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State Significant Infrastructure

Determination

Snowy 2.0 - Main Works

Snowy Monaro Regional, Snowy Valleys

Current Status: Determination

Interact with the stages for their names

  1. SEARs
  2. Prepare EIS
  3. Exhibition
  4. Collate Submissions
  5. Response to Submissions
  6. Assessment
  7. Recommendation
  8. Determination

Download the complete Environmental Impact Statement (EIS) below, or access a summary here.

The development of an underground pumped hydro power station and ancillary infrastructure.

Archive

Application (1)

Scoping Report

SEARs (2)

Cover Letter
Issued SEARs

EIS (64)

EIS Summary
EIS Main Report - Part 1
EIS Main Report - Part 2
Appendix A - SEARs compliance table
Appendix B - Detailed maps and plans
Appendix C - Project development - Options and Alternatives
Appendix D - Construction methods
Appendix E - Capital investment value report
Appendix F - Rehabilitation strategy
Appendix G - Mitigation measures table
Appendix H - Strategic context and need for Snowy 2.0
Appendix I - Stakeholder engagement report
Appendix J.1 - Water assessment report
Appendix J.2 - Water Assessment - Annexure A Water characterisation report - 1 of 10
Appendix J.3 - Water Assessment - Annexure A Water characterisation report - 2 of 10
Appendix J.3 - Water Assessment - Annexure A - Water characterisation report - 3 of 10
Appendix J.3 - Water Assessment - Annexure A - Water characterisation report - 4 of 10
Appendix J.3 - Water Assessment - Annexure A - Water characterisation report - 5 of 10
Appendix J.3 - Water Assessment - Annexure A - Water characterisation report - 6 of 10
Appendix J.3 - Water Assessment - Annexure A - Water characterisation report - 7 of 10
Appendix J.3 - Water Assessment - Annexure A - Water characterisation report - 8 of 10
Appendix J.3 - Water Assessment - Annexure A - Water characterisation report - 9 of 10
Appendix J.3 - Water Assessment - Annexure A - Water characterisation report - 10 of 10
Appendix J.4 - Water Assessment - Annexure B - Modelling Report
Appendix J.4 - Water Assessment - Annexure C - Flood risk assessment
Appendix J.4 - Water Assessment - Annexure D - Water management report
Appendix K - Talbingo and Tantangara reservoirs physical li
Appendix L - 01 Excavated rock placement and Annexes A-B
Appendix L - 02 Excavated rock placement and Annexes C-E
Appendix L - 03 Excavated rock placement and Annex F
Appendix L - 04 Excavated rock placement and Annexes G-H
Appendix M.1-01 Biodiversity Development Assessment Report - Part A1
Appendix M.1-01 Biodiversity Development Assessment Report - Part A2
Appendix M.1-01 Biodiversity Development Assessment Report - Part A3
Appendix M.1-01 Biodiversity Development Assessment Report - Part A4
Appendix M.1.01 Biodiversity Development Assessment Report - Part A5
Appendix M.1-01 Biodiversity Development Assessment Report - Part A6
Appendix M.1-01 Biodiversity Development Assessment Report - Part A7
Appendix M.1-01 Biodiversity Development Assessment Report - Part A8
Appendix M.1-01 Biodiversity Development Assessment Report - Part A9
Appendix M.1-02 Biodiversity Development Assessment Report - Part B
Appendix M.1-03 Biodiversity Development Assessment Report - Annexures
Appendix M.2 - Aquatic ecology assessment
Appendix M.2_Aquatic ecology assessment - studies
Appendix M.3 - Offset strategy
Appendix N.1-01 Contamination assessment
Appendix N.1-02 Contamination assessment - Annexures
Appendix N.2 - Soils and land assessment
Appendix O.1 - Palaeozoic geodiversity assessment
Appendix O.2 Cenozoic geodiversity assessment
Appendix P.1 - ACHAR
Appendix P.2 - 01 Historic Heritage
Appendix P.2-02 Historic heritage - Annexures 1-3
Appendix P.2-02 Historic heritage - Annexures 4-5
Appendix Q - Traffic and transport
Appendix R - Noise and vibration
Appendix S - Landscape and visual assessment
Appendix T - Bushfire risk assessment
Appendix U - Hazard and risk
Appendix V Air quality
Appendix W Navigation Impact Assessment
Appendix X.1 - Social impact assessment
Appendix X.2 Recreational User Impacts Assessment
Appendix Y - Economic Assessment

Response to Submissions (16)

Request RTS
Main Report
Appendix A - F
Appendix G - BDAR Part 1
Appendix G - BDAR Part 2
Appendix H - Response to DPI Fisheries
Appendix I - Water Modelling Part 1
Appendix I - Water Modelling Part 2
Appendix I - Water Modelling Part 3
Appendix J - Water Mgmt Part 1
Appendix J - Water Mgmt Part 2
Appendix L - Offset Strategy
Appendix N - Response to DPIE Biosecurity
Appendix M - Heritage Addendum
Appendix K - Traffic and Transport
Appendix O - Revised Project Description

Additional Information (2)

Response to RFI - 2 April 20
Response to RFI - 27 Feb 20

Determination (3)

Assessment Report
Notice of Decision
Infrastructure Approval

Approved Documents

Management Plans and Strategies (13)

Transport Management Plan
Transport Management Plan Approval
Environmental Management Strategy
Environmental Management Strategy Approval
Spoil Management Plan
Spoil Management Plan Approval
Heritage Management Plan
Approval of Plan Strategy or Study_20122020_034404
Biodiversity Management Plan
Approval of Plan Strategy or Study_19102020_034442
Groundwater Management Plan
Surface Water Management Plan
Water Management Plan

Independent Reviews and Audits (4)

6 monthly IEA Report Snowy 2.0 July 2021
Audit reports_23082021_122736
Snowy 2.0 IEA
IEA Response Letter_170621

Note: Only documents approved by the Department after November 2019 will be published above. Any documents approved before this time can be viewed on the Applicant's website.

