Sundown Solar Farm

Submission objecting to the Sundown Solar Farm and BESS Project being allowed to be built.
It is vitally essential that an electrical generating project, generating electricity to supply to the Grid must have a full supply of fuel in order that it is able to supply electricity for every second, of every minute, of every hour, of every hour, of every day, of the year, when it makes a bid to do so.
The Sundown Solar Farm and BESS Project has an insurmountable lack of fuel, which renders it to be impossible to ever be considered as a practical and economic supplier of electricity to the Grid.
To explain. The Sundown Solar panels will be powered by a weather fuel, Sunshine. At 12am, every day, the Sundown fuel tank is empty and will remain empty for the next seven to eight hours, until the Sun rises at 7am or 8am. If the weather is fine there may be six hours of viable fuel (10am to 4pm) and a further three hours (8.30am to 10am and 4pm to 5.30pm) of less viable fuel available. For a total of nine hours of fuel availability. But even this is very uncertain, because of the presence of fog, overcast cloud cover and rain, the fuel tank can suddenly become empty at any time. The amount of fuel available may be reduced to four hours or even on many Winter days, zero, with no electricity being produced. Beginning between 5pm and 6pm, the Sundown Solar Farm fuel tank becomes empty and remains empty for the next fourteen or fifteen hours. This means the fuel tank that supply the solar panels is empty for a minimum of fifteen hours of everyday and could even be empty for the whole day, with no electricity being produced.
As for including a BESS system, in the Sundown Solar Farm Complex. Batteries alone can never produce any electricity. Batteries only take in surplus electricity and then release less than they take out. Therefor batteries are inefficient in storing electricity. As the Solar Farm has fuel for only 40% of the day to generate electricity, the likelihood of there being a surplus to store is very uncertain and does not justify the cost of having the batteries. And will only increases the cost to the consumer.
For the reasons stated above, that leaves the Sundown Solar Farm with no control over a daily, significant shortage of fuel supply, that is held captive to the vagaries of the weather. This disqualifies the Sundown Solar Farm from ever being able to produce a reliable and economic supply of electricity to the Grid.
I believe it would be highly irresponsible to grant a planning permit to the Sundown Solar Farm and BESS Project, as rather than being able to make a positive contribution to the Grid, its inclusion would be totally negative and uneconomic.
Further points of objection.
1. In addition to my main objection, The Sundown Solar Farm will take up large areas of agricultural land. The loss of agricultural production will be substantial, both in volume and finance from sales per annum and the loss could continue for one hundred years or more, if the land is not restored. This has a wide effect on the surrounding towns and city of Inverell. Set against the electricity production of the Sundown Solar Farm, the lost economic agricultural production, may be more than the economic electricity production of the Solar Farm while it is in production. Once productive life of the Sundown Solar Farm has ceased in fifteen- or twenty-years’ time, then the lost financial benefit from lost agricultural production will continue to have a very significant effect on the surrounding towns and city of Inverell.
2. As all solar panels are declared hazardous e-waste in Victoria, the European Union and parts of the US., decommissioning will be a huge problem. With the Sundown Solar Farm Solar Panels containing heavy metals (such as cadmium telluride), glass, metal, sealants, copper, concrete steel reinforced blocks, steel stands, electrical cables, etc. They cannot be demolished by bulldozing and removed by excavators. But instead, they have to be removed carefully by hand which makes the cost prohibitive. And results in a huge amount of toxic waste to be disposed of, with in most cases landfill being the only option. Unless the Sundown Solar Farm puts up a restoration bond, there will be nothing stopping them from walking away and leaving the local Council and community with a very expensive noxious, Junk heap, that will pollute the whole area.
3. Consisting of so much electrification, the Sundown Solar Farm will create an extreme fire hazard to surrounding areas, particularly on a Total Fire Ban Day with the temperature at 43dC and a NW wind blowing at 50km/hr. Being so tightly packed together it would almost be impossible to contain a fire started within the Sundown Solar Farm perimeter. The surrounding land owners should be very concerned about their welfare.
4. If it should be approved to be built, then it should be mandated that the Sundown Solar Farm have a Public Liability policy to cover fire and other possible damage to surrounding areas of at least $500million to $1billion.
For the above reasons I strongly believe the Sundown Solar Farm should definitely not be granted a permit or allowed to be built.

