding this particular extra clearing and further loss of on site native biodiversity.


--
Stephen Grimes and Anna Grimes

This is terribly wrong, what is happening in our country, prime grazing land taken over by ugly toxic pollutants from solar and wind farms
Clearing of an additional 0.137ha of native vegetation, to accommodate this crossing.

An increase in the solar array and development footprint, of approximately 15.4 ha , within the existing project boundary = a further 50, 000 solar panels- totalling 700, 000 .
This is off the scale.

There needs to be an immediate independent inquiry into the disgraceful energy transmission is imperative. This rape of our pristine, prime grazing lands is criminal.
This is out of control.

I am disappointed with the changes put forward. They are not even slight changes. I'm a local and that road cannot handle that amount of traffic . The road can barely handle local traffic at the moment . The company are going back on their promises.

Development is taking more productive farmland.
Extension will disturb natural ecosystem.
Constant modifications are not in good faith. Its strenuous on local communities to keep on looking for their modifications and spend time preparing submissions. These extension are not in good faith to the original application and takes community for granted. Applicant does not value local community in which they operate.

My reasons for objection are - ;
The increase of the footprint of the solar plant takes away more valuable farming land. Valuable farming land should be protected. Farming is a viable industry for Australia. It supports farmers and related businesses. Solar works should be installed on land that is not viable for farming purposes. The applicant does have other solar works that are in Australia but did not provide evidence that this is occurring on their other solar works stations. The truth is that once solar works are installed, there will be no farming on the fertile land. It will be lost forever.
The new creek crossing construction will negatively impact native flora and fauna.
The issue of increased visual impact to the neighbouring properties (due to the increased footprint ) was not addressed adequately.
The increase in the number of Solar panels will cause increase in carbon production due to the carbon dioxide that is produced during the mining, transporting, and manufacturing process for the raw materials of solar panels to the installation of the panels into the ground

As per attached files

I strenuously object to the Walla Walla Solar Farm Modification SSD-9874-Mod-2 on behalf of the Orange Grove Gardens Wedding Venue. Who would possibly want to have their wedding overlooking 700000 solar panels. Even 500000 Solar Panels is a blight on the landscape and is very unacceptable.

This increase of solar panels also means further possible contamination of the soil and later contamination of the very important Murray River catchment area. They are now discovering that these panels are a huge enviromental threat during the life span of the Solar Farm as well as how to eventually dispose of them in the long term is even more of a concern.

The increase in the daily heavy vehicle numbers from 45 to 110 is also unacceptable. Are the roads up to standard? Will the roads be improved so they can accommodate this amount of transportation? This will also affect the serenity of the Orange Grove Gardens Wedding Venue.

*An increase in the solar array and development footprint, of approximately 15.4 ha, within the existing project boundary = a further 50,000 Solar panels - Totalling 700,000.
I object to the continuing erosion of agricultural land to a contaminating entity that can render the land useless for future food production - the whole renewable exercised is fraught with media generated fear that we are going to “FRY” in the next 50 years – the futility of present renewable push is that the energy that they produce will never cover the true cost of mining, manufacturing, transport and installation of 50,000 items plus and at least double the amount of batteries that are present as their life span is about 8/10 years and the panel mounts that will end up in council landfills leaving the contaminated land unfit for food production.

Dear Sir,
I wish to lodge a formal strong objection to the following aspects of the FRV's Walla Walla Solar Electricity Generating Works - Modification Plans.

1. *Construction of an additional vehicle crossing over Back Creek within the project site.

2. *Clearing of an additional 0.137 ha of native vegetation, to accommodate this crossing.

3. *An increase in the solar array and development footprint, of approximately 15.4 ha, within the existing project boundary = a further 50,000 Solar panels - Totalling 700,000.

4 *An increase in the peak daily total number of heavy vehicle numbers accessing the site from 45 to 110.

My objections are as follows:

Item 1, Additional vehicle crossings will result in further unacceptable disturbance and probable destruction of land areas associated with Back Creek. Re-establishment of original condition is both unlikely and impossible to return to original condition. Such destruction should simply not be undertaken in any form in the first place, it is not in keeping with environmental protection schemes.

Item 2, Clearing native vegetation is outrageous, it destroys native habitats, disrupts native flora growth and causes irreparable damage to native wild life in general. It is also destructive of the local environment and country vistas.

Item 3. An increase in the solar array of 15.4 ha is a criminal outrage against the country area presently used for agriculture. It is visually objectionable and is likely in the end to result in severe environmental pollution as arrays are dismantled following storm damage or end of life replacement. Such toxic pollution cannot be removed and the land is rendered useless. Further such a structure is a dreadful eyesore to the whole community both during construction when heavy vehicles wreck good land in accessing the site and ongoing when it is completed, it will be a blight on the landscape and should NOT BE BUILT especially with the widespread objection from local of other people.

Item 4, As mentioned above the increase in vehicle numbers will simply exacerbate an already objectionable situation.

I have a further general objection: As an engineer I submit to the project proponents that what you are planning is not fit for purpose and as such all work should be stopped immediately. It is not fit for purpose because no solar and/or wind system can provide steady regular reliable power, not now, not ever. Solar has a capacity factor of around 27%. There is no way such a system can replace fossil fuel or nuclear generation systems, no way, not now, not ever. The proponents of so call renewable energy (but it is not really, have you ever looked at the energy required to manufacture these systems?) suggest storage systems will provide fill-in supply. That too is not possible, not now, not ever. The biggest battery ever made is around 400 times too small to hold up the state of Victoria over one night. No battery is large enough to act as grid fill-in. The clincher is that storage has to be re-charged, no matter what technology is used. The grid capacity has to be double or tripled to do so, and even if that was built the whole system would fail under 2 weeks of inclement weather. Just not feasible.