Complaints

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Make a Complaint

Enforcements

There are no enforcements for this project.

Inspections

18/6/2020

16/7/2020

8/10/2020

18/11/2020

19/11/2020

17/2/2021

17/2/2021

18/2/2021

21/4/2021

21/4/2021

22/4/2021

23/6/2021

23/6/2021

24/6/2021

Note: Only enforcements and inspections undertaken by the Department from March 2020 will be shown above.

Submissions

Filters
Showing 1 - 20 of 201 submissions
Name Withheld
Support
THE PONDS , New South Wales
Message
I completely support the project with only concern that the massive machinery and equipment required to build the tunnels and power station at Lobbs Hole will need to be carried from snowy mountains highway through Lobbs Hole Ravine road and other new proposed roads which will not only be too risky for the workers and drivers for taking these humongous machinery through extremely hostile slopes as well as causing much larger destruction of the pristine forests to create massive spaces for the machinery movement.
Better and much safer option is to carry these massive machines via Talbingo reservoir by building a barge at Talbingo spillway as initially suggested by snowy hydro. Could be much safer for workers and the environment..we can get the power station up and running without injuries or fatalies and much smaller destroyed forest footprint.
William Sexton
Object
CONSTITUTION HILL , New South Wales
Message
Department of Planning, Industry and Environment
Major Projects Team
Attention: Anthony Ko
09/10/19
Submission on Snowy 2.0 Main Works Environmental Impact Statement

I, William Sexton, wish to indicate our strong opposition to the Snowy 2.0 project as described in the Main Works Environmental Impact Statement (EIS). The scale and intensity of environmental impact described in the EIS is inappropriate in any sensitive sub alpine region, let alone Kosciuszko National Park (KNP), one of our nation’s most iconic, National Heritage Listed national parks.
In addition to the unacceptable environmental impacts on KNP, the fractured assessment process seems designed to conceal the catastrophic extent of environmental impacts and there is a district lack of credible consideration of less expensive, lower impact alternatives.
Claims about energy storage potential are dubious and the excessive cost will be paid for by the Australian public, the ultimate owners of the Snowy Hydro scheme.
These failures clearly demonstrate that the Snowy 2.0 project does not meet the standards required of Environmentally Sustainable Development and accordingly the project should be refused by the Minister for Planning.
The project is of vast scale and the quantity of documentation makes it very difficult to address all my/our concerns about the project. Issues of particular concern are described below:

The EIS repeatedly asserts that the Snowy 2.0 project will have a minor impact on KNP on the basis that the development footprint represents approximately 0.25% of the total area of the park. I consider this assessment to be mostly incorrect for the following reasons:
The “Project Area”, as depicted in the EIS, covers approximately 50 km by 50 km (250,000 hectares), which is a third of KNP - an area twice the size of Greater Sydney.
While KNP is one of the largest National Parks in NSW (690,000 hectares), the portion containing sub-alpine habitats, the areas to be destroyed by Snowy 2.0, is much smaller. This sub-alpine area has some of the rarest habitat in Australia, and will prove increasingly important for the retreat of alpine species affected by the heating climate. These rare habitats provide the appropriate context for assessing the adverse environmental impacts of Snowy 2.0, not the lower altitude landscapes that characterise the majority of KNP.
This construction will be largest ever proposed loss of critically important habitats in a NSW National Park. The EIS acknowledges that the construction footprint will destroy 1,680 hectares, including 1,053 hectares of native vegetation, over 95% of which is habitat for threatened fauna, threatened flora and Threatened Ecological Communities. The construction footprint acknowledged in the EIS substantially understates the full extent of permanent damage outside the heavy construction zones, including Talbingo and Tantangara Reservoirs, 100 kms of new and upgraded roads, 10 kms of transmission lines with a 120 metre-wide easement swathe, ground water depleted areas above the tunnels, construction camps (for 2,100 workers) and multiple works areas. When all these areas are taken into account, Snowy 2.0 will permanently damage more than 10,000 ha of KNP, rather than the claimed 1,680 ha.
No development of this scale or intensity is appropriate in the sensitive habitats of a declared conservation reserve. The issue should not be whether the impacts of a proposal of this scale and intensity can be ‘mitigated’, offset or otherwise approved under the Environmental Planning and Assessment Act framework. On the contrary, such a proposal simply should not be contemplated in an internationally renowned conservation reserve.
The project requires tunnelling through 27 kms of rock, large scale quarrying, road building and widening and the establishment of large accommodation and construction sites. The EIS does not provide a credible account of how 14 million cubic metres of spoil, some of which is heavily contaminated by asbestos and acidic compounds, can be disposed in KNP without further significant environmental impacts. It is clear that much of the excavated materials will be used in ‘landscaping’ works that will further exacerbate the damage to the Park. Unbelievably, over 8 million cubic metres is to be dumped in the active storage areas of Talbingo and Tantangara Reservoirs, depleting their capacities.
The EIS describes extensive impacts on water dependant habitats and species through disruption to ground water systems by the tunnelling as well as in works beside 8 kms of the Yarrangobilly River.
The watertable drawdown is predicted to be in excess of 50 m above the tunnel in areas of high hydraulic conductivity (Gooandra Volcanics). The drawdown at 3 km either side of the tunnel is still 0.5 m in the western plateau. This will have a catastrophic impact on the environment along the 27 km tunnel, will dry up existing creeks and reduce inflows to the reservoirs and hence water releases.
Snowy 2.0 will disperse pest species (including redfin perch, eastern gambusia, wild goldfish, Epizootic Haematopoietic Necrosis Virus (EHNV) and elodea weed) throughout the waterways of KNP and downstream. Redfin is a Class One Noxious Pest - it is illegal to transfer Redfin between waterways in NSW. Snowy Hydro acknowledges that it is inevitable that these noxious species will be transferred from Talbingo to Tantangara. Establishment of the dominant Redfin Perch will be to the detriment of both recreational anglers and significant populations of threatened native fish.
Even worse than it being accepted that these noxious species will be transferred to Tantangara, it is highly doubtful that the measures proposed by Snowy Hydro will stop their eventual transfer downstream to the Murrumbidgee River and Lake Eucumbene and thence throughout the rest of the Snowy Scheme and downstream rivers (Snowy, Murrumbidgee and Murray).
One of KNP’s core values is the sense of wilderness and solitude unique to alpine landscapes. These aesthetic qualities, and the experience of visitors, will be seriously diminished by the increases in roads, permanent large structures and especially the transmission lines. The project will not only impact directly on the areas trashed by the project - the overall sense and experience of the Park landscape will be damaged forever. The implication in the EIS that the community will regard the proposed infrastructure as evidence of the nation’s engineering prowess offers hollow recompense for the loss of the Park’s unique aesthetic qualities.
Snowy Hydro claims that Snowy 2.0 will play a pivotal role in stabilising the national energy market as new renewable generation is added to the grid. I/we don’t not accept that such claims justify the extent and severity of environmental destruction that the project will cause to KNP, especially in the absence of a credible assessment of alternative ways of providing this service. In any case, the data provided in the EIS seriously undermines the claimed benefits of the project. Specifically:
Snowy 2.0 will be a net consumer of electricity, not a generator, with ‘round-trip’ losses of 30%, plus another 10% for transmission.
For the next decade or so most pumping electricity will come from coal-fired power stations, not renewables, belying the claim that Snowy 2.0 will ‘store’ electricity from renewable generators.
The claimed 350 GWh would only be available in the most exceptional of circumstances, requiring the top reservoir (Tantangara) to be full. If the full volume was used, at least one-third of the water couldn’t ‘fit’ within the smaller capacity lower reservoir (Talbingo) and would be discharged to Blowering and ‘lost’ to the Snowy 2.0 system. If Talbingo were not empty (historically it is kept near full to provide for operation of the Tumut 3 pumped hydro station), then most of the water from Tantangara would be discharged to Blowering and ‘lost’ to Snowy 2.0.
The practical recyclable capacity of Snowy 2.0 is considerably less than the claimed 350 GWh.
Whenever Tantangara were emptied, it would then require several months of pumping to be returned to full supply.
If Snowy 2.0 ever generated its claimed 350 GWh of energy, it would take 500 GWh of pumping energy to re-charge, incurring 150 GWh of losses. It is likely that the project, including transmission, will be $10 billion, or even more. At anything approaching this amount the project is totally uneconomic. Snowy Hydro is wholly owned by the Commonwealth Government, hence the Australian community.
The ultimate bearers of the risk of Snowy 2.0 are the Australian tax payers, including ordinary people, such as myself. I strongly urge that more economically & environmentally sound alternatives are considered to replace this flawed Main Works proposal.
Yours sincerely
William B Sexton
Peter Prineas
Object
DARLINGTON , New South Wales
Message
10 October 2019

To: Anthony Ko
Major Projects Team
Department of Planning, Industry and Environment

Submission on the Snowy 2.0 Main Works EIS from Peter Prineas

I oppose the Snowy 2.0 project.

The project is not the result of a rational consideration of all the options available. It is a ‘captain’s pick’ by a former Prime Minister who wanted a large scale ‘heroic edifice’ to mark his tenure in office. Like the NBN, with which the same person was also closely associated as a Minister, Snowy II will be a scandalously expensive and mediocre result that falls far short of what might have been achieved.

The environmental impact of the proposed project is unacceptable in a sensitive subalpine region, and especially so in Kosciuszko National Park, a National Heritage area. It may be said that the Park has already sustained much disturbance from hydro-electric development, but that is not an argument for adding even more.

The lack of any proper consideration of less expensive, lower impact, and more timely alternatives goes to heart of the EIS’s failure as a credible study.

Claims about the energy storage potential of the scheme are also doubtful and taken as a whole, the project and the EIS, are so deficient that Minister for Planning should refuse approval.

