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State Significant Development

Determination

Stubbo Solar Farm

Mid-Western Regional

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

Development of a 400 MW solar farm with energy storage and associated infrastructure.

Modifications

Archive

Request for SEARs (1)

SEARs (1)

EIS (11)

Response to Submissions (2)

Amendments (12)

Additional Information (2)

Determination (3)

Post-determination Notices (1)

Approved Documents

Management Plans and Strategies (27)

Notifications (1)

Other Documents (7)

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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Enforcements

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Inspections

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

Submissions

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Showing 1 - 20 of 38 submissions
DPI Fisheries
Comment
,
Message
The construction of the internal access roads and cable crossings in Stubbo Creek should be in accordance with DPI Fisheries Guideline document: Policy and Guidelines for Fish Habitat Conservation and Management (Update 2013).
Fire and Rescue NSW
Comment
Greenacre , New South Wales
Message
I refer to the submission of the request for agency input into the Environmental Impact Statement (EIS), dated December 2020, for the Stubbo Solar Farm to Fire & Rescue NSW (FRNSW). The relevant parts of the proponent’s EIS have been reviewed and the following comments are submitted for consideration. The proposed energy storage facility will have an indicative capacity of 200MW.

Large scale solar farm developments are usually located within NSW Rural Fire Services’ (RFS) fire districts. Notwithstanding, in the event of either a significant fire event or hazardous material incident (hazmat), FRNSW will be responded to either assist the RFS or to fulfill the role of the designated hazmat combat agency.

It is FRNSW experience that battery energy storage solutions (BESS) present unique hazards and risks to our personnel when fulfilling their emergency duties. It is highlighted that the Fire and Rescue NSW Act 1989 (the Act) imposes specific statutory functions and duties upon the Commissioner of FRNSW. Clause 5A of the Act requires the Commissioner to take all practicable measures for preventing and extinguishing fires and protecting and saving life and property within a FRNSW fire district. Clause 5A of the Act also requires the Commissioner to protect and save life and property endangered by hazmat incidents and for confining a hazmat incident and for rendering the hazmat site safe.

In addition, the Work Health and Safety (WHS) Act 2011 (and its subordinate Regulation) classify FRNSW as a person (entity) conducting a business or undertaking (PCBU). Clauses 34 and 35 of the WHS Regulation impose specific obligations upon a PCBU to identify hazards and manage risks at workplaces. A site involved in fire or hazmat incident is deemed to be a FRNSW place of work.

Due to the electrical and fire hazards associated and the potential risk to the health and safety of firefighters, both FRNSW and the NSW Rural Fire Service must be able to implement effective and appropriate risk control measures when managing an emergency incident at the proposed site.

In the event of a fire or hazardous material incident, it is important that first responders have ready access to information which enables effective hazard control measures to be quickly implemented. Without limiting the scope of the emergency response plan (ERP) requirements of Clause 43 of the Work Health and Safety Regulation 2011 (the Regulation), the following matters are recommended to be addressed:

1. That a comprehensive ERP is developed for the site.

2. That the ERP specifically addresses foreseeable on-site and off-site fire events and other emergency incidents (such as fires involving solar panel arrays, battery energy storage systems, bushfires in the immediate vicinity) or potential hazmat incidents.

3. That the ERP details the appropriate risk control measures that would need to be implemented to safely mitigate potential risks to the health and safety of firefighters and other first responders (including electrical hazards).

Such measures will include the level of personal protective clothing required to be worn, the minimum level of respiratory protection required, decontamination procedures to be instigated, minimum evacuation zone distances and a safe method of shutting down and isolating the photovoltaic system (either in its entirety or partially, as determined by risk assessment).

4. Other risk control measures that may need to be implemented in a fire emergency (due to any unique hazards specific to the site) should also be included in the ERP.

5. That two copies of the ERP (detailed in recommendation 1 above) be stored in a prominent ‘Emergency Information Cabinet’ located in a position directly adjacent to the site’s main entry point/s.

6. Once constructed and prior to operation, that the operator of the facility contacts the relevant local emergency management committee (LEMC). The LEMC is a committee established by Section 28 of the State Emergency and Rescue Management Act 1989. LEMCs are required to be established so that emergency services organisations and other government and non-government agencies can proactively develop comprehensive inter agency local emergency procedures for significant hazardous sites within their local government area. The contact details of members of the LEMC can be obtained from the relevant local council.

