State Significant Infrastructure
Response to Submissions
Oven Mountain Pumped Hydro Energy Storage.
Armidale Regional
Current Status: Response to Submissions
Interact with the stages for their names
- SEARs
- Prepare EIS
- Exhibition
- Collate Submissions
- Response to Submissions
- Assessment
- Recommendation
- Determination
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Development of a 900 MW pumped hydro energy storage and generation project, grid connection and ancillary infrastructure.
EPBC
This project is a controlled action under the Environment Protection and Biodiversity Conservation Act 1999 and will be assessed under the bilateral agreement between the NSW and Commonwealth Governments, or an accredited assessment process. For more information, refer to the Australian Government's website.
Attachments & Resources
Notice of Exhibition (2)
Application (2)
SEARs (1)
EIS (28)
Response to Submissions (1)
Agency Advice (16)
Submissions
Showing 61 - 76 of 76 submissions
Mike Pemberton
Object
Mike Pemberton
Object
SCOTTS HEAD
,
New South Wales
Message
Attention: The Honourable Paul Scully MP, Minister for Planning and Public Space C/-Anthony Ko, Project Contact Planner, DPE Department of Planning and Environment Locked Bag 5022 Parramatta / NSW 2124
Dear Hon. Paul Scully, Minister for Planning and Environment
Re: Submission of Objection by Michael Pemberton to the Proposed Oven Mountain Pumped Hydro Storage Proposal: Application Number SSI-12422997, EPBC ID Number 2020/8850, Assessment Type; Critical Infrastructure. Exhibited as : (EXH-62250958)
Thank you for the opportunity to provide a ‘Submission of Objection’ to the proposed Oven Mountain Pumped Hydro Storage CSSI Development Application. There is a possibility that we may provide additional information over the next four weeks.
From our review of raw DA, EIS and Appendices our concerns include:
1) Disturbance of a natural site along an escarpment with highly significant nature conservation and World heritage values when plenty of disturbed sites with equivalent hydrostatic head topographic variation exist in NSW, for example coal mines in the Hunter.
Alternatives to pumped hydro need to be investigated in for the northern region given the demise of coal fired power stations, the original main source of power for pumped hydro. Batteries linked to solar and wind in the region seem an obvious alternative with no environmental issues and a similar or lesser cost.
2) APPENDIX P Land, soils and erosion assessment
The physical and chemical properties of the soil are well covered in the report. The high erosivity of the various soils are identified as a significant management issue due to high intensity rainfall events, steep slopes, sheet flow velocities and very vulnerable soil types. The latter include high to extremely high soil loss class soils.
The soils include dispersive clay soils (and subsoils) and soils which are very prone to sheet erosion. These occur on very steep slopes where the rugged topography makes any mechanical intervention impossible according to the report. The report also makes it clear that soil erosion is inevitable as “…sheet flow velocities are likely to exceed maximum permissible velocities of the site soils…” (P 90) when areas are exposed during the construction phase. Sheet erosion, rilling and gully erosion are a major concern and serious turbidity problems in the Macleay could result given how close the river is to the construction site.
Tunnel erosion, an insidious form of land degradation which develops in dispersive soils has been identified as a serious hazard at the site. It can be extremely hard to identify until it has fully developed once surface soils have collapsed into the tunnels which initially form below ground. It can also form years after vegetation has been removed and roots die and rot in the soil providing the conduits for water to flow underground. The collapsed tunnels then develop into rills and gullies. Intervention and remediation is a major difficulty exacerbated by the areas topography.
Sedimentation and undermining reservoirs and threats to other infrastructure from these processes require assessment or the costs of construction and follow up work could lead to viability issues for the project. Sections of the report have made it quite clear that the soil boundaries are not well defined on existing soil maps and from soil work conducted for the project. It is essential that further soil assessments are conducted to investigate the extent of dispersive clays and other erodible soils and whether soil stability constraints are a major issue for the proposal.
Given the critical nature of the land degradation issues to the project (and its approval) these assessments should be conducted prior to the development of the Soil Stripping and Management Plan, the Soil and Water Management Plan and the Erosion and Sediment Control Plans.
We are particularly concerned about the sedimentation and turbidity threats related to the development which will take four to five years affecting 300 to 400 ha of land. In addition turbidity and sedimentation could be ongoing and extremely difficult to manage if tunnel erosion from dispersive soils is not clearly understood and addressed.
3) APPENDIX Q Rehabilitation
The rehabilitation report has identified very similar land degradation issues documented in Appendix P Land, soils and erosion assessment. It also identifies a very low land capability for parts of the site based on dispersive soils, tunnel erosion hazards and the development of rill and gully erosion.
This report also identifies high to extreme erosion hazards. It makes the point that the topography limits the ability to scarify or repair rills and other points of erosion and that over time erosion gullies could form. Sedimentation and turbidity from rehabilitating areas, the document notes, will continue to pose a threat to water quality and stream health having the potential to infill alluvial gravels, rapids and rock pools, diverting flows and affecting aquatic fauna. Erosion also threatens the rate and magnitude of rehabilitation. There are considerable concerns about the threats to water quality.
The rehabilitation report covers various aspects of onground works such as retention of organic matter and woody debri, the use of hydro mulching and earth works to support rehabilitation. There is however a major lack of detail regarding seed collection, seedling propagation, seed mixes and how these will be distributed or planted. There is also no reference to whether there will or will not be a reliance on seed dispersal into the site from adjacent bush and how this will monitored. Other aspects of rehabilitation monitoring appear to be well covered.
Use of fertilisers and other additives like gypsum (presumably to lighten clay soils) are mentioned but there is a lack of detail of the suitability for native vegetation rehabilitation and limitations to ensure adjacent areas are not adversely impacted for example through fertiliser concentration around drainage lines.”
4) Conclusion
The Save Our Macleay River Submission objecting to this development is supported.
We don’t believe this development, based on dated technology with severe land stability potential should be approved. The Macleay River valley has been significant disturbed by agricultural and mining activities, and adding yet another disturbance in the catchment, when the aim should be to reduce disturbance is not supported.