Some particular concerns are as follows:

The EIS is misleading in its assertion that 0.25% of the total area of the park will be affected by Snowy II, when in fact, The ‘Project Area’ covers approximately a third of KNP and the fraction of the Park’s sub-alpine habitats that will be affected is even greater. The project involves the largest loss of critically important habitats ever proposed in a NSW National Park. About a thousand hectares of native vegetation, providing habitat for threatened fauna, threatened flora and threatened ecological communities will be removed. Taking into account the whole of the impacts into Snowy 2.0 will permanently damage more than 10,000 hectares of KNP, rather than the claimed 1,680 ha. Such a damaging development should not be contemplated within a national park the principal purpose of which is nature conservation.

The EIS does not explain how 14 million cubic metres of spoil, some of it heavily contaminated by asbestos and acidic compounds, will be disposed of in KNP without further significant environmental impacts. To dump 8 million cubic metres of such material in the active storage areas of Talbingo and Tantangara Reservoirs, is highly questionable.

The EIS describes extensive impacts on water dependant habitats and species through disruption to ground water systems by the tunneling as well as in works beside 8 kms of the Yarrangobilly River.

The watertable drawdown will have very heavy impacts on the environment along the 27 km tunnel. It can be expected to dry up existing creeks and reduce inflows to the reservoirs and hence water releases.

It is irresponsible of Snowy Hydro to disregard the protection of water dependent ecosystems to the extent shown in its EIS

Snowy 2.0 will disperse pest species (including redfin perch, eastern gambusia, wild goldfish, Epizootic Haematopoietic Necrosis Virus (EHNV) and elodea weed) throughout the waterways of KNP and downstream. Redfin is a Class One Noxious Pest - it is illegal to transfer Redfin between waterways in NSW. Snowy Hydro acknowledges that it is inevitable that these noxious species will be transferred from Talbingo to Tantangara. Establishment of the dominant Redfin Perch will be to the detriment of both recreational anglers and significant populations of threatened native fish. It is very doubtful that measures proposed by Snowy Hydro will prevent their eventual transfer downstream to the Murrumbidgee River and Lake Eucumbene and thence throughout the rest of the Snowy Scheme and downstream rivers (Snowy, Murrumbidgee and Murray).

One of KNP’s great values is the sense of wilderness and solitude to be found in alpine landscapes. These aesthetic qualities, and the experience of visitors, will be seriously diminished by the new or enlarged roads, large structures and transmission lines. The experience of the Park landscape will be damaged.

It is claimed that Snowy 2.0 will play a pivotal role in stabilising the national energy market as new renewable generation is added to the grid. In the absence of a credible assessment of alternative ways of providing this service this claim is hollow. In any event, the data provided in the EIS questions the claims, in view of the following:

• Snowy 2.0 will be a net consumer of electricity, not a generator, with ‘round-trip’ losses of 30%, plus another 10% for transmission.
• For the next decade or so most pumping electricity will come from coal-fired power stations, not renewables, belying the claim that Snowy 2.0 will ‘store’ electricity from renewable generators.
• The claimed 350 GWh would only be available in the most exceptional of circumstances, requiring the top reservoir (Tantangara) to be full. If the full volume was used, at least one-third of the water couldn’t ‘fit’ within the smaller capacity lower reservoir (Talbingo) and would be discharged to Blowering and ‘lost’ to the Snowy 2.0 system. If Talbingo were not empty (historically it is kept near full to provide for operation of the Tumut 3 pumped hydro station), then most of the water from Tantangara would be discharged to Blowering and ‘lost’ to Snowy 2.0.
• The practical recyclable capacity of Snowy 2.0 is considerably less than the claimed 350 GWh.
• Whenever Tantangara were emptied, it would then require several months of pumping to be returned to full supply.
• If Snowy 2.0 ever generated its claimed 350 GWh of energy, it would take 500 GWh of pumping energy to re-charge, incurring 150 GWh of losses.
• The long delay before Snowy II comes on line is unacceptable. It will not be operating until about 2027, even with the best management. There would be alternative schemes that can produce power years sooner. On this basis alone, Snowy II should be rejected.
• Snowy II is too remote from consumers, and hence transmission costs and losses associated with the project are excessive. Smaller projects in proximity to population centres are likely to offer substantial advantages.

It is clear that the cost of Snowy 2.0 will be many times greater than when first proposed (originally $2 billion, then $3.8 billion, then $5.1 billion and, adding in new transmission capacity, as much as $10 billion, making the project laughably uneconomic.

Only an organisation wholly supported by the taxpayers, like Snowy Hydro, could afford to pursue such a financially hopeless project. Of course this is the organisation that spent large sums of money on magical attempts to increase rain over the Snowy Mountains in the hope of enhancing its bottom line. This was done even though the CSIRO abandoned “cloud seeding” years earlier.

The Main Works EIS is only part of the assessment of the broader Snowy 2.0 Project. The effect of this incremental planning and assessment process is to deny the community a view of the whole project. This obscures the full extent of the environmental impacts.

Despite the Environmental Planning and Assessment Regulation 2000 requiring “an analysis of any feasible alternatives to the carrying out of the development, activity or infrastructure”, no such analysis has been provided. Work on the project should be stopped until this requirement has been fulfilled. I believe that a proper consideration of alternatives – by open tender – would identify a number of options with much less environmental impact and much better economics.

The EIS makes many references to mitigating the impacts of Snowy 2.0 through promising future plans and works in consultation with NPWS or through formal offsetting processes. No appropriate offsets for the habitats that would be destroyed by Snowy 2.0 have been identified.

The Snowy 2.0 project also fails the test of Ecologically Sustainable Development demanded by the Environmental Planning and Assessment Act.