7. Page 2 of the EIS states that the proposal includes a 200MW battery energy storage system. FRNSW recommends that as a Condition of Consent a Fire Safety Study (FSS) be prepared for the BESS component of the site and submitted to FRNSW for review and determination. The FSS should be developed in consultation with and to the satisfaction of FRNSW.

For further information please contact the Fire Safety Infrastructure Liaison Unit, referencing FRNSW file number BFS20/4077. Please ensure that all correspondence in relation to this matter is submitted electronically to [email protected].
WaterNSW
Comment
PARRAMATTA , New South Wales
Message
Please find attached WaterNSW's no comment response.
Attachments
carey mustow
Object
COPE , New South Wales
Message
Cary and Julie Mustow 915 Blue Springs Rd Cope 2852 Application No: SSD_ 10452. We object to the proposal. Reason being it will devalue our property having such an ugly development in close proximity to our home. It will ruin the rural ambiance of the area, the traffic will become dangerous and annoying whilst under construction ,when built there well be continuing traffic from service vehicles and employees .Why would you put such an unsightly development in such a scenic location. Surely there are other locations that would be better suited .I am also appalled at the way this is being implemented ,why is there no face to face consultation? Why have you just sent blurred and vague maps only.
ROADS AND MARITIME SERVICES DIVISION
Comment
,
Message
Please find attached TfNSW submissions for SSD-10452
Kind regards
Carmel
Attachments
Regional NSW - Mining, Exploration & Geoscience
Support
,
Message
MEG - GSNSW have no issues.
Attachments
DPI Agriculture
Comment
DUBBO , New South Wales
Message
Good morning

Please find a response to the environmental assessment.
Thank you
Mary Kovac
Attachments
Heritage NSW – Aboriginal cultural heritage (ACH)
Comment
Sydney , New South Wales
Message
Dear Javier,
Please find Heritage NSW comments regarding Aboriginal cultural heritage attached.

Kind regards
Rebecca Yit (on behalf of my colleague Phil Purcell)
Attachments
Crown Lands
Comment
,
Message
Crown Lands has no further comments regarding this proposal as all previous comments have been addressed in 10.3.2 of the EIS.