The undisturbed condition of the site, disperive soils, turbidity threats, antimony and arsenic pollution and potential limits of rehabilitation are all issues, together with many others suggesting that this development should not proceed.
This natural gorge country should not be subject to large scale works proposed by this development. Areas close by are World heritage listed and why add this disturbance to an area whose integrity will be compromised by the OMPHS.
Yours sincerely
Fiona Preston and Michael Pemberton
Dear Hon. Paul Scully, Minister for Planning and Environment
Re: Submission of Objection by Michael Pemberton to the Proposed Oven Mountain Pumped Hydro Storage Proposal: Application Number SSI-12422997, EPBC ID Number 2020/8850, Assessment Type; Critical Infrastructure. Exhibited as : (EXH-62250958)
Thank you for the opportunity to provide a ‘Submission of Objection’ to the proposed Oven Mountain Pumped Hydro Storage CSSI Development Application. There is a possibility that we may provide additional information over the next four weeks.
From our review of raw DA, EIS and Appendices our concerns include:
1) Disturbance of a natural site along an escarpment with highly significant nature conservation and World heritage values when plenty of disturbed sites with equivalent hydrostatic head topographic variation exist in NSW, for example coal mines in the Hunter.
Alternatives to pumped hydro need to be investigated in for the northern region given the demise of coal fired power stations, the original main source of power for pumped hydro. Batteries linked to solar and wind in the region seem an obvious alternative with no environmental issues and a similar or lesser cost.
2) APPENDIX P Land, soils and erosion assessment
The physical and chemical properties of the soil are well covered in the report. The high erosivity of the various soils are identified as a significant management issue due to high intensity rainfall events, steep slopes, sheet flow velocities and very vulnerable soil types. The latter include high to extremely high soil loss class soils.
The soils include dispersive clay soils (and subsoils) and soils which are very prone to sheet erosion. These occur on very steep slopes where the rugged topography makes any mechanical intervention impossible according to the report. The report also makes it clear that soil erosion is inevitable as “…sheet flow velocities are likely to exceed maximum permissible velocities of the site soils…” (P 90) when areas are exposed during the construction phase. Sheet erosion, rilling and gully erosion are a major concern and serious turbidity problems in the Macleay could result given how close the river is to the construction site.
Tunnel erosion, an insidious form of land degradation which develops in dispersive soils has been identified as a serious hazard at the site. It can be extremely hard to identify until it has fully developed once surface soils have collapsed into the tunnels which initially form below ground. It can also form years after vegetation has been removed and roots die and rot in the soil providing the conduits for water to flow underground. The collapsed tunnels then develop into rills and gullies. Intervention and remediation is a major difficulty exacerbated by the areas topography.
Sedimentation and undermining reservoirs and threats to other infrastructure from these processes require assessment or the costs of construction and follow up work could lead to viability issues for the project. Sections of the report have made it quite clear that the soil boundaries are not well defined on existing soil maps and from soil work conducted for the project. It is essential that further soil assessments are conducted to investigate the extent of dispersive clays and other erodible soils and whether soil stability constraints are a major issue for the proposal.
Given the critical nature of the land degradation issues to the project (and its approval) these assessments should be conducted prior to the development of the Soil Stripping and Management Plan, the Soil and Water Management Plan and the Erosion and Sediment Control Plans.
We are particularly concerned about the sedimentation and turbidity threats related to the development which will take four to five years affecting 300 to 400 ha of land. In addition turbidity and sedimentation could be ongoing and extremely difficult to manage if tunnel erosion from dispersive soils is not clearly understood and addressed.
3) APPENDIX Q Rehabilitation
The rehabilitation report has identified very similar land degradation issues documented in Appendix P Land, soils and erosion assessment. It also identifies a very low land capability for parts of the site based on dispersive soils, tunnel erosion hazards and the development of rill and gully erosion.
This report also identifies high to extreme erosion hazards. It makes the point that the topography limits the ability to scarify or repair rills and other points of erosion and that over time erosion gullies could form. Sedimentation and turbidity from rehabilitating areas, the document notes, will continue to pose a threat to water quality and stream health having the potential to infill alluvial gravels, rapids and rock pools, diverting flows and affecting aquatic fauna. Erosion also threatens the rate and magnitude of rehabilitation. There are considerable concerns about the threats to water quality.
The rehabilitation report covers various aspects of onground works such as retention of organic matter and woody debri, the use of hydro mulching and earth works to support rehabilitation. There is however a major lack of detail regarding seed collection, seedling propagation, seed mixes and how these will be distributed or planted. There is also no reference to whether there will or will not be a reliance on seed dispersal into the site from adjacent bush and how this will monitored. Other aspects of rehabilitation monitoring appear to be well covered.
Use of fertilisers and other additives like gypsum (presumably to lighten clay soils) are mentioned but there is a lack of detail of the suitability for native vegetation rehabilitation and limitations to ensure adjacent areas are not adversely impacted for example through fertiliser concentration around drainage lines.”
4) Conclusion
The Save Our Macleay River Submission objecting to this development is supported.
We don’t believe this development, based on dated technology with severe land stability potential should be approved. The Macleay River valley has been significant disturbed by agricultural and mining activities, and adding yet another disturbance in the catchment, when the aim should be to reduce disturbance is not supported.
The undisturbed condition of the site, disperive soils, turbidity threats, antimony and arsenic pollution and potential limits of rehabilitation are all issues, together with many others suggesting that this development should not proceed.
This natural gorge country should not be subject to large scale works proposed by this development. Areas close by are World heritage listed and why add this disturbance to an area whose integrity will be compromised by the OMPHS.
