Birriwa Solar - Modification 1

To Whom It May Concern,

I am writing to lodge a strong objection to the proposed modification of development consent SSD-29508870 by ACEN, which seeks to:

Add additional lots to the approved project footprint;

Introduce an alternative secondary access route and upgrade part of the existing Birriwa Bus Route South road; and

Increase the capacity of the approved temporary accommodation facility.

This modification represents a substantial expansion of the project scope and is not a minor adjustment. It materially changes the scale, impacts, and character of the originally approved development, and in doing so undermines the integrity of the original assessment process.

Key grounds of objection

Procedural fairness and community consultation

The modification application has been brought forward without proper and transparent consultation with affected residents, road users, and local councils. Communities that will be directly impacted by the expanded footprint, increased road use, and enlarged accommodation facility have not been given adequate opportunity to understand, question, or respond to these changes.

SSD projects already have a poor record of community consultation. Allowing significant modifications without full re-exhibition and engagement erodes community trust and fails to meet the Department’s objectives for transparent and participatory planning.

Scope creep and cumulative impacts

The addition of further lots and an expanded workforce facility substantially increases the intensity of the development, with flow-on effects for land use, amenity, and cumulative impacts in the region.

The approved development was already significant in scale; these modifications represent incremental “scope creep” that should instead be subject to a full new assessment of environmental, social, and infrastructure impacts.

Traffic and road safety

The proposed alternative secondary access route and upgrade of Birriwa Bus Route South road will expose schoolchildren, school buses, and local road users to higher volumes of heavy vehicle traffic. This creates unacceptable safety risks that were not fully addressed in the original approval and cannot be brushed aside in a modification.

Road safety impacts on bus routes must be subject to rigorous independent assessment, not left to proponent-driven assurances.

Amenity and land use impacts

The increase in temporary accommodation capacity will intensify noise, traffic, and social pressures on the local community.

Larger workforce camps have proven in other projects to create significant pressures on housing markets, health services, policing, and community cohesion. These broader cumulative effects have not been disclosed or assessed in the modification application.

Precedent and integrity of SSD approvals

Allowing such significant alterations under the guise of a “modification” sets a concerning precedent. Developers could secure initial approval and then incrementally expand through modifications, avoiding the scrutiny and safeguards that come with a full EIS process. This undermines the credibility of the SSD framework and the Independent Planning Commission’s role.

Conclusion

Given the scale and consequences of the proposed changes, this modification should be rejected outright. At a minimum, it must be treated as a new development application requiring a comprehensive Environmental Impact Statement, full exhibition, and genuine community consultation.

On behalf of affected residents, I respectfully request that the Department of Planning and the Independent Planning Commission ensure that proper process is followed and that community interests, road safety, and land use protections are prioritised over proponent convenience.

I oppose the modification because the local people were never consulted about the enormous increase in traffic. There should be no increase in the size of the camp. There should be no alternative access via Merotherie Road and the Golden Highway.

I strongly object to the Project Modification - increasing the storage capacity (BESS). Increase the project area and development footprint. USING THE MEROTHERIE ROAD TO GAIN ACCESS TO THE BIRRIWA SOLAR PROJECT SITE. The cumulative impact of these projects cannot be looked at individually. The Merotherie Road is not yet upgraded and there in up to 100 vehicles a day going to and from the ACEREZ Workers' Camp and the Energy Hub.

i object to this project and any modifications to it.

I object to this project

I object to this project as it is wrecking our land, devaluing our land that we have worked so hard to obtain.
We as the rate payers land owners don’t get a say.
The whole process is all done so appallingly.

The Birriwa solar farm is likely to dramatically decrease the value of where we live, and have a huge effect asthetically on where we live. We live here because we love it here, because it provides a safe rural lifestyle for our family. The solar farm is now being extended to be even bigger than when it was first approved. What will the impacts be on agricultural land with the solar panels making it unusable but also collectively absorbing solar rays, creating a microclimate and potentially increasing the possibility of becoming droughtsticken area. This is not a positive way forward. It does not help the environment and is not 'green energy'. The production of the panels themselves don't support our environment or our economy, neither locally or nationally and are likely to only benefit the foreign wallet from whom we buy them from. We can do better than this. Please stop pushing a government tick box to provide clean, green energy. This is not that, and you are destroying the livelihoods and area that we live in for the benefit of the city populations. If solar panels are the only way of gaining energy how about proposing them on every roof in our towns and cities to 'host'. It has simply become easier to just steamroll those of us who live out here than to provide any other ideas or options. Without our local community and word of mouth, I would have never even been aware this project was happening, and now when there is constant roadworks, land clearing and earthmoving that I see on my way into town. This is the only way I am even aware of it happening, there has never been even any courtesy contact from the government. Disgraceful.