Please note that Crown Lands has incorrectly been referred to as "Service NSW - Crown Lands" in the EIS. It should read "DPIE - Crown Lands" (page 96/332).
Department of Transport
Comment
Haymarket , New South Wales
Message
RMS will be providing a consolidated letter on behalf of TfNSW.
Biodiversity and Conservation Division
Comment
DUBBO , New South Wales
Message
Hi Javier,
Please find attached BCS's response to the Stubbo Solar Farm EIS. If you have any questions please get in contact.
Regards, Renee.
Attachments
ENVIRONMENT PROTECTION AUTHORITY
Comment
BATHURST , New South Wales
Message
Please see attached response from the EPA
Attachments
Name Withheld
Object
STUBBO , New South Wales
Message
I object to the proposed development on a number of grounds and make the following comments in relation to the EIS and project in its' current form:
1. The proposal is not justified simply due to its proximity to an existing transmission line, being located within the Central West REZ (which had no community consultation or satisfactory local level engagement), along with an 'acceptance' from a couple of landowners who are are the only ones to benefit directly from this proposal whilst the surrounding residents, and the Gulgong community suffer both social and economic impacts in both the short and long term from the project.
2. The EIS and supporting traffic assessment fails to recognise cumulative impacts from increased traffic (both heavy and light vehicles) and resulting noise impacts for residents who live on Cope Road/ Blue Springs / Rouse Street during construction and also on the Gulgong township when up to 400 workers, plus contractors who would predominately drive from Mudgee due to the extremely limited accommodation options in Gulgong to attend work each day. The assessment has been conducted with a tube counter placed 1.7km west of the Blue Springs Road intersection (between 8 to 14 September 2020) and intersection surveys undertaken on 8 September 2020 (6am to 9am and 4pm to 7pm). This has been undertaken during COVID- 19 restrictions, including mine shutdowns and working from home arrangements and is not considered to be representative of the normal operating circumstances of the road network. This data cannot be used for assessment and the department should request a new study to be undertaken during full operating capacity (post COVID restrictions) and comparisons undertaken to attain current baseline traffic data for the assessment.
3. There is no assessment on the traffic impacts specifically on Medley, Herbert and Mayne Streets from construction workers. Vehicles (other than trucks over the current limit imposed) will not use Caledonia / Rouse Street when coming from Mudgee. They will always use the Gulgong CBD (Herbert / Mayne Street) which is already problematic with existing pedestrian crossings and lack of sight distances. This is further influenced by the high number of tourists who frequent the township. How will the developer ensure that project related traffic will not have an adverse impact on the Gulgong CBD, local school children and its residents over a 2 year construction project? This includes the proposed use of unsealed laneways such as Black Lead Lane and Stubbo Road for construction traffic. These existing gravel roads, used by local residents will not support the increase in traffic movements resulting directly from this project and the applicant is not committed to any upgrades?!
4. The application fails to recogise the existing lack of accommodation in the region and does not commit upfront to an accommodation strategy to support it's construction workforce. The Department should be enforcing an upfront strategy now to demonstrate the workforce can be accommodated locally - provision of this information prior to construction commencing is irrational and is not supported. Even if 50% of workers are not local residents (which is being extremely conservative given the history of previous SSD renewable works in the region where almost 98% of workers are not local residents), where are 200 workers alone proposed to be accommodated in this circumstance? The Ulan Village Green for example would only accommodate half of the 50% estimate of the labour workforce. On this basis, the applicant should be restricted to the provision of their own temporary accommodation on the subject development site for all DIDO labour workers to remove further impacts on the accommodation limitations already felt in the region and also reduce the risk of social and economic impacts on the township. This would also support a crime prevention strategy for the historic township that is held tightly by the local residents and community. A commuter bus to support all DIDO workers due to high likelihood of fatigue is also considered to be a compulsory requirement for this project.
4. The proposal does not commit to an appropriate waste disposal strategy. No wastes can be accommodated in the Gulgong Waste Transfer Station and this facility is already under pressure from existing residential wastes alone. Where will the waste from this project be accommodated if existing local facilities are already strained?
5. Confirmation is provided (and photos are available) to clearly demonstrate that the Railway level crossings associated with the Wallerawang Gwabegar Railway is in fact in use (S.2.4 of the traffic report). No impact assessment or recommended upgrades have been provided in this regard.
6. The site, and surrounding land is identified to contain saline soil environments which has a significant impact on steel components; shortening the life of such metal assets and additional reinforcement with concrete is required. Given the salinity in this area which has not been identified by the EIS, it is likely that greater levels of reinforcement is required. How does this implicate future rehabilitation of the site following the proposed 30 year life of the project? The proposed decommission strategy in the EIS is vague and does not sufficiently demonstrate how the site will return to its current land use. Leaving any form of cabling / concrete / steel piles below the surface (e.g. 1m as suggested) is not deemed appropriate and will have significant impacts on the ability for this land to return to its former use. Land degradation and erosion is a significant risk in this area and the application fails to acknowledge their responsibility to ensure the site is remediated appropriately. A comprehensive decommissioning plan is required now.
7. The applicant fails to recoginise the impacts a large scale solar farm will have on aeroplane operations including the existing operations on Stubbo Road.
8. The proposal generates a significant bushfire hazard that cannot be controlled by local emergency services including RFS. There is no proposal included to ensure that surrounding residents are not placed a greater risk from natural hazards including fires that escape the facility. Further there is no incorporation of onsite static water supply to assist in fire suppression and to reduce grassfire risks to nearby residents. A static water supply incorporated into an emergency management plan is required to be provided for assessment.

In summary, the scale of this project is illogical for such a small regional town to try to support over a 2 year construction period and will have significant negative impacts as outlined above. "Local" employment generation and economic stimulus as a way to gauge support for large scale renewable projects is considered to be a quick attempt at covering the real problems associated with such renewable developments and whilst short term and minor indirect economic benefits may be observed for the township, the overall cumulative impacts outweigh these minor benefits for such a large project. Gulgong cannot cope with this project during the construction phase alone and the applicant has failed to recogise the key issues, rather defers them to 'prior to commencement' when the approvals are already secured and no-one can legally challenge, let alone review, the content of these strategies after an approval is issued. This defeats the community consultation process and greater work should be done by the Department to support small communities under severe stress and anxiety due to the ongoing push, due to the legislative 'open door' policy for electricity generating works in NSW and greater strategic work is required (not just identifying REZ areas without community consultation of land affected) to provide greater certainty for landowners and the community moving forward.
Nat Barton
Object
WELLINGTON , New South Wales
Message
Please see attached
Attachments
Katelin Mustow
Object
MUDGEE , New South Wales
Message
I think this project is way to big for the area they are wanting to put it in the fact that there will be large trucks on that road is just scary as there is hardly room for cars. And not to mention if emergency services needed to be on the road. Also harming a lot of wildlife in the area. Not only that the sight of the solar farm will wreck the whole atmosphere of rural living and country life style. What are we gaining from this solar farm absolulty nothing
Ryan Lowbridge
Object
MUDGEE , New South Wales
Message
The area they are proposing to build this solar farm is too small. The only access road for heavy vehicles is way to narrow and has not designed for the weight and traffic it will have if this project goes ahead. There is no benefit from building a solar farm and it’s quite ironic to say it’s better for the environment when it’s less then 20 minutes away from 4 big coal mines. It will not provide long term jobs for locals, it will only attract backpackers who will in turn ruin small surrounding towns.
Not to mention what a fucking eye sore on some beautiful land.
Water Group
Comment
,
Message
Attached.
Attachments
Name Withheld
Object
Gulgong , New South Wales
Message
The site proposed for this solar farm is the catchment to the central and Western region’s main water supply dam, Burrendong Dam and damage to the solar panels by hail storm will contaminate the water for the region due to the toxins used in the manufacture of the panels. There has been a history of solar panels damaged but hail storm and lightning.