This project will have a catastrophic impact on the residents, especially during the construction phase and will dramatically impact their quality of life.
The proposed access via Spring Mountain Road and Sturmans Road to the proposed development will turn a quiet rural road only used by local residents into a road that would see, according to page 182 of the EIS, 478 vehicles per day on Spring Mountain Road. How will landowners be able to safely move stock between paddocks? Local residents, pedestrians, kids, elderlies, the school bus will be put at risk sharing a road with trucks carrying dangerous materials and allowed to drive to up to 100km/hr. The dust from those trucks will also be a real danger for the health of the residents and their stock.
The noise levels stated in the EIS on page 162/163 do not comply with Noise Management Levels set by the Interim Construction Noise Guideline and the EIS also states that “Menari” and “Warrawee” properties will suffer “highly intrusive noise”. Appendix H (Noise and Vibration Impact Assessment), Table 5.2 on page 26 mentions that 5 vibratory rollers over 18 tonnes will be used during Stage 1 and Stage 2 of construction while it is also stated that human comfort is impacted if the vibratory roller is over 6 tonnes. The noise and the vibrations during construction phase will make it unliveable on some of the properties and will force the residents to move away while they have been living and caring for their land and animals for generations.
An alternative “Western Road” option shorter and more direct which would avoid a lot of the adverse consequences to the community has been contemplated and turned down in the EIS for reasons that do not stand scrutiny. The impacts on the community largely outweighs the additional cost for Sundown in a project that will see Sundown make huge profits in the long term.

I object most vehemently to the proposed Sundown Solar Farm, on several grounds, as follows: 1. It is on prime agricultural land that contains some of the best soil in the district, and is also formerly part of the historic "Newstead Station". 2. Huge volumes of water are going to be used during construction, and ongoing. I live downstream of the area concerned and I rely heavily on Kings Creek for stock water and I don't believe the volumes of water required are, or will be, available without impacting the creek substantially. Also there are the ever-present dangers of water contamination, which could cause severe environmental damage. The 75 megalitres of water proposed to be used during construction, will reduce the amount of water available for stock, and equates to watering approximately 2,400 steers per month. 3. The large volume of traffic on the Spring Mountain & Sturman's Roads will seriously impact the residents on those roads and two residents in particular, with large amounts of dust drifting onto paddocks & the grass which will render the area useless for grazing. It will be impossible to effectively spray weeds, due to the layers of dust on them, which will prevent penetration of the weedicide. The huge increase in traffic will also make it extremely difficult, if not impossible, to move livestock across or along roads as necessary. 4. If the development does proceed, an alternate private road to the west is available and should be used, as it is much shorter, with no residences. 5. Solar farms should only be built in the far west of the state, where properties are large and only have minimal stock carrying capacity. 6. Many similar projects are also planned along the 330kw transmission line running through the Sundown Solar Farm and beyond, so this line will not have the capacity to accommodate this particular farm, so it definitely should not proceed.