The main objection to the whole project is that IT IS NOT FIT FOR PURPOSE -- simple!!

Yours Sincerely

Walla Walla Solar is a clear conflict of interest case this is because with original Planner & Environmental
Assessment Officer Rob Beckett - suddenly (within approx 4 - 6 weeks) becoming FRV's Solar Project Developer Manager.
with the increase in the solar array and development footprint, of approximately 15.4 ha, within the existing project boundary = a further 50,000 Solar panels - Totalling 700,000. this is just madness and not acceptable to this area we live in, STOP IT NOW!!!!!

SOS objects to the proposed Walla Walla solar works expansion as :
Australia has only 6% arable land out of a total land mass of 7.692 million sq km. This land in Walla Walla is suitable for agriculture due to a reasonably reliable annual rainfall. It makes no sense to take up prime agricultural land for industrial purposes. Land that not only feeds Australia but exports 70% of its produce. There are great risks associated with solar panels technology, as overseas studies have shown, in regard to soil and water contamination and also a greater risk in regard to grass and bushfires. Solar works can be located in other areas that have less detrimental impacts, agriculture cannot. Water is vital to a successful agricultural industry, agriculture cannot simply go elsewhere but renewables plants and their essential supporting infrastructure can and should be, with roof top solar the preferred choice supported by base-load nuclear plants.

I object to the modifications as I am concerned that the end of life decommissioning and land rehabilitation is not being properly considered. The addition of 50,000 more solar panels only increases the problems of decommissioning. In the past, when raising this issue with Developers, they state that it's a matter between them and the landowner. I am concerned that potentially there are no agreements in place or that the landowners have been led to believe that they will come out in front after recycling. This has proven not to be the case in solar industry that is already being decommissioned in America. One small 20MW industrial solar cost the landowners millions of US$ for decommissioning and land restoration, after receiving payment for recycling. In NSW the local council is responsible for end-of-life cleanup if the operator or land owner default.

I strongly object to Walla Walla Solar Farm Modification SSD-9874-Mod-2
I have strongly objected to all four solar projects in the Greater Hume Shire, totalling 2.4 million solar panels on 2,360 hectares within approximately 23 kms. on some of the best agricultural land in Australia, due largely to our reliable high average rainfall.

I will never forget that at an open community information session an involved person came up to me and said that the wrong soil classifications were given for the Walla Solar Project. Many people in our Shire wrote submissions to the DPI River Murray Draft Important Agricultural land Mapping project, as it was so obvious the mapping was wrong. We have a very productive farm that was classified below average. The date for the release of this project kept being delayed during the progress of solar Projects in our Shire. When finally released, three projects were determined all based on the incorrect land classifications, that the solar companies used. THIS IS WRONG!! Our Council in November 2019, in writing their submission to the EIS Walla Walla Solar, said they had been advised that this land will be mapped as important agricultural land, so the site could be considered constrained under the DPIE Large Scale Solar Energy Guidelines.

When the Land Mapping Results finally came, they were still incorrect and many submissions by people who wrote them a few years earlier, have resubmitted them again! This is completely wrong !! How can a project be determined on false land mapping figures?

From the start of the proposed Walla Solar project, I have made submissions, with deep concerns that many locals thought the same. None of these concerns have been taken notice of, yet many submissions for the project just say brief comments like `We need solar!' It is unbelievable that FRV can have two lots of major Modifications after the project was determined. I am not the only one who has no trust in FRV, especially after they portray Walla as a dying town,in need of an economic boost from a solar project! To say these untruths about Walla is wrong, when FRV say they want to build up trust and work closely with our town! How about having an open public meeting and explaining the huge benefits you have and take questions after it? How about putting notices up in our town and sending notices to ALL residents, not just emailing your list of recipients! The latest notice by the Department was a small notice in Tuesday`s Border Mail, whereas last time it was in a Saturday`s Border Mail in a prominent place. Not many people buy Tuesday`s BorderMail. The latest four modifications are huge! Fancy increasing the daily construction heavy vehicle movements from 45 to 110! In Greater Hume Council`s submission to the EIS in November 2019, Council engineers raised concerns about the unsealed part of Benambra Rd. and they wanted the proponent to consider and pay for the sealing of Benambra Rd to Schneiders Rd . I noticed in the latest Report, that Council would still like this to happen, but I noticed FRV are not saying this will happen. This is so wrong, considering FRV are asking for a daily limit of 65 more heavy vehicles!

With the modification of changes to the site layout, the additional crossing of Back Creek is deeply concerning. Both Back Creek and Middle Creek run into the Billabong, the longest Creek in the world. Broken, inferior, storm and fire damaged panels are a toxic contamination risk to our food, soil and water. The addition of more panels certainly makes this risk worse. After their life span, FRV are vague about who will remove the solar project. The soil definitely won`t be the same as it was. It is evident there will be a food shortage, with the contaminated soil not able to be used. Nowhere to recycle the millions of panels in Australia and the world that will be of no use anymore!

The increased destruction of Native Vegetation is completely ruining the environment, not to mention the 50 or so paddock trees , many over 400 years old destroyed! What about the destruction to living creatures? FRV manage that with biodiversity offset credits!

All for clean green energy?
Does anyone care?

There needs to be an URGENT Moratorium and Independent review NOW before any solar and wind projects proceed. That includes Walla Walla.
WAKE UP before it is too late!

this should proceed as soon as possible . the larger panels will perform better, the extra area is not a problem .This project is very urgent .Renewable energy is now the way to go . Coal must be left where it was formed ,to give the next generation a chance to survive!!!!!!