Yours sincerely
Fiona Preston and Michael Pemberton
Fiona Preston
Object
Fiona Preston
Object
SCOTTS HEAD
,
New South Wales
Message
Attention: The Honourable Paul Scully MP, Minister for Planning and Public Space C/-Anthony Ko, Project Contact Planner, DPE Department of Planning and Environment Locked Bag 5022 Parramatta / NSW 2124
Dear Hon. Paul Scully, Minister for Planning and Environment
Re: Submission of Objection by Michael Pemberton to the Proposed Oven Mountain Pumped Hydro Storage Proposal: Application Number SSI-12422997, EPBC ID Number 2020/8850, Assessment Type; Critical Infrastructure. Exhibited as : (EXH-62250958)
Thank you for the opportunity to provide a ‘Submission of Objection’ to the proposed Oven Mountain Pumped Hydro Storage CSSI Development Application. There is a possibility that we may provide additional information over the next four weeks.
From our review of raw DA, EIS and Appendices our concerns include:
1) Disturbance of a natural site along an escarpment with highly significant nature conservation and World heritage values when plenty of disturbed sites with equivalent hydrostatic head topographic variation exist in NSW, for example coal mines in the Hunter.
Alternatives to pumped hydro need to be investigated in for the northern region given the demise of coal fired power stations, the original main source of power for pumped hydro. Batteries linked to solar and wind in the region seem an obvious alternative with no environmental issues and a similar or lesser cost.
2) APPENDIX P Land, soils and erosion assessment
The physical and chemical properties of the soil are well covered in the report. The high erosivity of the various soils are identified as a significant management issue due to high intensity rainfall events, steep slopes, sheet flow velocities and very vulnerable soil types. The latter include high to extremely high soil loss class soils.
The soils include dispersive clay soils (and subsoils) and soils which are very prone to sheet erosion. These occur on very steep slopes where the rugged topography makes any mechanical intervention impossible according to the report. The report also makes it clear that soil erosion is inevitable as “…sheet flow velocities are likely to exceed maximum permissible velocities of the site soils…” (P 90) when areas are exposed during the construction phase. Sheet erosion, rilling and gully erosion are a major concern and serious turbidity problems in the Macleay could result given how close the river is to the construction site.
Tunnel erosion, an insidious form of land degradation which develops in dispersive soils has been identified as a serious hazard at the site. It can be extremely hard to identify until it has fully developed once surface soils have collapsed into the tunnels which initially form below ground. It can also form years after vegetation has been removed and roots die and rot in the soil providing the conduits for water to flow underground. The collapsed tunnels then develop into rills and gullies. Intervention and remediation is a major difficulty exacerbated by the areas topography.
Sedimentation and undermining reservoirs and threats to other infrastructure from these processes require assessment or the costs of construction and follow up work could lead to viability issues for the project. Sections of the report have made it quite clear that the soil boundaries are not well defined on existing soil maps and from soil work conducted for the project. It is essential that further soil assessments are conducted to investigate the extent of dispersive clays and other erodible soils and whether soil stability constraints are a major issue for the proposal.
Given the critical nature of the land degradation issues to the project (and its approval) these assessments should be conducted prior to the development of the Soil Stripping and Management Plan, the Soil and Water Management Plan and the Erosion and Sediment Control Plans.
We are particularly concerned about the sedimentation and turbidity threats related to the development which will take four to five years affecting 300 to 400 ha of land. In addition turbidity and sedimentation could be ongoing and extremely difficult to manage if tunnel erosion from dispersive soils is not clearly understood and addressed.
3) APPENDIX Q Rehabilitation
The rehabilitation report has identified very similar land degradation issues documented in Appendix P Land, soils and erosion assessment. It also identifies a very low land capability for parts of the site based on dispersive soils, tunnel erosion hazards and the development of rill and gully erosion.
This report also identifies high to extreme erosion hazards. It makes the point that the topography limits the ability to scarify or repair rills and other points of erosion and that over time erosion gullies could form. Sedimentation and turbidity from rehabilitating areas, the document notes, will continue to pose a threat to water quality and stream health having the potential to infill alluvial gravels, rapids and rock pools, diverting flows and affecting aquatic fauna. Erosion also threatens the rate and magnitude of rehabilitation. There are considerable concerns about the threats to water quality.
The rehabilitation report covers various aspects of onground works such as retention of organic matter and woody debri, the use of hydro mulching and earth works to support rehabilitation. There is however a major lack of detail regarding seed collection, seedling propagation, seed mixes and how these will be distributed or planted. There is also no reference to whether there will or will not be a reliance on seed dispersal into the site from adjacent bush and how this will monitored. Other aspects of rehabilitation monitoring appear to be well covered.
Use of fertilisers and other additives like gypsum (presumably to lighten clay soils) are mentioned but there is a lack of detail of the suitability for native vegetation rehabilitation and limitations to ensure adjacent areas are not adversely impacted for example through fertiliser concentration around drainage lines.”
4) Conclusion
The Save Our Macleay River Submission objecting to this development is supported.
We don’t believe this development, based on dated technology with severe land stability potential should be approved. The Macleay River valley has been significant disturbed by agricultural and mining activities, and adding yet another disturbance in the catchment, when the aim should be to reduce disturbance is not supported.
The undisturbed condition of the site, disperive soils, turbidity threats, antimony and arsenic pollution and potential limits of rehabilitation are all issues, together with many others suggesting that this development should not proceed.
This natural gorge country should not be subject to large scale works proposed by this development. Areas close by are World heritage listed and why add this disturbance to an area whose integrity will be compromised by the OMPHS.
Yours sincerely
Fiona Preston and Michael Pemberton
Dear Hon. Paul Scully, Minister for Planning and Environment
Re: Submission of Objection by Michael Pemberton to the Proposed Oven Mountain Pumped Hydro Storage Proposal: Application Number SSI-12422997, EPBC ID Number 2020/8850, Assessment Type; Critical Infrastructure. Exhibited as : (EXH-62250958)
Thank you for the opportunity to provide a ‘Submission of Objection’ to the proposed Oven Mountain Pumped Hydro Storage CSSI Development Application. There is a possibility that we may provide additional information over the next four weeks.
From our review of raw DA, EIS and Appendices our concerns include:
1) Disturbance of a natural site along an escarpment with highly significant nature conservation and World heritage values when plenty of disturbed sites with equivalent hydrostatic head topographic variation exist in NSW, for example coal mines in the Hunter.