As a Primary Producer and resident on Spring Mountain Road and part of the Swan Vale community, I strongly oppose to the proposed construction and development of a 360 MW Solar Farm and 150 MW Battery Energy Storage System at Spring Mountain.
After having no consultation in relation to the alleged proposal from Sundown Solar Farm or Inverell Council, I am now only becoming aware of not only the direct impact it will cause to myself and my family as residents on Spring Mountain Road, but as close neighbours to the proposed site.
The project has proposed Spring Mountain Road as the access road to the Solar Farm site. Spring Mountain Road is a no through road thus making it the only road residents can use to access the Gwydir Highway. This promotes major concern as it has been proposed that this quiet country road will have an increase during construction phase of 960% in traffic DAILY ! Spring Mountain Rd is used by landholders to muster and transport stock and just everyday access to neighbouring towns for food, medical services etc. That increase in traffic will not only cause major impacts to residents who have homesteads right on the road but every resident who uses it . I myself have already nearly had two head on crashes with other vehicles travelling too fast on the wrong side of the road. With that increase in traffic and with stock using that road regularly, I can foresee and accident waiting to happen should they use Spring Mountain Road.
An alternative shorter, more direct route was also proposed however, Inverell Council and Sundown Solar Farm did not see it as a 'feasible' road to use due to the impact it would have on vegetation and cost. I find these two reasons in comparison to the adverse impacts it will have on the residents of Spring Mountain Rd that I have stated above, very unreasonable, almost absurd. In relation to this the Solar Farm's proposed storage of 150 MW batteries on site, there is potentially a very high risk of fires occurring. If this were to happen, which I believe is highly likely as have heard reports of it happening regularly at other solar farms due to increase in temperatures etc, the RFS would need the quickest, most direct access to the site. Upon talking to the RFS in the Swan Vale area who would be directly responsible for fighting the fires, it was discovered upon looking at the two access roads proposed, that Spring Mountain Road would not be the RFS' road of choice as it would be 13 km longer than the alternative access road. Thus, if an emergency were to occur, valuable time would be wasted. Therefore, in the case of the risk of fires , I believe Inverell council's proposal to use Spring Mountain Road as the access road highly negligible on all accounts.
With all these points considered I am strongly opposed to the proposed construction of Sundown Solar Farm and the use of Spring Mountain Road as the access road should it go ahead.

This Project will be Redundant

I deeply believe in the need for a rapid energy transition to end our dependence on fossil fuels and mitigate the escalating impacts of climate change. I equally believe that everyone must be empowered by this transition as much as possible, which can only be achieved through meaningful community consultation and risk assessment. This is especially the case for the Sundown Solar Farm project, which will adversely affect local residents if the current plan goes ahead. This includes impacts on human health and safety, as well as significant noise, dust pollution, and loss of amenity.
I believe development sites for renewable energy farms and transmission lines should occur on agricultural land as it is already cleared and does not impede on biodiversity. However, just as it is important to balance energy and biodiversity values, it is important to assess the likely human and social costs of this project, and provide compensation where it is due. Further, changing the "Western Road" to be the alternative means of access would mitigate the most severe of the impacts as there are no Swan Vale residents on this road. It would also provide a shorter access route from the Sundown project to the Gwydir Highway. I truly believe that by listening to the voices of local residents, a solution can be reached that supports energy development, as well as the local community and agricultural practices that makes this region so valuable to NSW and Australia.

Decommissioning: It is perfectly understandable that the Community remains very nervous as to who will decommission, what will be decommissioned and when. The issues have been given very poor policy consideration by the Government and the developers.

Roads and Traffic: The operational and decommissioning traffic will be significantly less than peak construction traffic across Spring Mth Rd and Sturmans Rd. Traffic impacts have not been assessed in detail. Assessments detail the impacts along the Gwydir Hwy and the access to, but no mention of Spring Mth Rd and Sturmans Rd.

Socio-Economic: Existing shortages of a skilled workforce from local towns moving to solar project and other renewable projects, leaves locals without a key workforce to attend to their day to day operations, including 400 people required on site during construction. Project times can ‘blow out’ and there is no guarantee that construction will cease in 21 months.

