Snowy 2.0 - Main Works

Please refer to the attachment

Dear Assessment Team,
I wish to formally object to the Snowy Hydro 2 project for the primary reason that its collective impacts are unacceptable at this point in time in our history. Our environment has suffered immense loss of habitat, and this project, no matter how the "benefits" may be presented, is simply not appropriate. There are alternatives to achieving the stated power generation/storage objectives, and these are the way of our future, not Snowy Hydro 2.
The project area is extremely large, and the area of the ecosystems which will be detrimentally affected by the project is also very large.
A national park needs protection, not degradation, and Snowy Hydro 2 should not be granted an exception to this fundamental right of a national park.
The impacts on the Snowy River from the Snowy scheme have been immense. We know the complex negotiations which have happened in the past to try to restore flows to this significant waterway. Such environmental damage is not acceptable - it happened then, largely because not enough of the right people knew better. We do know better now, and the risks to groundwater as a result of the proposed tunneling is not acceptable.
The line drop (transmission loss) of generated power from Snowy Hydro 2, because of its distant location from end users, is a waste. A network of pumped storage projects, carefully selected for minimal environmental harm, would offer a much better solution, and with a much higher percentage of "usable" power if sited near end-users.
The proposed Snowy Hydro 2 project is inappropriate for the above reasons. A number of big companies and organisations have vested interests in the project, but it is the wrong project. There needs to be a thorough exploration of alternative projects to meet stated energy supply objectives, which is lacking in the EIS, even though this is required to have been done (regs.).
I request that the assessment team review the EIS in an unbiased way, and take into account the points raised in my submission, and ultimately, refuse the development.
Thank you.
Yours sincerely,
Paul Bourne

See attached submission

I would like to lodge an objection to the proposed Snowy 2.0 - Main Works. Originally this plan sounded beneficial as a producer of renewable energy, However, the scale and the devastation that this project will apparently produce means to me that it should be abandoned now before any more money is wasted on it. The project will destroy huge areas of native vegetation, including threatened species habitat. It will also apparently lead to reduction in water flows - something that just cannot be allowed at this critical time (or ever) for the Murray River. It is strange that this huge devastation would not normally be proposed or allowed in a National Park - so why here? Certainly not because it is the only place for pumped hydro storage - there are apparently other areas that would not cause the destruction that Snowy 2.0 would cause. Kosciusko National Park is a magnificent area - it must be preserved and protected for its beauty, its unique native species and its important water flows.

If this project will affect access to tantangara for fishing and camping I object to project unless alternative access. Need alternative access from tantangara Rd for recreational purposes

My husband and I drive down tantangera road with our children quite regularly as we go fishing and camping around these areas. It would be quite disappointing for our family to miss out on seeing the beautiful country on our road trips and not having the opportunity to show our children this beautiful part of our land. We go camping at wares yard and would love to continue to do so on a regular basis as it is very important for our family traditions. We don't think it is fair to stop us from doing something we have been doing together and individually for the past 20 years.

