New South Wales
It is misleading to call this development application an "upgrade", it is a degrading activity. It is difficult to see that the Coal Ash Dam is being "augmented", it is being made bigger, but bigger is certainly not better. The impact of the Bayswater Power Station Upgrade is as likely to be greater on the environment as less. The Biodiversity Assessment Report notes: "The construction and operation of the salt cake landfill would be in accordance with NSW EPA Environmental Guidelines for solid waste landfills (Second Edition, 2016) and would include appropriate leachate barrier systems and capping to prevent contamination of the surface and groundwater during operation. Clay materials for the construction of the cells and capping would be sourced from the proposed borrow pits described below.
Vegetation clearing would be required to facilitate the above works." I understand this to mean that clay is being regarded as appropriate leachate barrier material and that there is a belief that the 'salt cake' can be regarded as solid waste. I hope I am wrong. When the salt cake gets wet it will become liquid again won't it? I understand that there are toxic heavy metals in the groundwater which would become concentrated in the salt cake. Clay is not totally impermeable. The risk of water pollution from the leachate from the coal ash that continues to get dumped in the Ravensworth Final Void has not been considered. There is no upgrade of standard of care for the environment. It is world's best practice to have a membrane lining a coal ash dam to mitigate risk of water pollution from leachate. Bayswater is trying to get away with far less than best.
And there would be clearing of precious Hunter Valley Floor remnant vegetation in the process. A Critically Endangered Ecological Community cannot be 'offset' or have its 'biodiversity credits retired'. Critically endangered means precisely that. The Central Hunter Valley eucalypt forest and woodland ecological community in Borrow Pit 4 is not only critically endangered but has a high density of hollow-bearing trees. It is not clear to me that the requirement to avoid and minimise impact on Matters of National Environmental Significance has been complied with. If the design of the "augmentation" of the dam included lining with a membrane the area of clearing would be less as there would be less need for clay. I note that the Biodiversity Assessment Report, 7.1.3 Impact Assessment states that the impact on Delma impar, Striped Legless Lizard is unknown. An individual was found in Borrow Pit 4. It is part of a population at its northern extent of the known distribution. This species is listed as Vulnerable under the EPBC Act. The Federal Government has not received adequate information to determine the significance of the impact and make an informed decision. Delma impar is listed as Endangered (Global Status: IUCN Red List of Threatened Species: 2019.2 list)
AGL needs to operate Bayswater Power Station as a good corporate citizen, our days of reckoning bear down upon us. The reuse of the decontaminated coal ash, turning a problem in to an asset, is highly appropriate but this proposal lacks due diligence to detail.