SSD-8911
I object in the strongest possible terms to the proposed development and construction by
Sundown Solar Pty Ltd (the “applicant”), application No. SSD-8911 (the “proposed
development”). In particular, we object to the proposed access via Spring Mountain Road and
Sturmans Road to the proposed development.
Dust
Another safety implication is the dust which would be generated from the use of Spring
Mountain Road and Sturmans Road from such frequent heavy traffic so close to our homes
and primary production businesses. Paragraph 6.11.4 of the EIS at page 225 refers to “
reduced rural amenity” due to dust and asserts that “dust generation will be mitigated
using standard construction techniques such as the use of water carts and screens”. It is
not just a matter of loss of amenity, serious though that is. Increased levels of dust due to
the heavy traffic on Spring Mountain Road and Sturmans Road will be dangerous to the
health of residents, stock and farm animals. The use of water carts and screens will plainly
not eliminate the adverse health effects of dust on these public roads.
Appendix J to the EIS at paragraph ES3 states that during the construction phase of 21
months, it has been estimated that 75 megalitres of water is required, principally for water
carts to reduce dust. This seems a relatively small amount of water to ameliorate the
effects of dust over the two proposed access roads for such a long period. The distance
from the intersection of the Gwydir Highway to the closest access to the proposed
development on Sturmans Road is 10.23 kilometres (Appendix I Traffic Impact Study). So
far as we can tell, nowhere in the EIS is the basis for the calculation of 75 megalitres
provided.
The EIS does not appear to address at all the adverse health impacts to people and stock
due to dust and certainly has not attempted to measure these risks. For example, in
relation to stock, it is well known that stress and dust cause Bovine respiratory disease
(https://www.mla.com.au/research-and-development/animal-health-welfare-andbiosecurity/diseases/infectious/bovine-respiratory-disease). However, there is not a word
addressing this critical issue in the EIS.
In short, the use of Spring Mountain Road and Sturmans Road as access roads to the
proposed development is wholly unsuitable and approving the proposed development
access would endanger the lives and well-being of residents and their stock and farm
animals.
Noise and Vibration
Noise
The area of Spring Mountain is an extremely quiet rural environment. To use the language
of the Noise Policy for Industry 2017, the properties are in an area with an acoustical
environment that is dominated by natural sounds, having little or no traffic noise and
generally characterised by low background noise levels.
Table 6.26 at pages 162-163 of the EIS assesses the noise impact of the construction phase
of the proposed development at 21 sites, including “Menari’ at R15 and “ Warrawee” at R14
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which are the worst affected by construction noise of all the sites. Predicted construction
noise levels for “ Menari” are 66dB in Stage 1 of construction and 67 dB in Stage 2 of
construction. These levels do not comply with Noise Management Levels set by the Interim
Construction Noise Guideline. These breaches of the Guideline are said to be due to the
upgrade of the access roads for heavy trucks and machinery.
Using assumptions including that the existing traffic movements on Spring Mountain
Road and Sturmans Road are “less than 50” movements per day (it is in fact currently only
about 10 movements) and that projected traffic would travel along these roads at the
speed limit of 100 kilometres per hour, the EIS at Appendix H predicts traffic noise due to
construction to increase from 39 dB at present to 50 dB on Spring Mountain Road and
from 20 dB at present to 30 dB on Sturmans Road. These are significant increases but it is
unclear to us what the true quantitative impact would be if more realistic assumptions
were used.
Table 7.3 of Appendix H to the EIS states that “Menari” and “Warrawee” will suffer “highly
intrusive noise”.
Vibration
“Menari” homestead (R15) and “Warrawee” homestead ( R14) are the worst affected sites
assessed in the EIS for adverse impacts from vibration. At paragraph 6.6.3 on page 164, the
EIS states that vibration levels at “Menari” (R15) and “Warrawee” ( R14) during Stage 1 of
construction “may exceed the levels for human comfort if the
The area is zoned for primary production. The following properties are directly adversely
impacted by the proposed development and the proposed use of Spring Mountain Road and
Sturmans Road:
- “Menari” 489 Spring Mountain Road, Spring Mountain
- “Numeralla” 1071 Spring Mountain Road, Spring Mountain
- “Kokoda” 934 Spring Mountain Road, Spring Mountain
- “Warrawee” 155 Spring Mountain Road, Spring Mountain
- “Lockmore” 170 Northcotts Rd, Spring Mountain
To take “Menari” as an example of a property particularly adversely affected, it is the dwelling