The project should not proceed.

Yours sincerely,
Peter Prineas.
Janet Mayer
Object
FOXGROUND , New South Wales
Message
Please see attached submission for my reasons for objection
Attachments
Matthew Pye
Object
NORTH AVOCA , New South Wales
Message
Australia and particularly NSW is in an undeniable extinction crisis, in which we rank as one of the worst contries in the world. There is no coming back from extinction and every precaution should be taken to ensure we do not wipe out more species of plants and animals. It appears obvious to me that the planning of this project has not taken into account the seriousness of the effects on the local wildlife that this project will have.

EIS admits that the Main Works will destroy 1,053 ha of native vegetation and 992 ha of threatened species habitat. Surely this is enough to warrant a stop in the planning a thorough re-assessment - if this habitat loss can not be avoided then the project simply should not go ahead.

The EIS contains a totally incomplete and inadequate assessment of alternatives to Snowy 2.0. How can such an environmentally destructive development be proposed without an exhaustive exploration of viable alternatives? Kosciuszko is a National Park, not an industrial park.

Along with above the following points are very worrying, and display a lack of care for the environment which is seems to have been put behind profit.

14 million cubic metres of excavated spoil, nearly half of which contains asbestos and/or is acidic, will be dumped in Kosciuszko National Park. Most of the spoil will go into Talbingo and Tantangara Reservoirs, decreasing their storage capacities, with the remainder to go into roads or to ‘landscape’ the park.

Snowy 2.0 requires tunnelling through 27 kms of rock. This will depress the water table in some sections by more than 50 m and have an impact for up to 3 kms either side of the tunnel. This will lead to montane streams and water dependent alpine bogs drying up, further impacting upon vulnerable habitats and native species. It will also lead to a reduction of inflows to Snowy reservoirs and downstream rivers. These river systems are already under threat from feral animals and global heating. Any works that threatens water quality and quantity must be avoided.

Noxious pests and weeds will be spread throughout the Snowy Scheme and downstream, including Redfin Perch and aquatic weeds. These pests and weeds will be transported from Talbingo Reservoir up to pest-free Tantangara, the Upper Murrumbidgee catchment, and then to Eucumbene and throughout the Snowy Scheme and downstream rivers.

Kosciuszko National Park is a major tourist attraction. Snowy 2.0 will heavily impact future tourism by creating a visual blight on the pristine montane landscape from vantage points over thousands of square kilometers.

Major infrastructure, including the widening and construction of 100 km of roads and tracks are proposed throughout the project area. Some of which will destroy sensitive environmental and geological significant areas. Under normal circumstances these would not be allowed within a National Park, so why under Snowy 2.0?

Snowy Hydro claims that Snowy 2.0 will benefit the renewable energy sector. Yet most of the pumping electricity for Snowy 2.0 will come from coal-fired power stations, not renewables. Worse still, Snowy 2.0 will be a net consumer of electricity, not a generator, with ‘round-trip’ losses of 30%, plus another 10% for transmission. Why is Snowy 2.0 marketed as a boon for renewable energy when this is clearly not the case?

Not only is Snowy 2.0 environmental vandalism, it isn’t economic. The original $2 billion cost estimate is now approaching $10 billion, including transmission. Why is this project proceeding when it will likely run at a loss?

Many other pumped storage opportunities have been identified in NSW with a combined capacity considerably greater than Snowy 2.0. Why were these alternatives not explored before proposing construction within a National Park?

I am not opposed to pumped hydro storage. There is no question that additional electricity storage capacity is needed as renewable generation expands. However, this doesn’t mean that pumped hydro projects require any less scrutiny than any other construction projects, especially when they are proposed in one of the most precious and delicate parts of our nation. The case for Snowy 2.0 simply doesn’t stack up on environmental or economic grounds. There are better alternatives, ones that avoid catastrophic impacts on Kosciusko National Park.

I hope to hear detailed responses to all the points raised above.

Regards,
Matthew Pye
Jennifer Kent
Object
DULWICH HILL , New South Wales
Message
Please see my attached submission
Attachments
Leif Lemke
Comment
DARKWOOD , New South Wales
Message
The impact of climate change could lead to a global disaster and to mitigate the effect we need to protect all natural vegetation especially in areas of National Parks and World Heritage Areas.
Although I am in favour of Pump-Hydro systems we need to locate these systems away from protected areas preferable on degraded land such as disused mining sites.
But if Australia is serious about mitigating our impact of CO2 on the atmosphere we should consider reducing our general consumption. We are among the worst polluters in the world per capita and we could, with very little effort, half our impact.
Name Withheld
Comment
HORNSBY , New South Wales
Message
See attached submission
Attachments
Name Withheld
Object
HORNSBY , New South Wales
Message
See attachment.
Attachments
Catherine Crittenden
Object
Summer Hill , New South Wales
Message
Department of Planning, Industry and Environment
Major Projects Team
Attention: Anthony Ko

12 October 2019

Submission on Snowy 2.0 Main Works Environmental Impact Statement

I, Catherine Crittenden, wish to indicate my strong opposition to the Snowy 2.0 project as described in the Main Works Environmental Impact Statement (EIS). The scale and intensity of environmental impact described in the EIS is inappropriate in any sensitive sub-alpine region, let alone Kosciuszko National Park (KNP), one of our nation’s most iconic National Heritage Listed national parks.

