Deniliquin East Battery Energy Storage System

This is an IRREVERSIBLE LAND CONTAMINATION DISASTER!
Once lithium, PFAS, lead, and other battery toxins leach into soil and groundwater, the damage is permanent.
Future farming, grazing, or habitation on that land becomes impossible — the site becomes an unremediated toxic dump for generations.

While we are the owners of the proposed land for this project we are in favour of this project for the following reasons:
• After construction there will be 2 full time positions
• Energy must be stored so it can be fed back into the power system during periods of low power generation.
• The site is close to current town substation
• Proposed area is only 3.5ha on land that is unimproved. i.e not set out for irrigation
• It will have minimal impact on our farming business
• Developer agreement includes mitigation measures for fire.
• Developer will be doing landscape screen from highway and closest neighbour
• The land has not been impacted by recent flood events
• Our community will receive approx. $10,000 to $15,000 pa to be invested in community projects throughout the life of the program.
• The annual lease fee we will receive will be guaranteed payment, which is reliable, rather than uncertainty of annual farming income.

We need BESS projects and this largely unused parcel of land is relatively close to existing substation.

Comments contained in response attached.

The Agricultural Impact Assessment is significantly inadequate and needs to be redone by a competent person that is both suitably qualified (e.g. Bachelor of Environmental Science) and accredited (not just membership) by a relevant industry association (e.g. Soil Science Australia) or Environment Institute of Australia and New Zealand. The author has withheld their post nominals but is it clear to me after reviewing this report that they do not have the required competencies. I provide some examples:
1. The first fault is the report was stated as prepared in accordance with the incorrect guidelines: 'Large-Scale Solar Energy
Guideline (NSW Department of Planning and Environment, August 2022)' was superseded in 2024.
2. The assessment does not address the Agricultural Impact Assessments requirements in the Guidelines: e.g. there is no clear determination of the level of assessment required, there is no detail provided with regards to how the LSC has been verified against mapping.
3. Robust understanding of Guidelines for Surveying Soil and Land Resources' and other references stated in the Guidelines is critical for the soil survey component of this assessment. The soil survey appears very 'light' and I request an independent review against the references.
4. The Potential Impacts section is inadequate. There is no link between this section and either the outcomes of earlier work in the report or the assessment-level (basic, reduced, detailed) requirements, the rating system (e.g. 'Likelihood' and 'Significance of Impacts') is baseless , there are no definitions, no methodology references and no explanations how the rating values are determined.
5. Because of all of the above, the mitigation measures cannot be relied upon. Also , how are these measures specifically determined, with references? Were they copied from other projects?
6. The soil loss calculation is incorrect , with errors throughout.
Overall , a very low quality report.

Please refer to attached ERC Submission

I object to the proposed Deniliquin East BESS Works in this project because there are still so many unresolved concerns about risks and issues involved with Battery Energy Storage Systems (BESS), for instance:
1. Lack of research into the life-cycle of BESS
2. Resource intensive requirements
3. Involves slavery in mining and production
4. Environmentally damaging
5. Fire starting risks increased
6. Fire-fighting dangers increased
7. Local fire risks considerably increased
8. Expensive
9. Short life-span
10. Variable operation
11. Very little Australian content
12. Increased energy and sovereign risks
13. Roads and road travel are impacted
14. Electricity charging and air-conditioning requirements are high
15. Classed as hazardous goods
16. No certainty at end of the short life of a BESS or frequent battery/inverter replacements
17. Increased dependency on intermittent electricity generation
18. Poor viability
19. Increase retail electricity prices.

I object to this Proposed Project because all the real life evidence today demonstrates the claimed benefits of the project will not be achieved. Electricity prices will continue to increase for consumers and the project will have no affect on the climate. The local and global environments (people, flora and fauna) will be substantially damaged, food production compromised and livelihoods destroyed. The project must be rejected.

Mark P Mills'* March 2019 paper 'The "New Energy Economy": An Exercise in Magical Thinking' highlights the physics of energy to illustrate why there is no possibility that the world is undergoing— or can undergo—a near-term transition to a “new energy economy.”

Among the reasons he gives are:
1. "Scientists have yet to discover, and entrepreneurs have yet to invent, anything as remarkable as hydrocarbons in terms of the combination of low-cost, high-energy density, stability, safety, and portability. In practical terms, this means that spending $1 million on utility-scale wind turbines, or solar panels will each, over 30 years of operation, produce about 50 million kilowatt-hours (kWh)—while an equivalent $1 million spent on a shale rig produces enough natural gas over 30 years to generate over 300 million kWh.

