Bayswater Power Station Upgrade

The documents provided have been reviewed and there are no works in waterways considered as key Fish Habitat and there are no significant changes that should effect receiving waters. Fisheries NSW has no issues with the proposal.

Heritage Council of NSW comments attached.

Please see response from Subsidence Advisory NSW attached.
Thank you,
Pia Wimmer

Crown Lands has no comments for this proposal.

Please see attached correspondence

Whilst we are in support of the Bayswater upgrade project; in its current form, the project brief is limiting the potential outcomes.
We see a unique opportunity to offer a very different solution to that which is currently being proposed. Our solution is more environmentally friendly, is based on an Australian patented process and provides a great business opportunity to monetise a waste resource stream.
Please see details in the attached document.

Please see attached response

DPI Agriculture has no comments for the Bayswater Power Station Upgrade (SSD-9697)

Please find attached advice.

the planned upgrade to the Bayswater power station should not go ahead and is money misspent. australia has the technology and resources to provide our energy needs by using clean methods. Bayswater uses toxic and poisonous and atmospherically damaging methods to make electricity and its ongoing use as a power source is damaging to human health and our environment. the planned upgrades are supposed to make the power station more efficient but a toxic emitter is still a toxic emitter. the upgrade money should be spent on clean energy and storage. we should not be wasting money on outdated 'dinosaur technologies' when it is better spent on modern technology.
also: 1. the e.i.s fails to state how much diesel fuel is used to run the power station and to extract the coal and to carry out the upgrade. and burnt diesel fuel is toxic.
2. doesn't clarify how much co2 will be discharged before and after the upgrade.
3. how much dust settles on the surrounding towns and fields.
4. sunny scotland has managed to get over fifty percent of its energy from renewables. we can do the same and more.

so overall the ongoing use of coal (or gas) as an energy source is dangerous and criminal (wilfully damages our environment and our health). so any complicit activity to promote or prolong its use must be stopped by any means that is possible by those in the position to do so.
the upgrade must not go ahead and the money must be spent on clean energy.

The power station needs to be altered, to only make electricity through sustainable and biologically harmonious methods. If the upgrade perpetuates the use of coal, this will not be ideal for the community. The atmospheric emissions and coal-ash waste created by using more coal will be a perpetual problem. The cap and monitor approach will not stop continual leaching of heavy metals and other chemicals into the ground water. The ash created until now needs to be extracted from the ground and locked into new products at a dilution that will be safe for exposure to the atmosphere.
There are many possible solutions to energy demands, lets create the best practices.

🚫Bayswater employs risky coal-ash reuse practices with little community benefit and high environmental risk (which saw AGL fined for sale of ash with un-safe heavy metal levels)
❌Dumps coal-ash in the Ravensworth mine void
🚫 Their proposal lacks ANY information about water pollution risks from heavy metal leachate
❌ The proposal will see up to 1 million tonnes of coal-ash reused with no detail about where, how or for what purpose
🚫 Bayswater have no plans to safely, beneficially & economically reuse decontaminated coal-ash in building products which could bring employment to coal-energy regions and reduce volumes stored in leaching dumps
❌ Bayswater are planning to take a "cap and monitor pollution" approach to the so-called remediation of huge toxic waste sites where they have disposed of coal-ash free of charge for decades.

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.

Please see written submission attached

The Bayswater Power Station Upgrade will see a much-needed increase in coal-ash reuse BUT...
🚫Bayswater employs risky coal-ash reuse practices with little community benefit and high environmental risk (which saw AGL fined for sale of ash with un-safe heavy metal levels)
❌Dumps coal-ash in the Ravensworth mine void
🚫 Their proposal lacks ANY information about water pollution risks from heavy metal leachate
❌ The proposal will see up to 1 million tonnes of coal-ash reused with no detail about where, how or for what purpose
🚫 Bayswater have no plans to safely, beneficially & economically reuse decontaminated coal-ash in building products which could bring employment to coal-energy regions and reduce volumes stored in leaching dumps
❌ Bayswater are planning to take a "cap and monitor pollution" approach to the so-called remediation of huge toxic waste sites where they have disposed of coal-ash free of charge for decades.
For these reasons, the planning proposal should not be approved. They can do better. Reject this one with requirements for resubmission, that include addressing these factors. We need to get it right, for environmental and community health. This is so important because once the contamination is released, you can’t get it back.

I am writing to voice my objection to the Bayswater Power Station Upgrade.
Although this upgrade promises a much needed increase in coal-ash reuse, AGL needs to go much further in cleaning up its practises.
The environmental and community risks that have been posed by Bayswater's risky coal-ash reuse practises that led to AGL being fined for the sale of ash with un-safe heavy metal levels, must never be repeated.
This proposal lacks any information about water pollution risks from heavy metal leachate.
The dumping of coal-ash in the Ravensworth Mine void is unsafe.
The proposal will see up to a million tonnes of coal-ash reused with no detail about where,how or for what purpose. There have been no plans to safely and economically reuse decontaminated coal-ash in building products which could bring employment and reduce volumes stored in leaching dumps.
The cap and monitor approach proposed by Bayswater to the 'remediation' of huge toxic waste sites where they have disposed of coal-ash for decades free of charge, is unacceptable.

There needs to be a much better commitment by Bayswater to clean up their act.

The project is to increase the capacity of Bayswater ash dump and not for coal ash reuse or to mitigate heavy metal leachate contamination. The EIS does not provide enough information to be able to adequately identify the impacts. The EIS provides inaccurate estimates of coal ash produced, and volumes of coal burnt, and provides no estimates of the ash content of the coal burnt. The EIS does not provide laboratory analyses of the ash dumped or intended to be reused, or the leachate the ash dumps produce. No information is provided on what the reused ash will be used for. The volume of ash intended to be reused is overly optimistic and unlikely to be met without an economic incentive imposed on AGL. Increasing the amount of ash dumped at Pike Gulley ash dump and the Ravensworth mine void will increase heavy metal contamination of the Hunter River Valley.