The proposed solar farm is on valuable agricultural land that supports the mid-western region economy, NSW and Australia at large and must be rejected.

The proposed solar farm is on farmland and it’s not consistent with the objectives of Mid-Western Regional Council Local Environmental Plan. The proposal will cause land use fragmentation.

The township of Gulgong is on higher elevation than the proposed location. There will be negative visual impact caused by this development especially from the lookout.

The project must be rejected because of these and many other reasons.

The benefits of this development are next to none to the local community to provide a balance between the negative impacts this development will have on the local economy.

Thank you.
Rick Campbell
Object
BERYL , New South Wales
Message
Submission Against Stubbo Solar Farm
1. Are Solar Farms Necessary?
Projections of future electricity grid production (Transgrid) indicate that solar will contribute to less than 50% of that production. A study commissioned by the Clean Energy Finance Corporation found if that rooftop solar were fully exploited it could provide up to 245TWhrs of electricity annually for all of Australia. Compare this with consumption of 218TWhrs (2018) and it can be seen that solar farms are non essential.
2. Who Benefits from Solar Farms?
Solar farms are a commercial enterprise built for profit. Power line companies make a profit by charging for the transmission of electricity. They will obviously promote solar farms at the expense of rooftop solar, because the electricity from rooftop solar is largely consumed on site. Rooftop solar undercuts the business model of both solar farms and power line companies.
And who ultimately pays for the construction costs, running costs and profits of both solar farms and associated transmission line infrastructure? The electricity consumer.
Furthermore the employment opportunities promoted by solar farm companies would still exist if solar panels were erected on roofs rather than in paddocks.
3. Solar Electricity is Cheap
Solar energy is promoted as a relatively cheap means of electricity production. It is, but the technologies to make it workable are not. Peak solar output occurs at midday, whereas peak electricity demand occurs in the evening when the sun is not shining. The technologies available to "firm" solar output include pumped hydro {limited by rainfall and elevation}, green hydrogen {inefficient and dangerous}, peak gas (carbon intensive} and batteries. Of these technologies, all of which will increase the cost of "cheap" solar markedly, batteries will probably prevail. The magnitude of this cost is demonstrated by the miniscule uptake of batteries by people with rooftop solar: it does not make economic sense. The great hope is that battery prices will continue to fall dramatically, but if and until this happens solar electricity will not be cheap.
4. Viability of Solar Farms
At present there are 15 large scale solar farms for sale in Australia Some companies {John Laing and Energy Solar) are withdrawing from Australia completely. Major contractors {eg Tomlinson} have gone bankrupt. Grid connection problems are common. Workers have been stood down without notice. The problems in the industry will be exacerbated with continued competition from the expansion of rooftop solar.
Which brings up the subject of the eventual decommissioning and site rehabilitation of solar farms. Assurances are given by the solar farm companies that this will not be a problem; but with viability and change of ownership issues it could well be. No bond money is set aside for this purpose. If bankruptcies (real or manufactured} occur, who will be responsible for the cleanup? If the planning authorities/government believe in the assurances given by the solar companies then they should have no hesitation in underwriting these costs. Otherwise planning approval should not be given.
Rick Campbell
Name Withheld
Object
GULGONG , New South Wales
Message
Refer letter attached
Attachments

Pagination

Project Details

Application Number
SSD-10452
Assessment Type
State Significant Development
Development Type
Electricity Generation - Solar
Local Government Areas
Mid-Western Regional
Decision
Approved
Determination Date
Decider
Executive Director

Contact Planner

Name
karl okorn