2. Solar technologies have improved greatly and will continue to become cheaper and more efficient. But the era of 10-fold gains is over. The physics boundary for silicon photovoltaic (PV) cells, the Shockley-Queisser Limit, is a maximum conversion of 34% of photons into electrons; the best commercial PV technology today exceeds 26%.

3. Wind power technology has also improved greatly, but here, too, no 10-fold gains are left. The physics boundary for a wind turbine, the Betz Limit, is a maximum capture of 60% of kinetic energy in moving air; commercial turbines today exceed 40%.

4. The annual output of Tesla’s Gigafactory, the world’s largest battery factory, could store three minutes’ worth of annual U.S. electricity demand. It would require 1,000 years of production to make enough batteries for two days’ worth of U.S. electricity demand. Meanwhile, 50–100 pounds of materials are mined, moved, and processed for every pound of battery produced."


Fast forward to January 2025 and all Mr Mills' March 2019 reasons are fully vindicated:

• Every developer and proponents of wind, solar, and storage (referred to as 'Ruinables' in this submission) deliberately mislead the readers of their materials and proposals by ignoring the capacity factor of their proposal. e.g. a 500MW wind or solar project is not equivalent to a 500MW High Efficiency Low Emissions (HELE) coal-fired power plant, or modern gas-fired plant or nuclear power plant (large or small modular reactor). In fact, wind power only generates in Australia an average of 30% of the time over a full year and Solar is even less at under 25% capacity factor. Wind and solar are such a weak and erratic energy source that they cannot compete with energy dense sources;

• Sweden has abandoned its 100% Ruinables policy in favour of nuclear power;

• Finland commissioned a nuclear power plant in April 2023, which immediately reduced the nation's wholesale electricity costs by a reported 75%;

• Germany has reactivated coal mining and restarted producing electricity from coal-fired power stations; its economy is in rapid decline largely due to high energy costs

• The UK net-zero actions are continuing to substantially drive up the cost of electricity, which is hurting the UK population, businesses and industries.

• The Australian net-zero actions are continuing to substantially drive up the cost of electricity, which is hurting the Australian population, businesses and industries.

• China, who produces most of the world's Ruinables components, is building two coal-fired power stations a week and has issued permits for hundreds more;

• Despite $trillions being spent globally on Ruinables in the last 27 years, less than 3% of the world's energy comes from them;

• The cost of Ruinables is rapidly rising as projects are only viable if heavily subsidised and given preferential treatment by legislation and policies as well as others (taxpayers and electricity consumers) picking up all the costs for new, otherwise unnecessary, infrastructure to support the ruinables;

• Solar panels have not increased significantly in efficiency since shortly after Bell Laboratories invented the first modern commercial solar panel in 1954. The best commercial panel is still around 26% as it was in 2019, but most commercial and industrial solar panels installed today are a maximum laboratory determined efficiency of between 15 and 22.8% . In 70 years the claimed efficiency has barely trebled. Actual panel efficiency declines annually and is also reduced by high/low temperatures, dirt/dust/grim/algae/bird droppings, panel tilt and orientation, micro cracks, weather related damage (hail, heavy rain, lightning, fire) inverter efficiency, latitude, etc. as well as reduced output from lack of daily and seasonal sunshine;

• Wind turbines operating in Australia have over at least the last 11 years have an average annual capacity factor of 30.1%. Australia's two largest wind electricity generating works have never achieved their stated capacity factors of over 30% and have operated under 30% since commissioning;

• Most battery energy storage systems (BESS) contain significant quantities of lithium, cobalt and nickel, all of which have increased massively and are predicted to increase much more annually. Lithium prices have increased from $13/kg in May 2021 to over $17.24/kg recently. Significant increases in Cobalt, nickel and copper have also occurred. The 400MW Coleambally BESS only proposal in February 2023 stated a capital cost of $184 million for an initial annual output of 380,000MWh later revised to 146,000MWhpa due to an initial "calculation error" by the Proponent. An original projected life of 5.3 years (2.6 charge cycles/day) before the battery and inverters replacement means a potential total output of 2,014,000MWh at an initial capital cost recovery of $91.36/MWh. The revised figure for 13 years before replacement is $96.94/MWh. Add financing cost, maintenance, payments to hosts and community benefit funds we get a very, very costly backup/firming for Ruinables, which is required over not just over 70% of the time annually but with wind and sunshine droughts up to 100% of the time, sometimes for days across the NEM grid;