Alternatives to pumped hydro need to be investigated in for the northern region given the demise of coal fired power stations, the original main source of power for pumped hydro. Batteries linked to solar and wind in the region seem an obvious alternative with no environmental issues and a similar or lesser cost.
2) APPENDIX P Land, soils and erosion assessment
The physical and chemical properties of the soil are well covered in the report. The high erosivity of the various soils are identified as a significant management issue due to high intensity rainfall events, steep slopes, sheet flow velocities and very vulnerable soil types. The latter include high to extremely high soil loss class soils.
The soils include dispersive clay soils (and subsoils) and soils which are very prone to sheet erosion. These occur on very steep slopes where the rugged topography makes any mechanical intervention impossible according to the report. The report also makes it clear that soil erosion is inevitable as “…sheet flow velocities are likely to exceed maximum permissible velocities of the site soils…” (P 90) when areas are exposed during the construction phase. Sheet erosion, rilling and gully erosion are a major concern and serious turbidity problems in the Macleay could result given how close the river is to the construction site.
Tunnel erosion, an insidious form of land degradation which develops in dispersive soils has been identified as a serious hazard at the site. It can be extremely hard to identify until it has fully developed once surface soils have collapsed into the tunnels which initially form below ground. It can also form years after vegetation has been removed and roots die and rot in the soil providing the conduits for water to flow underground. The collapsed tunnels then develop into rills and gullies. Intervention and remediation is a major difficulty exacerbated by the areas topography.
Sedimentation and undermining reservoirs and threats to other infrastructure from these processes require assessment or the costs of construction and follow up work could lead to viability issues for the project. Sections of the report have made it quite clear that the soil boundaries are not well defined on existing soil maps and from soil work conducted for the project. It is essential that further soil assessments are conducted to investigate the extent of dispersive clays and other erodible soils and whether soil stability constraints are a major issue for the proposal.
Given the critical nature of the land degradation issues to the project (and its approval) these assessments should be conducted prior to the development of the Soil Stripping and Management Plan, the Soil and Water Management Plan and the Erosion and Sediment Control Plans.
We are particularly concerned about the sedimentation and turbidity threats related to the development which will take four to five years affecting 300 to 400 ha of land. In addition turbidity and sedimentation could be ongoing and extremely difficult to manage if tunnel erosion from dispersive soils is not clearly understood and addressed.
3) APPENDIX Q Rehabilitation
The rehabilitation report has identified very similar land degradation issues documented in Appendix P Land, soils and erosion assessment. It also identifies a very low land capability for parts of the site based on dispersive soils, tunnel erosion hazards and the development of rill and gully erosion.
This report also identifies high to extreme erosion hazards. It makes the point that the topography limits the ability to scarify or repair rills and other points of erosion and that over time erosion gullies could form. Sedimentation and turbidity from rehabilitating areas, the document notes, will continue to pose a threat to water quality and stream health having the potential to infill alluvial gravels, rapids and rock pools, diverting flows and affecting aquatic fauna. Erosion also threatens the rate and magnitude of rehabilitation. There are considerable concerns about the threats to water quality.
The rehabilitation report covers various aspects of onground works such as retention of organic matter and woody debri, the use of hydro mulching and earth works to support rehabilitation. There is however a major lack of detail regarding seed collection, seedling propagation, seed mixes and how these will be distributed or planted. There is also no reference to whether there will or will not be a reliance on seed dispersal into the site from adjacent bush and how this will monitored. Other aspects of rehabilitation monitoring appear to be well covered.
Use of fertilisers and other additives like gypsum (presumably to lighten clay soils) are mentioned but there is a lack of detail of the suitability for native vegetation rehabilitation and limitations to ensure adjacent areas are not adversely impacted for example through fertiliser concentration around drainage lines.”
4) Conclusion
The Save Our Macleay River Submission objecting to this development is supported.
We don’t believe this development, based on dated technology with severe land stability potential should be approved. The Macleay River valley has been significant disturbed by agricultural and mining activities, and adding yet another disturbance in the catchment, when the aim should be to reduce disturbance is not supported.
The undisturbed condition of the site, disperive soils, turbidity threats, antimony and arsenic pollution and potential limits of rehabilitation are all issues, together with many others suggesting that this development should not proceed.
This natural gorge country should not be subject to large scale works proposed by this development. Areas close by are World heritage listed and why add this disturbance to an area whose integrity will be compromised by the OMPHS.
Yours sincerely
Fiona Preston and Michael Pemberton
Name Withheld
Object
Name Withheld
Object
Lancefield
,
Victoria
Message
I Object to Ovens Mountain Pumped Hydro SSI-12422997 as it is firstly extremely expensive and very time consuming to construct; secondly again adequate capacity requires systems of the proposed size of Snowy 2.0. Wide area such constructions are out of the question for cost (Cost estimates for Snowy 2.0 are approaching $10 billion (from an original estimate of around $2 billion) and water availability reasons;
• All storage systems require immediate recharge following use, such recharge cannot be guaranteed as it depends on the prevailing weather condition;
• Further in order to affect recharge the grid generation capacity would have to be more than doubled to accommodate the storage recharge, the inefficiency factor of all storage, and the normal daily grid load. Such increased capacity is not financially feasible nor is it technically viable, due to the vagaries of weather.
• Simply put, storage cannot work."
• All storage systems require immediate recharge following use, such recharge cannot be guaranteed as it depends on the prevailing weather condition;
• Further in order to affect recharge the grid generation capacity would have to be more than doubled to accommodate the storage recharge, the inefficiency factor of all storage, and the normal daily grid load. Such increased capacity is not financially feasible nor is it technically viable, due to the vagaries of weather.
• Simply put, storage cannot work."
Name Withheld
Object
Name Withheld
Object
ARMIDALE
,
New South Wales
Message
I would like, as an individual, to endorse the 'Save Our Macleay River' Group's objections to this proposal, as below:
Reasons for our submission for DA Refusal/Decline include:
▪ The Project’s scale in this isolated and inaccessible area and amount of disturbance proposed makes this expensive to develop and will adversely impact on such a natural area surrounded by such significant natural assets, Macleay River water quality as well as existing infrastructure.