I strongly object to the entire concept of Snowy 2.0. It is financially and environmentally irresponsible for the government to try to push this to fruition.
Before the first clod of soil has been turned, we have already seen the cost of the project increase from $2billion to over $5billion, without even including the installation of transmission infrastructure. The closure or part closures of both Talbingo and Tantangara Dams will affect revenue for local businesses who supply equipment for fishing and camping. Tourism will suffer. Also, the entire concept of pumping water to Tantangara using "off-peak" electricity, is in defiance of improving CO2 emissions. The same energy that pumps the water uphill at night time will be sourced from coal fired power stations, because solar does not make power at night. Pumped hydro was a great "battery" concept back in the 1950s when off-peak electricity helped stabilise the power grid, but it is not suitable as a bulk energy storage system today when coal is being replaced as an electricity source.
Environmentally, the Snowy 2.0 project does not make things any better. Putting the spoils of the tunnel excavations into the bottom of Talbingo Dam reduces it's storage capacity. With drought affecting the nation presently and forecasts of even dryer conditions, how is reducing our catchments a smart idea? Also, the quality of water is a big concern, especially for the trout in the dam. I have been a trout fisherman for over four decades in the Snowy region and anything which could lessen the number of trout in the area is bad for me and bad for fishermen who come from far and wide to catch the beautiful species that have lived there for generations. I'm sure the N.S.W government will have no plans to help re-populate the fish, nor to stop the spread of Redfin. It will only take a few hundred eggs to get sucked into Tantangara and that ecology will be destroyed by this invasive species.
Also, with all that water moving rapidly, how will the trout in Tantangara Dam handle the inevitable clouded water from the extra currents? Tantangara is not like Talbingo Dam, in that the bottom is mainly mud and silt instead of rocks. Any extra flow from pumping water will stir up this silt and create a place where trout cannot survive. For evidence of the trouts' inability to cope with this continuous change in water quality, look no further than Blowering Dam which has lost most of its trout fishing stock due to silt muddying the water, constantly changing levels and invasive species eating up their offspring.
With Tantangara then becoming a part of the hydro scheme, how will the flow of water into the Murrumbidgee River be maintained? Already there have been studies that show insufficient flows to maintain habitats prior to the weir's construction. How then, when Tantangara is interlinked with this new system, do they plan to keep enough water running into the Murrumbidgee River? It will probably come from Talbingo, if that decision is made, but then it's storage will be further reduced.
In conclusion, I submit that the Snowy 2.0 project is not just financially and environmentally unsound, but also that there are better ways for the N.S.W and Australian Federal Government to spend this enormous amount of money. Whilst energy is a big issue at the moment, I believe water is an even bigger problem. Why should we be toying around with hair-brained schemes designed last century, instead of looking at 21st Century technology and ideas for powering our country. Building a power generation system that relies on water, when drought is and continues to wipe out livelihoods, just defies belief. How can a government with any wisdom look for a solution to a crisis, by relying on another system that is also facing a crisis. There must be a smarter way.

Department of Planning, Industry and Environment
Major Projects Team
Attention: Anthony KO

2nd November 2019
Submission on Snowy 2.0 Main Works Environmental Statement

I wish to make a strong statement opposing the construction of the Snowy 2.0 Project as described in the Main Works Environmental Impact Statement (EIS).

I live in Queanbeyan, NSW & have always regarded the Snowy Mts. as 'my home park', visiting during all seasons. I have been observing the early groundworks as they occur in the northern part of the park & I am extremely worried at the potential damage to an extremely fragile & already vulnerable (due to the impact of wild brumbies & climate change effects) area of the park. It is not a small area, it will have some degree of impact on one third of the park.
The impact on the sub-alpine areas of the park is magnified by the increase in temperatures in Australia - these rare habitats will not recover from any disturbance & are a vital habitat for any species that are forced to retreat due to loss of their present habitats by global warming.
The huge footprint of the construction is understated in the EIS document. There will be 100's of kms of new & upgraded existing roads; kms of transmission lines with a 120 metre-wide easement swathe; tunnel construction will have unknown effects on ground water, especially in the sensitive Yarrangobilly area. Construction camps for workers & equipment storage areas will affect the delicate & vulnerable landscape & wildlife for all future as evidenced by the 'scars' still visible throughout KNP from the initial Snowy Mts. Scheme.
The EIS does not give a detailed or adequate explanation of how it is going to deal with the mountains of excavated materials that will come from the construction. Any dispersal/disposal of this material will have an unalterable effect on the unique landscape of KNP. It cannot be easily rehabilitated in such a harsh climate.

One of the most worrying impacts is the certain dispersal of unwanted aquatic pests such as redfin perch, eastern gambusia, wild goldfish, the Epizootic Haematopoietic Necrosis Virus (EHNV) & Elodea weed throughout the waterways of KNP and downstream. My questioning of staff in the NSW Freshwater Fish agency tell me the EIS does not assure them that there will not be an environmental catastrophe when inevitably these noxious species are transferred from Talbingo to Tantangara water reservoir. KNP is a renown recreational angling destination in the state/Australia, this will be ruined by the dispersal of these pest species within KNP & worse still, eventually the inevitable will happen & they will find their way into the Murrumbidgee R., Lake Eucumbene & the Murray R. As if these river systems don't already have enough problems to deal with?