Was this the plan all along? To get this approved, ignoring all the local outrage and keeping it on the down low as much as possible, and then once the green light to go ahead was done, just expand to the size you always planned for? We keep objecting, we keep having to log into portals to have a say. It falls on deaf ears.
The solar farm, and by default its extension:

- will devalue our major asset that we have worked hard to gain. Our family home is the only thing we currently have to give us something to sell when we are older as we are unable to put $ into superannuation in our current circumstance
- will aesthetically desecrate our country
- has the potential to contribute to raised surface temperatures given the collection of solar rays at a single area
- will therefore impact on weather and rainfall in our region and likely lead to increase drought and fire
- has been completely under-researched for the hazards it will create to the environment in terms of drought and fire
- will not positively benefit the environment at any point.
- The preparation requires extensive earthmoving and major roadworks
- the solar panels and batteries themselves still require mining to source aluminium, silica, metals and lithium
- These solar panels are likely to be purchased from a cheaper supplier, meaning it will not benefit the Australian economy either and will only fatten the foreign wallet.
- The disposal of these solar panels when they run their lifespan of approx 15 years has not been discussed.
- The effectiveness of each solar panels degrades over those years. How long will they even provide sufficient energy for before needing an upgrade or another 'modification'/extension to the project .

This project is nothing more than a government agenda to make it look like they are moving forward with 'clean, green energy' but in reality it only takes a moment to recognise that this is not in any way positive for our environment, our economy, or our local areas.

I strongly object to this project.
Agricultural land should not be used for renewable projects.
The cumulative impact of all the projects in the CWO REZ have not been taken into account and grossly underestimated.

Please find attached objection.

Modifications that add to destroying the soil, flora and fauna of that area.
I object to this project. Where is the leadership in critical analysis and then they would see there are more cons than pros to this project?

CWO REZist Inc., with 3 community groups and over 2000 members, objects to this modification.

The previous approval of Birriwa Solar was made without social licence - the majority of the community opposed. Since that time, more projects are appearing within the CWO REZ and the eastern area of the REZ particularly the area between Coolah, Dunedoo and Gulgong is heading for wall to wall wind/solar/BESS projects. The community finds this unacceptable.

The proponent, ACEN, has a poor reputation in the local community and their staff have been combative, rude and have targeted individuals that oppose their projects. This is not the sort of business that local people want to deal with or be a neighbour to.

The residents around the Energy Co Merotherie Hub are already severely impacted by roadworks and truck movements with the building of the Hub and the traffic for these residents will already increase when ACEREZ contractors begin the transmission line construction. ACEN's modification request seeks to utilise the SAME road that will already be overused, to access their project. The residents are angry at this modification request and their previously quiet rural lives are planning on being destroyed even further.

With a number of TWAs already in the district (Energy Co x 2, ACEN for Valley of the Winds x 1, TILT x 1), the area DOES NOT NEED an increase in capacity of the ACEN Birriwa temporary accommodation facility.

This is NOT in the public benefit - it is only in the developer's benefit.

We request that DPHI rejects this modification request in the light of residents and the community already being heavily impacted and not being able to withstand even more negative impacts.

CWO REZist Inc.

The project area now adjoins my family property, however we were not engaged in any SIA interviews, and we were previously, with the original application.

Greater visual impacts will occur at our families dwellings, we were not approached to be part of a visual impact assessment.

As evident White Creek is fragile and subject to erosion. With the significance of the non-permeable surfaces, runoff will be greater resulting in further erosion. Detention basins on the development site should be installed to assist in regulating the flow of stormwater to minimise further erosion. There are several crossing of White Creek proposed, these should be minised and significant vegetation should planted and maintained to assist in slowing the stormwater flow. There is local knowledge of suitable vegetation for the area, the neighbouring community should be engaged in proposed vegetation planting selection.

We have concern regarding deteriorating of and damage to solar panels and subsequent contamination impacts to water, soils and livestock bred for human consumption. There is no discussion of this in the documentation, this should be explored, mitigation measure proposed and a testing methodology established to protect the agricultural industry.