▪ Decommissioning of the Site at ‘end of life’ (un-viability or long term) in such a natural area with high environmental scenic and recreation values will not and can never be restored.
▪ There are already more efficient and cost-effective and less disturbing ‘Alternative’ methods of longer-term storage of electricity with less energy loss-factors. For example; Big Battery technologies; which develop a-pace and will be even more efficient by the estimated 5years timeframe for the Oven Mountain facility is estimated to come on-line and are largely recyclable.
▪ The ‘Business case’ for the stated $1.8billion project is highly questionable; given Snowy 2 and other pumped hydro project examples have all had massive cost overruns, delays and ‘unforeseen’ problems. The cost estimate provided is likely only for ‘The Site’ and does not consider transmission costs. Kempsey/Armidale Road upgrades needed are stated as being paid for by the Project, but constructed by Council(s); these costs are stated as omitted from the Project costing. Off-site or associated public infrastructure maintenance costs to the tax-payer (i.e.: ‘hidden’ costs) are also not addressed in the EIS. If all these were included in the budget for cost/benefit and feasibility, the project would likely not stack-up. – The Lendlease proposal for Pumped Hydro here, 20 odd years ago, was dropped because ‘it did not stack-up.’
Yours sincerely,
Reasons for our submission for DA Refusal/Decline include:
▪ The Project’s scale in this isolated and inaccessible area and amount of disturbance proposed makes this expensive to develop and will adversely impact on such a natural area surrounded by such significant natural assets, Macleay River water quality as well as existing infrastructure.
▪ Decommissioning of the Site at ‘end of life’ (un-viability or long term) in such a natural area with high environmental scenic and recreation values will not and can never be restored.
▪ There are already more efficient and cost-effective and less disturbing ‘Alternative’ methods of longer-term storage of electricity with less energy loss-factors. For example; Big Battery technologies; which develop a-pace and will be even more efficient by the estimated 5years timeframe for the Oven Mountain facility is estimated to come on-line and are largely recyclable.
▪ The ‘Business case’ for the stated $1.8billion project is highly questionable; given Snowy 2 and other pumped hydro project examples have all had massive cost overruns, delays and ‘unforeseen’ problems. The cost estimate provided is likely only for ‘The Site’ and does not consider transmission costs. Kempsey/Armidale Road upgrades needed are stated as being paid for by the Project, but constructed by Council(s); these costs are stated as omitted from the Project costing. Off-site or associated public infrastructure maintenance costs to the tax-payer (i.e.: ‘hidden’ costs) are also not addressed in the EIS. If all these were included in the budget for cost/benefit and feasibility, the project would likely not stack-up. – The Lendlease proposal for Pumped Hydro here, 20 odd years ago, was dropped because ‘it did not stack-up.’
Yours sincerely,
Glen Ravenscroft
Object
Glen Ravenscroft
Object
TEMAGOG
,
New South Wales
Message
Dear Minister,
My wife, Family and Myself are property holders and residents along the Macleay River in the Temagog Region. We have a recognised Flora and Fauna Refuge along with a Sculpture Park and Art Gallery. On our property we have numerous trees, shrubs, flowers and orchids that are unique to this region that are rare and unique only to this region. Along with this we have a myriad of birds, animals and insects also unique to this area many of which are listed as rare and protected. This Hydro Proposal in the short term and the long term will be a huge threat to both. Our property is sponsored and assisted by Landcare, Kempsey Shire Council and Land Services Nth Coast.
Macleay River Water security in the short term will deprive all Flora and Fauna in the area due to the Damming mentioned in the proposal. All species rely on the regular supply of a regular flowing river to sustain its existence, stopping this regular flow is instant death to many species. This current drought we are experiencing is sufficient testimony to prove the interrupted river flow causes extreme trauma even within the last three shorts months, food and nourishment from plants has become scarce and many plants and trees have perished and or closed down leaving little food for creatures that need that sustenance.
Water security in the long term will create dangerous situations in water flow for anyone downstream. Our region is well known for its floods that occur on a regular basis, some during very short periods of heavy rainfall, once the dam is filled it will need to be emptied and in some heavy conditions would need to be emptied quickly. If a deprived meandering river such as the Macleay has a large release of water there is no telling where it might go and since it is the fastest flowing (in rainfall) than any other river in the Southern Hemisphere, it could become an unpredictable disaster perhaps wiping out many villages and bridges on its down stream
The proposal of this Hydro Storage system will significantly impact all wildlife within this region along with safety of anyone residing or on vacation within the region.
It is quite clear this proposal will severely impact cattle and domestic animal farmers below the catchment along with anyone with Agricultural investments downstream.
This whole project is in an area that is recorded as a WORLD HERITAGE WILDERNESS which encompasses many National Parks and State Forests along with areas untouched by man's interference with species of Flora and Fauna and insect that have probably not even been recorded nor acknowledged as existed and would be destroyed before its discovery. There are few remaining areas on this planet that are pristine and untouched as this region, to destroy that untouched rarity would be a crime.
This region has a strong Indigenous presence and indeed have many significant sites along the Macleay River, an instance, along our riparian zone (beside the Macleay River) it is prolific with Indigenous Artefacts and is Acknowledged as a Significant Site.
Overall this proposed project would impact a reliable clean water source needed by communities living within the Mid North Coast, It would threaten many creatures and plant-life along with many livelihoods in the area and should not go ahead under any circumstances. I raise the issues pertaining to short term impacts of reduced water flows and the possible long term ramifications during prolonged flooding and possible catastrophic situations with uncertain water conditions bearing in mind the unpredictability of Global warming.
Thank you for the opportunity to provide this Submission of objection and i look forward to working with all involved to achieve a good result for our community, our economy, our environment and water security with which we live.