The part of KNP to be impacted by Snowy 2.0 is an area known for its wilderness & outstanding aesthetic qualities, all of which will be seriously impacted by the infrastructure associated with this project, especially the massive transmission lines & their swathe of cleared easement.
2019 has been the 70th Anniversary of the start of the original Snowy Mts. Scheme & I believe the government has been 'pushing' the ideal that this project made us great as a nation with its amazing engineering feats & that it is time we saw this 'greatness' rise up again! The fact that it sounds environmentally sound, using water as a renewable source of much needed energy is another carrot being dangled at an unsuspecting community who will be bearing the real cost of this 'feel-good' project. I believe it is not economically feasible for this project to contribute in any sustainable way to our projected power requirements - an idea being touted by our politicians!

When I travel through the northern end of the park I see construction work that is already having a considerable environmental impact on the ethos of a national park of this stature & yet the Main Works EIS has only recently been made available for public comment. This lag in an environmental assessment of the impacts of such a massive project on a world renown park with a unique habitat & aesthetic within Australia is indicative to me that we are being 'hoodwinked' into accepting this project because it will be 'good for the state/country'.
Where is evidence of the 'offsetting process'? This system is a joke, as any comparably classified (alpine & sub-alpine) areas of NSW are already contained within the KNP.
In conclusion I believe the Snowy 2.0 Project as outlined in the Main Works EIS, does not meet the requirements of an 'Ecologically Sustainable Development' as described in the Environmental Planning and Assessment Act. The impacts of a development of this scale will ameliorate all the original reasons for declaring this area of NSW a national park & makes a mockery of our environmental legislation.
Yours sincerely,
Alison Crawley

I agree with the proposal to dump spoils into Talbingo Dam. However I disagree with the disposal methodology, which is to build a new bitumen road and use B double trucks to transfer spoils to Ravine Bay.
I suggest that the spoils be transferred using an inland waterways transport system that utilises an autonomous barge train.
The use of split hopper barges was considered in the initial project phase but was discarded pursuant to quotes from marine companies being too high and the cost to deliver too expensive. The tender specification provided to marine companies was based upon a traditional method of spoil management, which uses a single large split hopper barge (1500m2). A vessel of this size requires modulation to be transported to site and recommissioning to be mobilised, rendering it a logistically difficult and very expensive exercise.
Instead of using the above method I suggest using an autonomous barge train of six smaller barges (335m2) linked together to provide higher volume. The barge train is equipped with autonomous thrusters, which have 360-degree steering capability thereby offering “intelligent manoeuvrability” capacity. The autonomous barge train offers a number of advantages over the “road & truck” concept.
- fuel efficiency
- negates the need to construct a new road in a national park
- higher safety outcomes due to reduce personnel involved in operation therefore lower risk
- “intelligent” manoeuvring delivers pinpoint accuracy to a location based within the spoil dump grid
- cheaper capital cost outlay
- cheaper maintenance outlay
- higher volume per movement reduces size of stock pile quickly and therefore reduces environmental footprint on shoreline
- heavy equipment can be transported to site via barges
- smaller split hoppers have less draft enabling them to create a higher spoil mound
Barge trains are used extensively in Europe and America on inland waters and the technology to create autonomous, intelligent barges is also commercially available.
The spoil management method I am proposing has the ability to remove spoils as they are produced, which is the normal approach of projects of this scale. Creating a stockpile for removal at a later date dramatically increases the environmental footprint of this part of Snowy Hydro 2.0 and significantly contributes to project costs. Autonomous barge trains have the capacity to reduce stockpiles quickly and are cost efficient.

please see attachment

This will create a lot of traffic through Cooma, is there any possibility that the construction of the tunnels could be made in Adaminaby instead of Polo Flats Cooma? Construction material could come to Adaminaby via a direct road from Canberra, this road is due to be upgraded soon. Workers could be bused in daily from Cooma. This is just a suggestion, hoping you will consider. Adaminaby has ample water and electricity and I believe it could handle this enterprise.
Regards,
Jan

see attachment

The Project, in its current form, cannot be approved by way of s.4.15 EP&A

I am strongly opposed 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.

