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State Significant Development

Response to Submissions

Guildford West Battery Energy Storage System

Cumberland

Current Status: Response to Submissions

Interact with the stages for their names

  1. SEARs
  2. Prepare EIS
  3. Exhibition
  4. Collate Submissions
  5. Response to Submissions
  6. Assessment
  7. Recommendation
  8. Determination

Construction, operation, and decommissioning of a battery energy storage system (BESS) with a capacity of 85 MW/340 MWh and ancillary infrastructure.

Attachments & Resources

Request for SEARs (2)

SEARs (3)

EIS (21)

Response to Submissions (1)

Agency Advice (12)

Submissions

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Showing 1 - 3 of 3 submissions
John Kite
Comment
TUMUT , New South Wales
Message
Submission regarding the Battery Energy Storage System (BESS) project currently on exhibition
Submitted by: John Kite, WGEH Pty Ltd (HYGEN‑X/F Division)

I welcome the opportunity to provide a submission regarding the proposed Battery Energy Storage System (BESS). While battery storage plays an important role in supporting the electricity network, its assessment must consider system‑strength, synchronous‑support, and clean‑firming requirements under current planning and energy‑market conditions.

Under the State Significant Development framework, the Environmental Impact Statement (EIS) must include feasible alternatives to the development and its key components, a detailed consideration of the capability of the project to support security and reliability of the electricity system, and an assessment of local system conditions and grid capability. These requirements apply equally to standalone BESS projects, hybrid renewable projects, and grid‑support infrastructure.

BESS provides short‑duration firming and fast frequency response but does not provide inertia, fault‑level contribution, voltage stability, or sustained multi‑hour or multi‑day dispatchable clean energy. As a result, BESS‑only projects can introduce system‑strength deficits, particularly in areas with high penetration of inverter‑based resources.

In accordance with the SEARs requirement to assess feasible alternatives, I request that the assessment include consideration of a system best described as HYGEN‑X, an alternative based on existing field‑tested and trialed technology, configured as an IP novelty. HYGEN‑X is a zero‑carbon synchronous firming technology recently assessed under Commonwealth CIS Tenders 7 and 8. It provides continuous, dispatchable clean energy, modular deployment from 5 MW to 200+ MW, and full synchronous support (inertia, fault‑level contribution, frequency stability). HYGEN‑X directly addresses the system‑strength and reliability gaps that BESS‑only projects cannot resolve.

Introducing HYGEN‑X as a feasible alternative or complementary technology would improve local system strength, reduce reliance on grid‑imported synchronous support, provide dispatchable clean energy during peak periods, enhance reliability during multi‑hour or multi‑day events, and reduce emissions intensity of firming services.

I respectfully request that the Department require the proponent to:

Assess HYGEN‑X as a feasible alternative to BESS‑only firming.

Model synchronous‑support requirements including inertia and fault‑level contribution.

Evaluate grid‑impact and system‑strength implications of a BESS‑only configuration.

Provide a comparative analysis of BESS vs HYGEN‑X vs hybrid configurations.

Consider emissions‑free firming options consistent with NSW and Commonwealth clean‑energy objectives.

Kind regards,
John Kite
WGEH Pty Ltd (HYGEN‑X/F Division)

2. Technical Annexure
Annexure A — HYGEN‑X Technical Summary
A1. Technology Overview
HYGEN‑X is a zero‑carbon synchronous firming technology combining proven industrial subsystems into a novel IP‑configured clean‑energy platform. It is comprised of field‑tested, trialed, equipment and recently assessed under Commonwealth CIS Tenders 7 and 8.

A2. Core Capabilities
Continuous, dispatchable clean energy

Multi‑hour and multi‑day firming capability

Full synchronous support:

inertia

fault‑level contribution

frequency stability

voltage support

Modular deployment (5 MW to 200+ MW)
(Comparison capability: 65/330MW HYGEN-X modules requiring a combined land footprint of 33 Hectares retrofitted to any of Australia's 125 Hydro electric schemes would supply Australia's entire firmed 2024 energy demand using existing transmission corridors eliminating REZ Corridors for the same projected final cost of Snowy 2.0.

Suitable for urban, industrial, and weak‑grid locations

A3. Comparison to BESS
BESS provides short‑duration storage and fast frequency response but lacks synchronous support. HYGEN‑X provides both firming and system‑strength services, enabling stable operation in areas with high penetration of inverter‑based resources.

A4. Relevance to SSD‑Level BESS Projects
HYGEN‑X satisfies SEARs requirements for feasible alternatives, grid capability, system reliability, and local system‑strength assessment. It is a viable alternative or complementary technology to BESS‑only configurations.

3. Comparative Matrix (BESS vs HYGEN‑X vs Hybrid)
(Annexure B — ready to attach)

Criterion BESS‑Only HYGEN‑X Hybrid (BESS + HYGEN‑X)
Firming Duration Short (1–4 hrs) Multi‑hour / multi‑day Full spectrum
Synchronous Support None Full (inertia, fault‑level, stability) Full
Grid Impact Can weaken system strength Strengthens grid Strongest outcome
Emissions Zero operational Zero operational Zero operational
Response Speed Fast Fast Fast
Reliability in Multi‑Day Events Limited High Highest
Planning Compliance (Alternatives) Partial Full Full
Urban Suitability High High High
Cumberland Council
Comment
Merrylands , New South Wales
Message
Attachments
Jamie McMahon
Support
YARRAWARRAH , New South Wales
Message
BESS projects are critical to a clean energy future for Australia. People who claim they are prone to fires or other hazards are either wrong, or intentionally working in bad faith based upon ideology.

Pagination

Project Details

Application Number
SSD-83916959
Assessment Type
State Significant Development
Development Type
Electricity Generation - Other
Local Government Areas
Cumberland

Contact Planner

Name
Cameron Ashe