Yours sincerely
Glen Ravenscroft
My wife, Family and Myself are property holders and residents along the Macleay River in the Temagog Region. We have a recognised Flora and Fauna Refuge along with a Sculpture Park and Art Gallery. On our property we have numerous trees, shrubs, flowers and orchids that are unique to this region that are rare and unique only to this region. Along with this we have a myriad of birds, animals and insects also unique to this area many of which are listed as rare and protected. This Hydro Proposal in the short term and the long term will be a huge threat to both. Our property is sponsored and assisted by Landcare, Kempsey Shire Council and Land Services Nth Coast.
Macleay River Water security in the short term will deprive all Flora and Fauna in the area due to the Damming mentioned in the proposal. All species rely on the regular supply of a regular flowing river to sustain its existence, stopping this regular flow is instant death to many species. This current drought we are experiencing is sufficient testimony to prove the interrupted river flow causes extreme trauma even within the last three shorts months, food and nourishment from plants has become scarce and many plants and trees have perished and or closed down leaving little food for creatures that need that sustenance.
Water security in the long term will create dangerous situations in water flow for anyone downstream. Our region is well known for its floods that occur on a regular basis, some during very short periods of heavy rainfall, once the dam is filled it will need to be emptied and in some heavy conditions would need to be emptied quickly. If a deprived meandering river such as the Macleay has a large release of water there is no telling where it might go and since it is the fastest flowing (in rainfall) than any other river in the Southern Hemisphere, it could become an unpredictable disaster perhaps wiping out many villages and bridges on its down stream
The proposal of this Hydro Storage system will significantly impact all wildlife within this region along with safety of anyone residing or on vacation within the region.
It is quite clear this proposal will severely impact cattle and domestic animal farmers below the catchment along with anyone with Agricultural investments downstream.
This whole project is in an area that is recorded as a WORLD HERITAGE WILDERNESS which encompasses many National Parks and State Forests along with areas untouched by man's interference with species of Flora and Fauna and insect that have probably not even been recorded nor acknowledged as existed and would be destroyed before its discovery. There are few remaining areas on this planet that are pristine and untouched as this region, to destroy that untouched rarity would be a crime.
This region has a strong Indigenous presence and indeed have many significant sites along the Macleay River, an instance, along our riparian zone (beside the Macleay River) it is prolific with Indigenous Artefacts and is Acknowledged as a Significant Site.
Overall this proposed project would impact a reliable clean water source needed by communities living within the Mid North Coast, It would threaten many creatures and plant-life along with many livelihoods in the area and should not go ahead under any circumstances. I raise the issues pertaining to short term impacts of reduced water flows and the possible long term ramifications during prolonged flooding and possible catastrophic situations with uncertain water conditions bearing in mind the unpredictability of Global warming.
Thank you for the opportunity to provide this Submission of objection and i look forward to working with all involved to achieve a good result for our community, our economy, our environment and water security with which we live.
Yours sincerely
Glen Ravenscroft
Name Withheld
Object
Name Withheld
Object
West Kempsey
,
New South Wales
Message
I am a resident of the Macleay Valley and after participating in several information sessions with the representatives of the Oven Mountain Pumped Hydro Project, I believe this project will have a significant negative impact on the local natural environment, our communities, our local infrastructure including roads and facilities and will be a net loss to our regional economy.
I refer to the comprehensive submission by the Save Our Macleay River group (as well as concerns held by other key stakeholders including Traditional Custodians) as this covers the range of issues raised at these consultation sessions and which have not been satisfactorily addressed in the Environmental Impact Statement (EIS) or in the reports.
One does not have to be an 'expert' in the sciences or any other field to recognise the deep flaws in the design and implementation of the pumped hydro storage scheme with potential issues arising at every development stage.
The scale of the Project and the amount of disturbance in what is an isolated and inaccessible (steep) area bounded by National Park, Gondawana World Heritage area, and State Forests will lead to cost overruns from the get go.
The environmental impact will be devastating particularly on the Macleay River water quality during construction and then inevitable issues arising out of operations and the EIS does not adequately provide remediation measures.
It is inevitable that the decomissioning of the scheme and restoration of the site at ‘end of life’ will not see a return to a state that that will ensure its current high environmental, scenic and recreation value.
There are alternative less disturbing and brownfield energy production sites with existing infrastructure and a trained workforce which may be adapted to pumped hydro storage and these alternatives should be investigated by the Department and their feasibility placed alongside any assessment of this proposal.
The business case for the stated $1.8billion project is highly questionable; given Snowy 2 and other pumped hydro project examples have all had massive cost overruns, delays and ‘unforeseen’ problems.
The technologies and challenges of tunnelling at this site with its hydro- geological limitations present too many unknowns and the failure of the Snowy 2 borer – ie getting 'stuck' and necessitating expensive and time consuming recovery - presents a very real scenario for similar problems at this site.
There is also the concern that with water usage restrictions now in place across Kempsey Shire and a likely prolonged drought in the foreseeable future, there must be no further 'tapping' into the Macleay River or any other harvestable water supplies either in feeding the reservoirs or during construction eg ensuring the borer does not over heat.
According to reports contained in the EIS there are faults and fissures leading to instability in the upper and lower reservoir wall areas. There will be significant site disturbance with massive cut and fill batters and reservoir walls, as well as tunnelling through the granite and likely (at least in parts) needing to be ‘blasted’ with explosives. Thus, raising the potential for further fissures, water penetration and major slips on the steep slopes, which occur naturally in the area and have already resulted in landslips on sections of the Kempsey- Armidale Road.
The cost estimate provided is likely only for ‘The Site’ and does not consider transmission costs for the 'poles and wires', increased bushfire risk, impacts on wildlife including raptors, light aircraft training flight routes used by the Australian International Aviation College and other stakeholders, nor haulage of infrastructure which threatens local roads including main thoroughfares for town residents and rural land holders.
Significant upgrades will be needed and while it is stated that these will be paid for by the Project (constructed by Council(s)) these costs and priorities and impacts on Council(s) operating forecasts are not adequately addressed in the Project's overall costing.
This is especially concerning noting that Kempsey Shire Kempsey Shire Council faces a forecast $103 million deficit over the next 10 years and ratepayers are looking at significant rate increases.