In addition to the unacceptable environmental impacts on KNP, the fractured assessment process seems designed to conceal the catastrophic extent of environmental impacts and there is a distinct lack of credible consideration of less expensive, lower impact alternatives.

Claims about energy storage potential are dubious, and the excessive cost will be paid for by the Australian public, the ultimate owners of the Snowy Hydro scheme.

These failures clearly demonstrate that the Snowy 2.0 project does not meet the standards required of Environmentally Sustainable Development and accordingly the project should be refused by the Minister for Planning.

The project is of vast scale and the quantity of documentation makes it very difficult to address all of my concerns about the project. Issues of particular concern are described below:

Environmental impacts

The EIS repeatedly asserts that the Snowy 2.0 project will have a minor impact on KNP on the basis that the development footprint represents approximately 0.25% of the total area of the park. I consider this assessment to be utterly incorrect for the following reasons:

• The “Project Area”, as depicted in the EIS, covers approximately 50 km by 50 km (250,000 hectares), which is a third of KNP - an area twice the size of Greater Sydney.
• While KNP is one of the largest National Parks in NSW (690,000 hectares), the portion containing sub-alpine habitats, the areas to be destroyed by Snowy 2.0, is much smaller. This sub-alpine area has some of the rarest habitat in Australia, and will prove increasingly important for the retreat of alpine species affected by the heating climate. These rare habitats provide the appropriate context for assessing the adverse environmental impacts of Snowy 2.0, not the lower altitude landscapes that characterise the majority of KNP.
• This construction will be largest ever proposed loss of critically important habitats in a NSW National Park. The EIS acknowledges that the construction footprint will destroy 1,680 hectares, including 1,053 hectares of native vegetation, over 95% of which is habitat for threatened fauna, threatened flora and Threatened Ecological Communities. The construction footprint acknowledged in the EIS substantially understates the full extent of permanent damage outside the heavy construction zones, including Talbingo and Tantangara Reservoirs, 100 kms of new and upgraded roads, 10 kms of transmission lines with a 120 metre-wide easement swathe, ground water depleted areas above the tunnels, construction camps (for 2,100 workers) and multiple works areas. When all these areas are taken into account, Snowy 2.0 will permanently damage more than 10,000 ha of KNP, rather than the claimed 1,680 ha.
• No development of this scale or intensity is appropriate in the sensitive habitats of a declared conservation reserve. The issue should not be whether the impacts of a proposal of this scale and intensity can be ‘mitigated’, offset or otherwise approved under the Environmental Planning and Assessment Act framework. On the contrary, such a proposal simply should not be contemplated in an internationally renowned conservation reserve.
The project requires tunnelling through 27 kms of rock, large scale quarrying, road building and widening and the establishment of large accommodation and construction sites. The EIS does not provide a credible account of how 14 million cubic metres of spoil, some of which is heavily contaminated by asbestos and acidic compounds, can be disposed of in KNP without further significant environmental impacts. It is clear that much of the excavated materials will be used in ‘landscaping’ works that will further exacerbate the damage to the Park. Unbelievably, over 8 million cubic metres is to be dumped in the active storage areas of Talbingo and Tantangara Reservoirs, depleting their capacities.

The EIS describes extensive impacts on water dependant habitats and species through disruption to ground water systems by the tunnelling as well as in works beside 8 kms of the Yarrangobilly River.

The water table drawdown is predicted to be in excess of 50 m above the tunnel in areas of high hydraulic conductivity (Gooandra Volcanics). The drawdown at 3 km either side of the tunnel is still 0.5 m in the western plateau. This will have a catastrophic impact on the environment along the 27 km tunnel, will dry up existing creeks and reduce inflows to the reservoirs and hence water releases.

It is remarkable that Snowy Hydro would show such disregard for the protection of water dependant ecosystems not just in alpine areas but at the headwaters of our major waterways. Despite the assurance offered, this is certainly not acceptable. Experience demonstrates that once ground water systems are disrupted by mining activities the damage is irreversible and can become even more extensive over time.

Snowy 2.0 will disperse pest species (including redfin perch, eastern gambusia, wild goldfish, Epizootic Haematopoietic Necrosis Virus (EHNV) and elodea weed) throughout the waterways of KNP and downstream. Redfin is a Class One Noxious Pest - it is illegal to transfer Redfin between waterways in NSW. Snowy Hydro acknowledges that it is inevitable that these noxious species will be transferred from Talbingo to Tantangara. Establishment of the dominant Redfin Perch will be to the detriment of both recreational anglers and significant populations of threatened native fish.

Even worse than it being accepted that these noxious species will be transferred to Tantangara, it is highly doubtful that the measures proposed by Snowy Hydro will stop their eventual transfer downstream to the Murrumbidgee River and Lake Eucumbene and thence throughout the rest of the Snowy Scheme and downstream rivers (Snowy, Murrumbidgee and Murray).

One of KNP’s core values is the sense of wilderness and solitude unique to alpine landscapes. These aesthetic qualities, and the experience of visitors, will be seriously diminished by the increases in roads, permanent large structures and especially the transmission lines. The project will not only impact directly on the areas trashed by the project - the overall sense and experience of the Park landscape will be damaged forever. The implication in the EIS that the community will regard the proposed infrastructure as evidence of the nation’s engineering prowess offers hollow recompense for the loss of the Park’s unique aesthetic qualities.