Kosciuszko National Park is quintessentially Australian. It is significant internationally, nationally, and in its regional setting. The value of its landforms, rivers, streams, native plants, native animals, wilderness, ecosystem processes, aesthetics, cultural significance, recreation and tourism will all be significantly impacted by this project.

In addition to the unacceptable environmental impacts on KNP, the fractured assessment process means the full catastrophic extent of the environmental impacts of the project will not be assessed by the main works EIS. Additionally, there is a distrinct 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. Furthermore, alternatives have not been adequately addressed by the proponents.

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.

See attached for detailed submission

Submission on Snowy Hydro 2.0
I am greatly concerned about the proposed Snowy Hydro 2.0 and do not support it going ahead. My reasons are as follows:
1. The EIS contains a totally incomplete and inadequate assessment of alternatives to Snowy 2.0.
2. Snowy Hydro claims that Snowy 2.0 will benefit the renewable energy sector. Yet, for the next decade or so, most of the pumping electricity for Snowy 2.0 will come from coal-fired power stations, not renewables. It will also be a net consumer of electricity, which means that the carbon emissions for NSW will increase, not decrease.
3. Snowy 2.0 isn’t economic. The original $2 billion cost estimate is now approaching $10 billion, including transmission.
4. Many other pumped storage opportunities have been identified in NSW with a combined capacity considerably greater than Snowy 2.0. Why haven’t these, together with batteries and other forms of storage, been explored before proposing construction of such a huge project within a National Park?
5. 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. Normally, this type of project would not be allowed in a National Park. Why, then, is it being considered in Australia’s most frequently visited park?
6. The EIS has understated the full environmental impact on the Park. The vegetation clearance, earthworks, dumping and damage to water streams and water-dependent ecosystems will exceed 10,000 ha. Clearing of native vegetation (when we so desperately need to keep our trees) will destroy 992 ha of threatened species habitat.
7. Noxious weeds and pests will be spread through the Park.
This proposal is totally unacceptable. The destruction of large sections of the National Park for a badly thought out, environmentally destructive and economically unsound project cannot be justified.

The Ryde Gladesville Climate Change Action group is composed of over 650 people who are greatly concerned about climate change and the need to for urgent action to reduce our carbon emissions and move to 100% renewables by 2030.
We are, therefore, greatly concerned about the proposed Snowy Hydro 2.0 and strongly do not support it going ahead. Our reasons are as follows:
1. Snowy Hydro claims that Snowy 2.0 will benefit the renewable energy sector. Yet, for the next decade or so, most of the pumping electricity for Snowy 2.0 will come from coal-fired power stations, not renewables. It will also be a net consumer of electricity, which means that the carbon emissions for NSW will increase, not decrease.
2. The EIS has understated the full environmental impact on the Park. The vegetation clearance, earthworks, dumping and damage to water streams and water-dependent ecosystems will exceed 10,000 ha. Clearing of native vegetation (when we so desperately need to keep our trees) will destroy 992 ha of threatened species habitat.
3. Snowy 2.0 isn’t economic. The original $2 billion cost estimate is now approaching $10 billion, including transmission. The EIS contains a totally incomplete and inadequate assessment of alternatives to Snowy 2.0.
4. Many other pumped storage opportunities have been identified in NSW with a combined capacity considerably greater than Snowy 2.0. Why haven’t these, together with batteries and other forms of storage, been explored before proposing construction of such a huge project within a National Park?
5. 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. Why, then, is this type of project being considered when normally no such project would be allowed in a National Park.
6. Noxious weeds and pests will be spread through the Park as a result of the works.

Pamela Reeves
Secretary
Ryde Gladesville Climate Change Action Group

Conservation impacts of Snowy 2.