The increase in development footprint is removing additional land from agricultural production. Whilst a monetary figure is stated, the documentation does not detail the indirect economic impacts of this. Reduced stock numbers through the saleyards, less work for agronomists, reduced farm supply (chemical, fertilizer etc) sales from local business etc etc. The documentation does not cite the hectares of agricultural land lost in the region and it’s impact on the local economy.

We would be grateful if security fencing could be minimized and not located on property boundaries, but rather setback within the development area. Fencing should not be located along Birriwa Bus Route North, as there appears to be opportunity to locate it within the development area. A fencing plan should be prepared in consultation with neighbours and be included as a condition of development consent. Fencing should be black in colour (rather than grey) to minimize its visual impact on the landscape.

The SIA mentions the GP in Dunedoo, however, they are available two days and have closed books. We visited the Dubbo Base Hospital Emergency Department last Friday after a farm accident, with a suspected bone fractures and head injury. It took four hours to see a doctor and we were treated and left after seven hours, then traveled 1.5 hours home. This wait period is similar to what we have experienced previously. Whilst we recognise there will be a nurse onsite, there is no mention of the impact on emergency departments and capacity and safety for employees traveling from Dubbo back to the temporary workers facility. We feel the expansion by 150 people, in such a remote location has not been adequately assessed. Noting Mudgee is not a base hospital and you can be transfer from Mudgee to Dubbo, resulting in even greater vehicular movements.

Approved transport routes and management plans do not work. We have already witnessed on several occasions the EnergyCo camp construction vehicles using the wrong roads with poor driver behaviours. Alternate approaches should be explored and discussed with neighbours.

We are already experiencing impacts of REZ developments: port to REZ upgrades and EnergyCo accommodation facility. Accordingly, we think we have been impacted enough and it is not necessary for us to have to endure additional workforces (to the Birriwa Solar) and the impacts utilising the workforce camp. This modification should state the temporary workers facility is for the Birriwa Solar development only.

We are disheartened, inconvenienced and soon to be financially burdened (Port to REZ road upgrade, Barney’s Reef road closure, any day to Feb-Mar 2026) by the impacts we’re already experiencing. It has placed significant stress and anxiety on the family in try to understand the future cumulative impacts of these many developments occurring at such a rapid pace. I object to this modification and hope things can slow down and a comprehensive cumulative assessment can be undertaken to determine where the development threshold for this community is.

I support the construction of this project for the benefits of renewable energy both for the environment and the economic contribution it will bring to our region.

Please stop burdening rural communities with such industrial developments, enough is enough. This is a substantial expansion above anyone’s expectations, and sets a dangerous precedent for further developments around the state if approved.

This project cannot continue to use valuable agricultural land without the cumulative impacts of surrounding projects being taken into account.

The Central West Cycle Trail Incorporated (CWCT Inc) is objecting to the aspects of the road design. This is not an objection to the overall project but to those aspects which in current form need to be modified to meet the requirements of the Central West Cycle Trail.

I object to this expansion for similar reasons that I objected to the original proposal. Once a developer gets their foot in the door they then seek expansion. Killing even more bats and birds, including the protected wedge-tail eagle. The area in this locality is an eagle breeding and hunting ground. More visual and land contamination and industrialisation of our landscape character. No more!

I object to the modifications of this project. How can a project be approved with certain conditions only for the proponent to then ask to make the project bigger? There are many many problems with the modifications, of which several people have pointed out in the past, that I am not going to spend time going into because we never get listened to anyway!

In this amendment the Phillipine owned developer, ACEN, seeks to further profit from government subsidies, taxpayers and electricity consumers, at the expense of our environment, community and agricultural land.

Increasing the size of the workers accommodation camp to rent the facilities to other developers in the region is unacceptable. This area already has 15 solar projects within 45 km. These 15 projects are in planning, under constructions or approved. Each one has millions of solar panels, endless shipping containers of batteries, workers accommodation camps, substations and endless transmission lines and towers.

The NSW Government's CWO REZ transmission project has barely started and the costs have exploded from original budget of less than $600 million to now over $5.5 billion. So far all that has been accomplished are some road works (where none were required) for the benefit of foreign developers such as ACEN and an enormous workers camp that will house more people than the local towns.


Why is the NSW Government putting ACEN's needs ahead of the local community? This project and all related ones should be in the degraded "agricultural land" that is now Sydney. ACEN are planning to further destroy native and rural environments and yet the NSW Government has not completed a cumulative impact study for the CWO REZ.

No further approvals for projects or modifications should be processed by the NSW Government until the cumulative impact study has been completed.