The impacts on existing public infrastructure within the Kempsey Shire and maintenance costs to the Kempsey Shire taxpayers and ratepayers (i.e.: ‘hidden’ costs) are also not addressed in the EIS. If all these were included in the budget for cost/benefit and feasibility, the project would likely not stack-up.
I seek that the Development Application be refused or at the very least be deferred until more comprehensive investigations take place and also that the proponents must provide a detailed management plan covering key areas such as transport, waste disposal, contamination, water quality etc and that rigorous compliance to current and indeed enhanced legislation be enforced with heavy penalties for any breaches and guaranteed upfront compensation to affected landholders by Alinta Energy and the NSW Government.
Thank you and kind regards
I refer to the comprehensive submission by the Save Our Macleay River group (as well as concerns held by other key stakeholders including Traditional Custodians) as this covers the range of issues raised at these consultation sessions and which have not been satisfactorily addressed in the Environmental Impact Statement (EIS) or in the reports.
One does not have to be an 'expert' in the sciences or any other field to recognise the deep flaws in the design and implementation of the pumped hydro storage scheme with potential issues arising at every development stage.
The scale of the Project and the amount of disturbance in what is an isolated and inaccessible (steep) area bounded by National Park, Gondawana World Heritage area, and State Forests will lead to cost overruns from the get go.
The environmental impact will be devastating particularly on the Macleay River water quality during construction and then inevitable issues arising out of operations and the EIS does not adequately provide remediation measures.
It is inevitable that the decomissioning of the scheme and restoration of the site at ‘end of life’ will not see a return to a state that that will ensure its current high environmental, scenic and recreation value.
There are alternative less disturbing and brownfield energy production sites with existing infrastructure and a trained workforce which may be adapted to pumped hydro storage and these alternatives should be investigated by the Department and their feasibility placed alongside any assessment of this proposal.
The business case for the stated $1.8billion project is highly questionable; given Snowy 2 and other pumped hydro project examples have all had massive cost overruns, delays and ‘unforeseen’ problems.
The technologies and challenges of tunnelling at this site with its hydro- geological limitations present too many unknowns and the failure of the Snowy 2 borer – ie getting 'stuck' and necessitating expensive and time consuming recovery - presents a very real scenario for similar problems at this site.
There is also the concern that with water usage restrictions now in place across Kempsey Shire and a likely prolonged drought in the foreseeable future, there must be no further 'tapping' into the Macleay River or any other harvestable water supplies either in feeding the reservoirs or during construction eg ensuring the borer does not over heat.
According to reports contained in the EIS there are faults and fissures leading to instability in the upper and lower reservoir wall areas. There will be significant site disturbance with massive cut and fill batters and reservoir walls, as well as tunnelling through the granite and likely (at least in parts) needing to be ‘blasted’ with explosives. Thus, raising the potential for further fissures, water penetration and major slips on the steep slopes, which occur naturally in the area and have already resulted in landslips on sections of the Kempsey- Armidale Road.
The cost estimate provided is likely only for ‘The Site’ and does not consider transmission costs for the 'poles and wires', increased bushfire risk, impacts on wildlife including raptors, light aircraft training flight routes used by the Australian International Aviation College and other stakeholders, nor haulage of infrastructure which threatens local roads including main thoroughfares for town residents and rural land holders.
Significant upgrades will be needed and while it is stated that these will be paid for by the Project (constructed by Council(s)) these costs and priorities and impacts on Council(s) operating forecasts are not adequately addressed in the Project's overall costing.
This is especially concerning noting that Kempsey Shire Kempsey Shire Council faces a forecast $103 million deficit over the next 10 years and ratepayers are looking at significant rate increases.
The impacts on existing public infrastructure within the Kempsey Shire and maintenance costs to the Kempsey Shire taxpayers and ratepayers (i.e.: ‘hidden’ costs) are also not addressed in the EIS. If all these were included in the budget for cost/benefit and feasibility, the project would likely not stack-up.
I seek that the Development Application be refused or at the very least be deferred until more comprehensive investigations take place and also that the proponents must provide a detailed management plan covering key areas such as transport, waste disposal, contamination, water quality etc and that rigorous compliance to current and indeed enhanced legislation be enforced with heavy penalties for any breaches and guaranteed upfront compensation to affected landholders by Alinta Energy and the NSW Government.
Thank you and kind regards
John Taylor
Object
John Taylor
Object
PARRAMATTA
,
New South Wales
Message
This submitter did not provide an address accompanying the submission and has been assigned the address of the head office of Department of Planning and Environment
Attachments
Name Withheld
Object
Name Withheld
Object
Mary Forbes
Object
Mary Forbes
Object
EUNGAI CREEK
,
New South Wales
Message
This pristine environment needs protection as an integral part of an irreplaceable and precious landscape.
As the Save our Macleay River organisation has pointed out, "The Project’s scale in this isolated and inaccessible area and amount of disturbance proposed makes this expensive to develop and will adversely impact on such a natural area surrounded by
such significant natural assets, Macleay River water quality as well as existing infrastructure."
Nothing is more precious than water. Farms, communities and particularly the environment all rely on invaluable water quality. This Project will create too much disturbance and compromise water quality.
Projects such as this hinder our rapid transition to renewables, which is the only way forward to a safe, sustainable and healthy future. |
As the Save our Macleay River organisation has pointed out, "The Project’s scale in this isolated and inaccessible area and amount of disturbance proposed makes this expensive to develop and will adversely impact on such a natural area surrounded by
such significant natural assets, Macleay River water quality as well as existing infrastructure."
Nothing is more precious than water. Farms, communities and particularly the environment all rely on invaluable water quality. This Project will create too much disturbance and compromise water quality.