Minimal contribution to renewable energy

Snowy Hydro claims that Snowy 2.0 will play a pivotal role in stabilising the national energy market as new renewable generation is added to the grid. I don’t not accept that such claims justify the extent and severity of environmental destruction that the project will cause to KNP, especially in the absence of a credible assessment of alternative ways of providing this service. In any case, the data provided in the EIS seriously undermines the claimed benefits of the project. Specifically:
• Snowy 2.0 will be a net consumer of electricity, not a generator, with ‘round-trip’ losses of 30%, plus another 10% for transmission.
• For the next decade or so most pumping electricity will come from coal-fired power stations, not renewables, belying the claim that Snowy 2.0 will ‘store’ electricity from renewable generators.
• The claimed 350 GWh would only be available in the most exceptional of circumstances, requiring the top reservoir (Tantangara) to be full. If the full volume was used, at least one-third of the water couldn’t ‘fit’ within the smaller capacity lower reservoir (Talbingo) and would be discharged to Blowering and ‘lost’ to the Snowy 2.0 system. If Talbingo were not empty (historically it is kept near full to provide for operation of the Tumut 3 pumped hydro station), then most of the water from Tantangara would be discharged to Blowering and ‘lost’ to Snowy 2.0.
• The practical recyclable capacity of Snowy 2.0 is considerably less than the claimed 350 GWh.
• Whenever Tantangara were emptied, it would then require several months of pumping to be returned to full supply.
• If Snowy 2.0 ever generated its claimed 350 GWh of energy, it would take 500 GWh of pumping energy to re-charge, incurring 150 GWh of losses.

Uneconomic

It is clear that the cost of Snowy 2.0 will be many times greater than the original $2 billion and then $3.8 billion estimates – a single contract for $5.1 billion has recently been awarded. It is likely that the project, including transmission, will be $10 billion, or even more. At anything approaching this amount the project is totally uneconomic.

Snowy Hydro is wholly owned by the Commonwealth Government, hence the Australian community. The ultimate bearers of the risk of Snowy 2.0 are the Australian community.

In addition to its shareholding the Commonwealth increased the commitment of public funds through a $1.38 billion subsidy into the project.

Flawed planning and approval process

The Main Works EIS is only part of the assessment of the broader Snowy 2.0 Project.

It is over 2½ years since Snowy 2.0 was announced (March 2017). Over the intervening period the Snowy Hydro Board has authorised the Final Investment Decision, the Government has approved the project and kicked in $1.38 billion, a $5.1 billion contract has been awarded, construction commenced 8 months
Attachments
Elizabeth Searle
Comment
Mollymook Beach , New South Wales
Message
See attached document
Attachments
Alan Outhred
Object
SUMMER HILL , New South Wales
Message
See attachment.
Attachments
Jonathon Howard
Object
Albury , New South Wales
Message
Please see the attached file.
Most of the pumping electricity for Snowy 2.0 will come from coal-fired power stations, not renewables. Worse still, Snowy 2.0 will be a net consumer of electricity, not a generator, with ‘round-trip’ losses of 30%, plus another 10% for transmission. Why is Snowy 2.0 marketed as a boon for renewable energy when this is clearly not the case?
The project is not economic. The original $2 billion cost estimate is now approaching $10 billion, including transmission. Why is this project proceeding when it will likely run at a loss?
Many other pumped storage opportunities have been identified in NSW with a combined capacity considerably greater than Snowy 2.0. Why were these alternatives not explored before proposing construction within a National Park?
Attachments
Jenny Medd
Object
NASHDALE , New South Wales
Message
I object to this project. Please see my submission attached.
Attachments
Sean McSharry
Object
MOSMAN , New South Wales
Message
There are detailed submissions on the environmental degradation of the National Park that I will not repeat. But which I support. It is no way to inflict damage of a permanent kind in some parameters upon a high percentage of the Park. This is not what Parks are about.

From an economic standpoint, there is no business plan, there is no independent review of the project's possible minute contribution to energy security, there is no cost/benefit analysis, there is pretence that the connecting power lines are someone else's project (yet there are large dollars in connecting to NSW and Victoria), the return on equity/possible lifetime subsidy by taxpayers' money is not mentioned. The Federal Government has already spent over one Billion dollars of securing ownership of the Snowy Mountain Scheme. How much more, and when would it make any contribution?

No sane Government o]would proceed with such investments until the filters suggested have been rigorously undertaken and exposed to the Australian nation, openly and frankly.

Be aware that the original scheme, splendid as it was, created considerable damage, and was in fact a taxpayer subsidy scheme for the Murray basin agricultural industry rather than an electricity scheme. It is a a sort of standby electricity operation.

Don't let's make the same mistake twice, in the same location!
Bruce Robins
Object
Glebe , New South Wales
Message
I have expressed my comments in some detail in the attachment.
Attachments
Jonathan Smith
Object
METUNG , Victoria
Message
Please see attached submission
Attachments
Kay Shields
Object
KEILOR DOWNS , Victoria
Message
Snowy 2.0 Submission

The proposed Snowy 2.0 energy solution should not proceed. The Environmental Impact Statement says this construction will permanently damage rare mountainous habitats and species over large areas of the Kosciuszko National Park.

So many other alternatives are already available to produce energy in environmentally responsible ways. Why would we damage this unique site and expend a great deal of taxpayers’ money when better energy solutions are already available in Australia? It is vandalism and ideological madness at the highest level.