The Snowy 2 concept is at face value not unattractive from a conservation viewpoint. We applaud the development of energy storage systems that can reinforce the advantages of renewable energy in avoiding the climate impacts of fossil fuelled electricity generators. But the impacts of land clearing, roads, accommodation camps, spoil dumps etc. for the major engineering works involved in Snowy 2 will be detrimental to the ecosystem protection values of Kosciuszko National Park, arguably the most important in NSW. These impacts must therefore be weighed against the benefits and alternatives, which is properly the function of an environmental impact assessment.

The option for many smaller alternative pump-storage sites, explored by Prof. Blakers of ANU, are acknowledged in the project summary document but dismissed without cost-benefit-impact analysis in that document. The Snowy 2 concept was apparently the thought-bubble of ex-Prime Minister Turnbull, prompted no doubt by SMC engineers.

Assurances of environmental protection or restoration for Kosciuszko National Park features and values under Snowy 2 are called into question by the erratic history of environmental management by the NSW Government. From 1889 to 1957, NSW over-issued summer grazing leases with the same gay abandon more recently recognisable with Murray-Darling water rights. Seasonal overstocking and damaging erosion followed the free-for-all pattern of gold-mining at Kiandra.

Fortunately, with the creation of Kosciusko State Park in 1944, the erosion impacts of overgrazing by sheep and cattle were recognised as incompatible with engineering aspects of plans for the Snowy Mountains Hydroelectric Scheme. A far-sighted program by the Soil Conservation Commission of soil stabilisation and revegetation eg. around Mt Twynam on the Main Range was established to protect catchments, streams and reservoirs against erosion and siltation.

After establishment of the NSW National Parks and Wildlife Service and Kosciusko National Park in 1967 a firmly conservation based program was pursued but steadily undermined over subsequent decades by resort over-development, run-down of NPWS staffing for scientific and wildlife management and political distortion of priorities. The most recent and damaging of such perverse priorities has been the Kosciuszko Wild Horse Heritage Act, placing higher protection priority for feral horses than on threatened native species. Horses, having bred to a population of around 6000 are, as with stock prior to 1944, again pugging streams and swamps, mobilising silt, destroying habitat for eg. the corroboree frog, driving macropods from valleys and plains along the Cascades-Tin mines track and now even threatening walkers with dangerous attack. The NSW Government’s failure to address this current management problem destroys credibility for the promise of environmental responsibility in developing Snowy 2.

Snowy 2 might indeed be beneficial, even essential, to address climate change but it will not be accepted as such unless rigorously and transparently assessed against decentralised energy storage options in terms of cost, benefit and impact.

Please see the attached submission on behalf of STEP Inc.
We oppose the project in its current form. The ability of the project to achieve its objectives have not been proven from the information provided to date.

1. AABR is not convinced that sufficient cost-benefit analysis has been done to ensure that this project is the best way of attaining pumped hydro for Australia, taking into account the environmental losses that are likely to occur. To gain social license for Snowy 2, the net environmental benefits and need must be much more thoroughly evaluated after consideration of environmental risk of this project and the availability of alternative projects

2. AABR is also not convinced of the commitment of the project to an appropriate level of ecological restoration. Despite some good work in rehabilitation in recent decades in the National Park, the predictability of rehabilitation or restoration outcomes is not sufficiently reliable to remove environmental risk associated with the Snowy 2 developments. Most industrial development in Australia have failed to attain acceptable restoration outcomes. Satisfactory results have only been attained where there is a very high commitment to restoration to the pre-existing natural condition - which is missing in the current Snowy 2 development proposal.

To gain social license for Snowy 2, the rehabilitation plan framework would need explicit commitment to a five-star recovery outcome for all sites in a manner consistent with the National Standards [Standards Reference Group SERA (2017) National Standards for the Practice of Ecological Restoration in Australia. Second Edition. Society for Ecological Restoration Australasia URL: http://www.seraustralasia.com/standards/home.html] as well as commit to adequate compensation for the inevitable net environmental damage of such a project. This compensation would need to be provided in the form of offsets that attain additional restoration of current degradation in Koscziusko National Park including the removal of feral horses and rehabilitation of damage to bogs and fens created by their presence.

Comments are in the attachments