Projects such as this hinder our rapid transition to renewables, which is the only way forward to a safe, sustainable and healthy future. |
Name Withheld
Object
Name Withheld
Object
Object
Object
Rupert Milne Home
Object
Rupert Milne Home
Object
Object
Object
nona harvey
Object
nona harvey
Object
WEST KEMPSEY
,
New South Wales
Message
Dear Minister,
Re: Submission of Objection by Dr Nona Harvey to the proposed Oven Mountain Pumped Hydro Storage Proposal: Application Number SSI-12422997, EPBC ID Number 2020/8850, Assessment Type: Critical State Significant Infrastructure. Exhibited as: (EXH-62250958)
Firstly I would like to thank you for making available and exhibiting the DA, EIS and accompanying documents and appreciate the opportunity to provide a Submission to the Proposed Oven Mountain Pumped Hydro Development Application.
I am a founding member of Save our Macleay River Inc and share their concern about the capacity of the above proposal to ensure high water quality for the Macleay Catchment and to protect downstream communities from any past, present and potential impacts.
The Project will disturb a large (440Ha) area of a very steep site in highly culturally and environmentally significant areas, surrounded by National Park, Gondwana World Heritage area, State Forests and adjacent to the Macleay River. Although the project site does not encompass all these areas it is important to recognize the collateral damage that can occur on the areas surrounding the site, including, and especially, the river unless adequate assessment of potential damage and safeguards can be put in place.
With extreme weather events such as droughts, fires and flood becoming more frequent and protracted, my concern is to what extent has this been factored into the assessment, and whether indeed it can be adequately done. As noted in the EIS, significant variation occurs on climate change predictions and future extremes may not be fully captured in current data available (Appendix M p123 pdf). Furthermore, an expert in the field recommends a comprehensive baseline water database and continuing monitoring program in order to fully understand and monitor potential project impacts, verify model predictions and reassess limitations or conditions where necessary. In particular to allow assessment of metalloid remobilisation and to determine whether additional constraints on the project are required other than those proposed.
According to geo-assessments, the site features a fault and fractures and yet no assessment has been made of the extent of dispersive soils characteristic of such terrain. The consequences of this issue not being properly assessed and managed would be ongoing and impact of the water quality of the river would be extremely difficult if not impossible to remediate, according to one expert.
Therefore on the above issues alone, I object to the Approval until these issues are properly investigated and addressed.
There are several alternatives to this project which I would recommend be considered when weighing up the pros and cons of this project including:
• A large battery storage in Armidale (near the sub-station)
• Green hydrogen
• Less sensitive and isolated/more accessible Sites for pumped hydro in less damaging and costly ‘Brown-field’ (already disturbed) sites (such as the existing Hunter Valley coal mine infrastructure).
Have you made a serious investigation into such alternatives, considering issues such as cost benefit analyses and redundancy in the near future?
Thank you for considering my concerns, based on the findings of experts in the field, and I look forward to seeing a good result for the local community and economy, but also for the water and environment without which we cannot survive. Thus I strongly endorse the submission of Save our Macleay River whose members have devoted many years in voluntary work to fight for the quality of our river.
Yours sincerely,
Dr Nona Harvey
Member of Save our Macleay River Inc
8 Angus Avenue
West Kempsey 2440 NSW
Re: Submission of Objection by Dr Nona Harvey to the proposed Oven Mountain Pumped Hydro Storage Proposal: Application Number SSI-12422997, EPBC ID Number 2020/8850, Assessment Type: Critical State Significant Infrastructure. Exhibited as: (EXH-62250958)
Firstly I would like to thank you for making available and exhibiting the DA, EIS and accompanying documents and appreciate the opportunity to provide a Submission to the Proposed Oven Mountain Pumped Hydro Development Application.
I am a founding member of Save our Macleay River Inc and share their concern about the capacity of the above proposal to ensure high water quality for the Macleay Catchment and to protect downstream communities from any past, present and potential impacts.
The Project will disturb a large (440Ha) area of a very steep site in highly culturally and environmentally significant areas, surrounded by National Park, Gondwana World Heritage area, State Forests and adjacent to the Macleay River. Although the project site does not encompass all these areas it is important to recognize the collateral damage that can occur on the areas surrounding the site, including, and especially, the river unless adequate assessment of potential damage and safeguards can be put in place.
With extreme weather events such as droughts, fires and flood becoming more frequent and protracted, my concern is to what extent has this been factored into the assessment, and whether indeed it can be adequately done. As noted in the EIS, significant variation occurs on climate change predictions and future extremes may not be fully captured in current data available (Appendix M p123 pdf). Furthermore, an expert in the field recommends a comprehensive baseline water database and continuing monitoring program in order to fully understand and monitor potential project impacts, verify model predictions and reassess limitations or conditions where necessary. In particular to allow assessment of metalloid remobilisation and to determine whether additional constraints on the project are required other than those proposed.
According to geo-assessments, the site features a fault and fractures and yet no assessment has been made of the extent of dispersive soils characteristic of such terrain. The consequences of this issue not being properly assessed and managed would be ongoing and impact of the water quality of the river would be extremely difficult if not impossible to remediate, according to one expert.
Therefore on the above issues alone, I object to the Approval until these issues are properly investigated and addressed.
There are several alternatives to this project which I would recommend be considered when weighing up the pros and cons of this project including:
• A large battery storage in Armidale (near the sub-station)
• Green hydrogen
• Less sensitive and isolated/more accessible Sites for pumped hydro in less damaging and costly ‘Brown-field’ (already disturbed) sites (such as the existing Hunter Valley coal mine infrastructure).
Have you made a serious investigation into such alternatives, considering issues such as cost benefit analyses and redundancy in the near future?
Thank you for considering my concerns, based on the findings of experts in the field, and I look forward to seeing a good result for the local community and economy, but also for the water and environment without which we cannot survive. Thus I strongly endorse the submission of Save our Macleay River whose members have devoted many years in voluntary work to fight for the quality of our river.
Yours sincerely,
Dr Nona Harvey
Member of Save our Macleay River Inc
8 Angus Avenue
West Kempsey 2440 NSW
Name Withheld
Comment
Name Withheld
Comment
Name Withheld
Object
Name Withheld
Object
Pagination
Project Details
Application Number
SSI-12422997
EPBC ID Number
2020/8850
Assessment Type
State Significant Infrastructure
Development Type
Electricity Generation - Other
Local Government Areas
Armidale Regional