described as R15 on various maps in the Environmental Impact Statement (“EIS”) for the
proposed development. “Menari” borders and is immediately adjacent to the project area for
the proposed development. The site of the proposed development is, at its closest point,
approximately 2 kilometres from the “Menari” homestead. The “Menari” homestead is
approximately 45 metres from Spring Mountain Road and its vegetable garden is
approximately 4 metres from Spring Mountain Road at its closest point. “Menari” is intersected
by both Spring Mountain Road and Sturmans Road, the proposed public roads to be used for
access to the proposed development.
Spring Mountain Road and Sturmans Road are currently 4-metre-wide unsealed roads. They
are both no through roads. On average approximately 10 vehicles (primarily local residents)
drive on these roads daily. Spring Mountain Road and Sturmans Road are our only access
point to travel to and from Inverell and Glen Innes. Spring Mountain Road is also used to
connect with school buses and the Black and White bus that make daily deliveries to enable
us to carry out our daily business operations. Critically, it is the only access road for residents to
reach medical services.
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Similarly, both Spring Mountain Road and Sturmans Road are used by pedestrians and are
critical in the movement of stock between paddocks, stockyards and the loading ramp that is
divided by the existing road network. Farm dogs are used to muster stock along both roads.
In summary, we object to the application on the following grounds:
• Health and Safety
• Noise and Vibration
• Loss of amenity
• Adverse business impacts and financial loss
• Use of public access roads
Health and Safety
Traffic
The EIS refers to a proposal by the applicant to widen Spring Mountain Road and Sturmans
Road to a width of 8.76 metres and for the roads to be compacted and gravelled. In Appendix
I to the EIS , Traffic Impact Statement, Table 3.6 states the Austroads design for rural roads 150-
500 design standard is minimum 7.2m wide seal.
At paragraph 3.4.1 the EIS states that the purpose of widening these roads is to accommodate
26-metre B-double trucks. Table 6.37 at page 182 of the EIS states that the daily baseline and
development traffic volume is expected to be 478 vehicles per day on Spring Mountain Road.
The construction phase, during which there will be the heaviest traffic volumes, is expected to
last for 21 months: see paragraph 6.6.3 of the EIS.
As well as the frequent movement of heavy trucks there would also be heavy traffic due to
construction and operating workers travelling to and from the proposed development.
According to paragraph ES.5.6 of the EIS, construction works are scheduled to occur from 7
am to 6 pm Monday to Friday and from 8 am to 6 pm on Saturday. There would be a peak
construction workforce of about 400 people (Appendix H, paragraph 2.1.1). Peak project
construction workforce traffic is predicted to consist of 14 shuttle buses and 100 light
vehicles each day (Appendix I, table 5.1). If workers are required to start work at 7 am and
finish at 6 pm it can be expected that this traffic will commence on the local road network
from about 6:30 am and will continue until about 6:30 pm each day. This extends the true
period of traffic movement by about 1 hour each day beyond the assumptions in the EIS.
Other assumptions used in the EIS (e.g., in Appendix H, Noise and Vibration Impact
Assessment) include that vehicular traffic associated with the proposed development will
travel along Spring Mountain Road and Sturmans Road at the default speed limit of 100 kmh.
This huge volume of heavy vehicle traffic travelling at high speeds and carrying hazardous
materials greatly increases the risk of accidents and will expose the local residents and our
employees to dangers having an impact on the safety of motorists, pedestrians and graziers
mustering stock along these roads. Local residents, including the elderly and school children,
have no option but to use Spring Mountain Road and Sturmans Road to purchase supplies,
attend school and access services from Inverell and Glen Innes.
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We are concerned about the risks to the health from the stress of living and working so close
to these extreme traffic movements along the proposed access roads.
Despite these obvious safety and health risks and the profound adverse impact on local
residents from this increased traffic, the EIS contains no risk assessment of the impact of this
increased traffic on Spring Mountain Road and Sturmans Road. Appendix I ( Traffic Impact
Assessment ) paragraph 4.1 and Table 4.1 asserts that this risk assessment is contained in
paragraph 6.4 of Appendix I. However paragraph 6.4 does not address the risks of using these
access roads at all but states that the use of these roads is “acceptable to Council as a
temporary construction stage road”