• For example, on June 4, 2024 during peak demand from 6pm to 9pm all of South Australia's, which has over 70% of its generating capacity in wind and solar and a very large battery backup, generated its electricity from 97% gas and 3% diesel. Zero wind, zero solar and zero battery output. The whole of the NEM during the same time only got generation from wind (1%), zero solar and zero batteries. AEMO is forecasting blackouts before 2025 winter's end as gas supplies and hydro electric output falls. This is proof that wind, solar and BESS capacity has never provided, and cannot provide, sufficient electricity for a modern economy like Australia's economy.

• Electricity prices become amongst the highest in the world once any country or jurisdiction exceeds Ruinables capacity of 30% in its electricity generation mix. Australia has exceeded the 30% figure and now has joined the other countries, such as UK, Denmark, Germany and the states of South Australia and California and others with the highest retail and business electricity prices in the world. Ruinables are the cause. They are unreliable, intermittent, resource hungry, idle most of the time and very environmentally destructive.


Conclusion
The claims made by this Proponent do not align with reality, only some of which has been presented in this submission. The project does not justify approval. The Proponent has not proven that their proposed project will even achieve the basic requirements of reduced emissions and lower electricity prices. However, they have demonstrated that their project will harm the environment, will cause further wide-spread economic damage to consumers, will cause more businesses to close or move off-shore, will cause intergenerational harm and will require consumption and utilisation of unsustainable quantities of the Earth's resources.

There are better alternatives, which are already being pursued by other countries who now realise that Ruinables is a failed experiment. The US President just announced that the USA is again withdrawing from the Paris Climate Agreement.

The Project is definitely not in the public interest. Reject the proposed project!

Please refer to the attachment.

I object to this BESS because it is adjacent to an irrigation channel in the Riverina. This is an unsustainable development and should not go ahead. Positioning a Battery Energy Storage System (BESS) adjacent to an irrigation channel poses unacceptable risks, including flooding, contamination of agricultural and potable water supplies, erosion undermining structural stability, and limited access for emergency response. It also increases the potential for rapid fire spread through dense riparian vegetation. Locating a BESS in such a flood-prone area is inconsistent with best-practice safety guidelines and may breach relevant standards, exposing the community, environment, and agricultural enterprises to significant harm.

The proximity of irrigation channels to the proposed grid scale battery runs the risk of contamination of irrigation water and therefore the agricultural production. Lithium battery fires are very toxic and some of the compounds released are carcinogenic.
The risk is too great and therefore this project should not be approved.

PFAS are persistent “forever chemicals” that can leach into waterways, including the River systems.what measure will be in place to reduce this?
What containment systems will prevent contaminated water from reaching the river ecosystem and food chain?

Has a full soil and groundwater assessment been done to confirm it’s safe for high-energy infrastructure?
Airborne emissions from fires or thermal events could impact nearby residents due to prevailing winds from the west, was this addressed in the planning phase. Will it be addressed now?

What coordination plans are in place with surrounding landowners and business in case of an incident?
The BESS is being developed on low-lying, un disturbed land, this project risks of contamination , what plans in the planing process address this?.

What coordination plans are in place with surrounding landowners in case of an incident?
The BESS is being developed on low-lying, un disturbed land, this project risks of contamination , what plans in the planing process address this?.

Does this project have chemical hazard controls?
How will emergency vehicles access the site quickly if there’s a fire or chemical leak?

Plastic and chemical debris can linger after closure.
How will you ensure full site cleanup and microplastic removal after battery dismantling?
Where will the recycling take place?

There’s no financial security for decommissioning or cleanup.
Will both the developer and the landholder deposit equal amounts into an escrow fund, managed by a neutral third party, before commissioning begins?

The site could be abandoned post-operation, leaving toxic waste behind at the end of use.
Will you provide a legally binding decommissioning plan including full land rehabilitation and timelines?

Battery breakdown during storms or fire could release heavy metals well be a health hazard.
How will you secure and weatherproof battery modules to prevent accidental environmental contamination?

Cleaning operations risk discharging PFAS and plastic waste into drains and on the soil.
What procedures will prevent harmful substances from leaving the site during normal operations?