This park is an Australian icon that has stood for 100 million years. It does not belong to the government, the state or even the people. It belongs to this country and this planet and should remain as it is, a wonderful gift to this nation to appreciate, revere and protect.

Yours sincerely,
Kay Shields
16 October 2019
Khye Abbott
Object
URUNGA , New South Wales
Message
I do not support the idea of the Snowy 2.0 Project.
The National Parks of this country are treasures that need to be worshiped and protected not exploited and destroyed by bad planning and short sightedness.
The environmental impact that this project will have on the park is simply unacceptable and disturbing...if this kind of destructive project can happen in one of our most beloved National Parks then what hope is there for the rest of Australia's fragile ecosystems?

As a 25 year old male I feel a responsibility to share my opinion on these matters as it is myself and my family who will have to deal with the problems these projects will cause in the near future.
I am not a scientist or a professor with an expensive education and big words to say and major facts to build an argument on...I am an ordinary citizen who strongly believes in preservation over exploitation and I will do my best to help protect the environment.
Attachments
Name Withheld
Comment
EAST JINDABYNE , New South Wales
Message
To the Dept of Planning
Re: Public Submission regarding Snowy 2.0 Main Works

My concerns regarding the Snowy 2.0 project mainly revolve around the impacts on recreational access and the environment in the Tantangara region of KNP.
The Tantangara area is a remote, stunning and unique region, which I have visited for many years, camping, horse riding, swimming, fishing and water skiing.

My concerns regarding Snowy 2.0’s impacts on the Tantagara area include:

CLOSURE OF TANTANGARA ROAD
It is stated in the EIS that Tantangara Road will be closed for nine months for upgrade work (up to December 2020)
If the start to this work is delayed or if the work itself runs over schedule then all recreational facilities in the Tantangara area will be inaccessible for the 2020/2021 summer season.
With the winter conditions experienced in the Tantangara area, is it realistic that all road upgrades would be completed in that timeframe at that time of the year and not be delayed?
What guarantee is there that the Tantangara Road will be re-opened at the conclusion of the upgrade works? And if so what will the access conditions be - will it be timed access? Will there be limitations to non-construction traffic on the road?

CAMPGROUND (& HORSE CAMP) IMPACTS
According to the EIS, Wares Yards will be either closed or will be affected by dust, noise and traffic, meaning it will be an undesirable location for camping.
Rocky Plain will be affected by traffic noise from increased traffic on the Snowy Mountains Highway
Old Snowy Camp and Currango Homestead will be inaccessible when the Tantangara Road is closed (Port Phillip Fire Trail is not a suitable alternative as access is affected by lake levels)
The Long Plain area campgrounds (Long Plain, Cooinbil) are already busy and do not have the capacity to act as alternatives for the Tantangara region horse camps and campgrounds
Are there plans to provide alternate horse camps (for example on the Eucumbene side of the Snowy Mountains Highway) to offset the loss of campgrounds and facilities in the Tantangara area?

CURRANGO HERITAGE AREA
Currango Homestead and heritage area is accessible via Tantangara Road and is a popular accommodation spot for horse riders, fishermen and bushwalkers. This is evident from the current bookings, for example the Pines Cottage for the coming 2019/20 season already has almost every weekend booked out.
Port Phillip Fire Trail is not a suitable alternative for access as it is regularly closed subject to lake levels
The Currango Homestead has a permanent caretaker in residence who maintains the grounds and the buildings. If this maintenance is not ongoing during the 2.0 project then the historic buildings and other features in the heritage precinct will deteriorate.

TANTANGARA RESERVOIR AND ITS TRIBUTARIES
Tantangara is a popular camping, boating and fishing spot which will be irreparably damaged by the impacts of Snowy 2.0. The visual amenity will be permanently impacted by the intake/outlet structure and also by the spoil which will be disposed of on the shore of the reservoir - reducing the size of the lake.
If boat access is allowed from the northern end of the Lake during construction, how far will this extend and will the entire Lake be affected by the turbidity from the spoil placement?
Many fishermen prefer to walk or ride to more remote locations and fish in the small streams in the area so will the quality of the water in these tributaries be affected or will there be a risk of pest species getting into the smaller tributaries?
The Upper Murrumbidgee flows directly out of Tantagara Dam wall, can we be sure the project won’t impact on water quality or that invasive aquatic pests like redfin won’t spread into the Murrumbidgee or into the Eucumbene Dam?

COMMERCIAL HORSE RIDING OPERATORS
Reynella Rides is a commercial operator in the area who have been taking visitors into the region on horse riding safaris for over forty years, from November through to the end of April in the Tantangara area. The three and five day rides camp mainly at Wares Yards and sometimes at Rocky Plain. Both these campgrounds will either be closed or will be affected by noise and potentially dust from the Snowy 2.0 traffic and works.
Will any alternative campground locations that allow for horses be provided to Reynella Rides and will the areas they ride with visitors be restricted due to Snowy 2.0 works?

I hope that these concerns will be taken into account and addressed through the approval process of Snowy 2.0 Main Works.

Pagination

Project Details

Application Number
SSI-9687
Assessment Type
State Significant Infrastructure
Development Type
Electricity generation - Other
Local Government Areas
Snowy Monaro Regional, Snowy Valleys
Decision
Approved
Determination Date
Decider
Minister
Last Modified By
SSI-9687-Mod-1
Last Modified On
28/01/2022

Contact Planner

Name
Anthony Ko