Objection to Application No.SSD-8911 by Sundown Solar Pty Ltd
To whom it may concern,
As a rural landowner, I am writing to object to this proposed development for a number of reasons.
- I am concerned about the environmental impact that increased traffic will cause to the local wildlife and ecosystems.
- This project may also cause water contamination and use vital water supply in an already draught affected area.
- Reports also indicate that there will be a 960% increase in daily traffic in the area, which will prevent landowners from being able to manage and transport their livestock in neighboring farms. In particular, this project will detrimentally affect traffic via Spring Mountain Road and Sturmans Road.
- This project will greatly affect the health of livestock and in turn will financially impact local businesses.
- There has been a lack of community consultation at a grassroots level to determine the impacts on local farmers and residents.
For these reasons, I would like the project halted until there has been further consultation with the affected communites.

I object to application No SSD-8911 by Sundown Solar Pty Ltd which is classed as a State Significant Project.
This planned Solar farm, in the area of Swan Vale will impact that community and surrounding communities for the next 35 years and for years after.
The increased traffic alone will cause a significant impact on the local communities with over 400 heavy vehicles proposed to be travelling on the network of roads, including Spring Mountain Road and Sturmans Road to the site. These Rural roads are not designed to take this volume of traffic, and the residents who will still need to use these roads to travel to and from their properties, towns and other local communities will be disadvantaged by the massive increase of traffic. The negative impact of traffic not only includes meeting a stream of heavy vehicles on narrower roads but also the increased noise and ground vibrations that go with heavy vehicles.
The loss of the quality of life presently enjoyed by those who live in the Swan Vale community is irreplaceable. Land for primary production is extremely valuable not only to the farmers and landholders but to the Australian population who rely on the production of food resources from this land.
Has there been a study which takes into account the sheer volume of prime agriculture land that has been swallowed up, in not only solar farms but also wind farms, and the combined impact that has on the landscape by the loss of tree cover and therefore loss of biodiversity.
Farm land resources are precious, and should not be abandoned to the developers without the full impacts of the development, both short and long term, being made known to those closely affected and to the general public. This development in the Swan Vale area will create a major negative impact for many others including the possible contamination of the land and water resources in the vicinity of the planned farm. The problem in the future of disposing of the infrastructure required for the farm, including but not limited to the panels, posts and wiring has not been solved. Is that something we are willing to just leave to the future generations.
This proposal needs to be re-evaluated taking into account all stakeholders and not a minority.

I wish to object to the Sundown Solar project primarily because of the adverse impact on local residents.
Traffic safety will be heavily impacted by a 960% increase in traffic on the unsealed Spring Mountains Road and Sturmans Road. Local farms will not be able to safely move their livestock from paddock to paddock as a result. Visitors’ and residents’ access to properties in the area will be unsafe as they negotiate the narrow unsealed roads and huge increase in the large commercial vehicles using them. In addition the noise levels will be of an unacceptable level with the increasing traffic.
The loss of Spring Mountain Road and Sturmans Road as access roads for local properties will destroy their quality of life and make ongoing business unviable.

Another risk to consider is the project’s need for water. Sundown Solar proposes that 75 mega litres of their water requirements will be sourced from Kings Creek, which feeds into the Macintyre River. The risk of chemical spills could potentially create a water quality disaster for this major water source to the Inverell area. Sundown Solar also proposes using harvestable rights to take water from adjacent landowner dams which will adversely impact those landowners and their agricultural needs, especially with difficult drought predictions in the next seasons.

I wish for my objections to the Sundown Solar project and, in particular, its use of Spring Mountains Road and Sturmans Road, to be given full consideration.

Restricted Consultation: The Swan Vale community has only now become aware of the submission stage of this project. How clearly were the impacts communicated prior to holding community forums with the local Swan Vale Community so they would feel invested to find out more? Sundown Solar has an obligation to bring the community in on the details. Reviewing hundreds of documents before the community can assess the potential impacts on them during the submission period is overwhelming. Stakeholders benefiting from the project were approached for in depth interviews. They raised noise and dust from project construction traffic as a potential issue only for some residents closer to the project site. They didn’t believe the impacts would result in significant impacts to the lifestyle of local residents; most of whom have not been directly approached for comment. This is a conflict of interest.

Business and Lifestyle Impacts of Road Widening: The EIS refers to a proposal by the applicant to widen Spring Mountain Road and Sturmans Road to a width of 8.76 metres and for the roads to be compacted and gravelled. This is a breach of the Austroads design standard for rural roads. Appendix I to the EIS (Traffic Impact Statement) Table 3.6 states that the Austroads design standard for traffic of 150-500 vehicles is a 7.2 metre wide sealed road. Spring Mountain Road and Sturmans Road are currently 4 metre wide unsealed roads. Both roads are critical to the movement of stock for impacted neighbouring properties.

Extended Traffic Times. According to paragraph ES.5.6 of the EIS , construction works are scheduled to occur from 7 am to 6pm Monday to Friday and from 8 am to 6pm on Saturday. There would be a peak construction workforce of about 400 people (Appendix H, paragraph 2.1.1). If workers are required to start work at 7 am and finish at 6 pm it can be expected that this traffic will commence past affected homes from about 6:30 am and will continue until about 6:30 pm each day. This extends the true period of traffic movement by about 1 hour each day beyond the assumptions in the EIS.

Unsafe default speed limit.Other assumptions used in the EIS (e.g. in Appendix H, Noise and Vibration Impact Assessment) include that vehicular traffic associated with the proposed development will travel along Spring Mountain Road and Sturmans Road at the default speed limit of 100 kmh. This huge volume of heavy vehicle traffic travelling at high speeds and carrying hazardous materials greatly increases the risk of accidents to motorists, pedestrians and graziers mustering stock along these roads. Local residents, some elderly, have no option but to use Spring Mountain Road and Sturmans Road to purchase supplies and access services from Inverell and Glen Innes.

The EIS contains no risk assessment of the impact of this increased traffic on Spring Mountain Road and Sturmans Road. Widening the road to 8.7m from the current 4.0m is a safety issue for residents and livestock. A safe shoulder to access residential properties and adjacent gates for stock access is impacted by widening where there is no safe egress. Existing fences are stock proof for the low volume of traffic (approximately 10 movements per day), but will not be for the proposed volume of heavy traffic that will impact livestock. Some stakeholders raised the concern that livestock is often transferred between lots which would be impacted by high volumes of construction vehicles, further expressing a need to upgrade fences along the site access roads. Safe crossing points for livestock and landholders to cross the widened road are safety concerns. What compensation is there for the landholder when livestock are injured or killed by the impact of heavy machinery? Sundown Solar has entered into lease agreement with 3 associated landowners, but not with non-associated landowners who were assessed as not significant enough to warrant such an agreement. This is despite impacts on these landowners' ability to conduct their businesses as usual including moving stock and equipment on their properties with high levels of noise and dust generated for long hours past their places of residence. Sundown Solar states that properties adjacent to the project area will be able to continue their agricultural activities unimpeded, during all phases of the project (noting that the issue of allowing stock to safely cross roads during construction will be addressed). The sides of the road are used to convey stock between paddocks for optimum movement. How can this occur when widening the roads eliminates this movement.

Health Risk Impacts: Another safety implication is the dust which would be generated from the use of Spring Mountain Road and Sturmans Road from such frequent heavy traffic close to homes. Paragraph 6.11.4 of the EIS at page 225 refers to “ reduced rural amenity” due to dust and asserts that “dust generation will be mitigated using standard construction techniques such as the use of water carts and screens”. It is not just a matter of loss of amenity, serious though that is. Increased levels of dust due to the heavy traffic on Spring Mountain Road and Sturmans Road will be dangerous to the residents health and the health of livestock.

Noise and Vibration Impacts on Sensitive Receptors Table 6.26 at pages 162-163 of the EIS assesses the noise impact of the construction phase of the proposed development at 21 sites. Predicted construction noise levels of 66dB in Stage 1 of construction and 67 dB in Stage 2 of construction affecting sensitive receptors does not comply with Noise Management Levels set by the Interim Construction Noise Guideline. These breaches of the Guideline are said to be due to the upgrade of the access roads for heavy trucks and machinery. At paragraph 6.6.3 on page 164 , the EIS states that vibration levels at sensitive receptors homes (R15) and ( R14) during Stage 1 of construction “ may exceed the levels for human comfort if the size of the vibrator roller used to construct the access road is greater than six tonnes”. Appendix H to the EIS ( Noise and Vibration Impact Assessment) at Table 5.2 on pages 26 identifies that 5 vibratory rollers over 18 tonnes will be used during Stage 1 and Stage 2 of construction (a predicted period of 17 months). This creates a level of vibration during construction that will be intolerable for these residents. The mitigation measures suggested in paragraph 7.3 of Appendix H notification, verification (i.e. measurement) and respite offers are cosmetic and will not eliminate the adverse impacts of vibration if the current access roads for the proposed development are approved.

Loss of Amenity: It is obvious that the proposed development would fundamentally adversely affect the lives of neighbouring residents to the project. Instead of quiet country laneways (which are not through roads) intersecting properties, during the construction phase Spring Mountain Road and Sturmans Road would be used by many hundreds of vehicles per day, including hundreds of daily movements of 26 metre B-double trucks. That’s a 960% increase from very early in the morning until evening six days a week.

Hazard Impacts: Appendix K to the EIS (Preliminary Hazard Analysis) contains a completely superficial analysis of the consequences of fire from the proposed development to neighbouring properties. Table 5.4 identifies fire hazards due to electrical conversion systems, the battery energy storage system, substation fire and bushfire but in each case in relation to the consequences of fire makes the facile statement that “ as there is a large separation distance … to the nearest non-project related residential dwelling, the effects are not expected to have an off-site impact”. The likelihood of a fire having a devastating consequence for people, and livestock, is entirely foreseeable yet has been completely dismissed in the EIS. Rural fire services are aware that fires on or near large-scale solar energy facilities present tactical challenges, while these are similar to those seen with existing transmission infrastructure, state and national fire organisations are developing research programs, guidance material and operational procedures to identify and manage local conditions and site-specific risks.”

Sundown Solar Farm
SSD-8911
Sturmans Rd Spring mountain.
I am pleased to support this project, it has the potential in the short term to create infrastructure that the local community could benefit by, for example, improved public road infrastructure. A broader community benefit would be that there is local employment opportunity and growth involving trades outside the normal agricultural frameworks which will be created that otherwise would not exist in the area. As a local resident I believe there is a potential positive flow on effect to the broader local community with these large infrastructure projects that are effectively managed in all the developmental phases. The project is a step in providing a renewable energy solution for future generations.

This project will have dire consequences for the Swan Vale residents and farming enterprises. I am an advocate for supporting Australian owned businesses and the farming enterprises in this area make a significant contribution to our food supply. The construction of this project will negatively impact farming practises and the health and welfare of the residents.
Traffic, noise and dust will certainly affect residents and livestock but the major concern will be the escalated risk of fire.
Sundown Solar is not Australian owned and that also rings alarm bells. Why should Australian farmers and residents be impacted by a foreign company's investment? Health and Safety is paramount and as this project represents a huge fire risk, why should it even be considered?
Renewable energy has its place when the environment is right.
This project is not ticking the right boxes.

I object on the following points:
- dust impacting on local animals and humans
- traffic (400 workers during construction phase on our dirt road)
- on prime agricultural land
- visual impact on neighbours
- mental health impact on neighbours who get all the problems & none of the financial benefit
- decreased land values & reduction of rural amenity

Looking to support the project with solutions tailored specifically to Sundown Solar Farm

Solar farms being built in this country are desecrating the environment and turning productive land into wasteland with a very large waste disposal problem. It is seen as a get rich scheme to attract government subsidies and is not economical. If panels must be installed construct them on existing building roof’s.

Instead of placing the solar panels on a single property, distribute them across multiple properties

I object to this Electricity Generating Works proposal because I am not convinced it will ever result in cheaper electricity for us or others. Our electricity costs have already gone up four-fold in four years even before the latest 25% increase by the AER. Wind and solar electricity generation have increased significantly over the same period. Conclusion, as discovered by others around the world: more wind and solar equals increasingly higher energy bills.

Save Our Surroundings objects to this proposed project as it poses so many risks to the local human and animal populations. Risks still include grass/bush fires, noise, soil and water contamination, very high disposal costs, unclear responsibility for end-of-life cleanup, lack of economic viable recycling of such huge volumes of toxic components, and the risk of obsolesce as much better technologies, such as small nuclear reactors become available over the next few years. Australia's oldest wind electricity plant recently reached its end-of-life and rather than undertake the decommissioning, etc. that it promised, the owner just declared it a museum. How many more wind and solar projects will not meet their EIS commitments, as is happening in other countries? No upfront bond means no skin in the game.