Hunter Power Project (Kurri Kurri Power Station)

I strongly object to the project.

Please refer to the attached submission for our detailed objection to this project.

I think it is morally wrong to go ahead with this project because it will worsen climate change and is not needed (there are other ways of using $600 million to improve our energy system which do not involve worsening climate change - at least not to the same degree as a gas-fired power station would). We cannot afford to prop up fossil fuels any longer. I quote part of the Federal Court Judge ruling in the recent Sharma v Minister for the Environment case, 'The physical environment will be harsher, far more extreme and devastatingly brutal when angry. As for the human experience – quality of life, opportunities to partake in nature’s treasures, the capacity to grow and prosper – all will be greatly diminished.Lives will be cut short. Trauma will be far more common and good health harder to hold and maintain.' Decision makers have a duty of care not to approve decisions that will harm people. Additionally, as a taxpayer, I am angry that this large amount of money is going towards a project that is uneconomic and also going to inflict harm on people (via climate and direction pollution impacts), rather than something that is beneficial and that addresses climate change.

Fiona Lee
109 Albert Street, Islington NSW 2296
[email protected]

Submission on the proposed Hunter Power Project (Kurri Kurri Power Station).
Application number SSI-12590060

Dear Sir/Madam,
As a mother and bushfire survivor I strongly oppose the Hunter Power Project. I urge the Minister to reject this proposal because we know that burning gas drives climate change. Gas is a polluting fossil fuel and the carbon emissions generated from the extraction and transport of it will only fuel more fires like the one that took my home and thousands of others in the catastrophic bushfires of 2019/20.

Australia doesn’t need new destructive unconventional gas. Economists, energy industry experts, power companies and the Australian Energy Market Operator have all stated that it is uneconomic and unnecessary.

Australians like myself, have lived through numerous extreme weather events in just the last two years- from enduring crippling drought then losing our home to bushfires and recently suffering through the devastating flash floods this year.

We must urgently phase out all fossil fuels, including gas, if we are to avoid more dangerous climate change. Every time we expand or build new fossil fuel infrastructure, including gas power stations, we are putting more Australian lives, like my 4 year old child’s, in danger.[1]

If we continue along our current trajectory of relying on fossil fuels to meet our power needs, I will remain fearful of what Australian summers will look like when my daughter is my age. The recent court case Sharma v Minister for Environment (May 29, 2021) established a new duty of care to protect young people from foreseeable future climate change harms and establishes a clear link between fossil fuel projects and those harms. The risks to young people are real and being felt in my community already.

“If we want to reach net zero by 2050 we do not need any more investments in new oil, gas and coal projects.” International Energy Agency, May 2021

The NSW Government has committed to a strategy to transition rapidly to renewable energy generation and storage, effectively reducing Greenhouse gas emissions and creating secure and sustainable jobs. This commitment is clearly articulated in the Electricity Infrastructure Roadmap enacted into law on 2 December 2020.[2]


Contrary to the claim made in the EIS (on page 58), the proposed Power Station is inconsistent with this NSW Government policy. The Roadmap aims to help NSW deliver on its ambitions to reach net zero emissions by 2050 and to reduce NSW electricity emissions by 90 million tonnes by 2030. The NSW Government’s commitment to a transition from fossil fuels to renewable energy is also clearly articulated in the Net Zero Plan Stage 1: 2020–2030 Plan, which aims to achieve net zero emissions by 2050 by creating new jobs, cutting household costs and attracting investment.[3]

The proposed Hunter Power Project is incompatible with the commitment made by NSW Energy and Environment Minister Matt Kean for NSW to become a “renewable energy superpower”. The Roadmap clearly differentiates the NSW Government’s approach to energy from the Commonwealth’s reliance on a “gas-led recovery”. It could see renewable energy increase from 16% of energy generated in NSW to more than 60%.

“Using gas to create electricity is a really expensive way to do it. If you’re interested in driving down electricity prices, then you’d be mad to use gas.” Matt Kean, NSW Energy & Environment Minister

We have clean and affordable alternatives to gas. Batteries and pumped hydro can provide clean and affordable power. These are dispatchable technologies and batteries are being embraced by the private sector, with a number of projects planned in NSW. Snowy hydro should invest in these technologies to help reduce New South Wales’ emissions, improve grid security and put downward pressure on electricity prices.[4]

We can meet energy demand through a combination of renewable energy and battery storage. The EIS acknowledges that a combination of grid-scale batteries and fast-start-turbines could provide dispatchable capacity and meet demands when the needs of electricity consumers are highest (p.x). Further, the EIS states that “the cost of batteries is falling, making storage an increasingly commercially viable option” (p.52).

I urge the Minster to consider his duty of care to protect young people from foreseeable future climate change harms and reject the Hunter Power Project.

Sincerely,
Fiona Lee

[1] https://www.climatecouncil.org.au/resources/net-zero-emissions-plummet-decade/
[2] https://energy.nsw.gov.au/government-and-regulation/electricity-infrastructure-roadmap
[3] NSW Government Net Zero Plan Stage 1: 2020–2030 Plan
the objective is to achieve net zero emissions by 2050 by creating new jobs, cutting
household costs and attracting investment.
https://www.environment.nsw.gov.au/-/media/OEH/Corporate-
Site/Documents/Climate-change/net-zero-plan-2020-2030-200057.pdf
[4] https://reneweconomy.com.au/big-battery-storage-map-of-australia/

Thank you for the opportunity to express an objection to the Kurri Kurri power station development.  



Whilst my background is in medicine and public health, where I have a special interest in environmental public health, I’m motivated to write to you today as a parent with a deep concern regarding climate change, air quality and biodiversity.  



Having viewed the submitted documentation regarding the development, I have five major concerns regarding the proposal: impact on climate crisis, air quality and ground water contamination; major risk of industrial accident in a fire zone, and a further fundamental concern regarding the lack of transparency on the economic case for this project. 



Climate Crisis: 



Australia, along with many other nations, is already experiencing the impacts of climate change with more frequent extreme weather events, bleaching of the Great Barrier Reef, and catastrophic bushfire seasons. These events have had profound socioeconomic and psychological impacts on communities in NSW around Australia and globally. 



To effectively reduce the risks of climate change, clear targets to reduce emissions have been put in place, including the NSW Government’s own Net Zero commitments. Construction of a new fossil fuel based power plant is extremely concerning as this contravenes our own targets. 



The stated use of diesel for at least six months to power the plant whilst awaiting gas pipelines is extremely worrying given the contribution this would have to climate change and to air quality. 



Air Quality and Water Contamination: 



The evidence base for the impact of poor air quality on health is extremely strong. The construction and operation of the plant will expose the local population to high levels of particulates, and other emissions that can have both acute and chronic deleterious effects on cardiovascular and respiratory health. It is concerning that vulnerable groups, such as the Kurri Kurri high school will be unnecessarily impacted by emissions. 



The Commonwealth Department of Agriculture, Water and the Environment (DAWE) itself, noted in relation to the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) that the proposal would have a significant impact on the environment including generating emissions and pollutants which may impact air quality, and potentially disturbing contaminated and/or acid-sulphate soils in the proposed action area with potential impacts to surface or ground water. 



During construction and operation, spills may arise from chemicals, which may contaminate soils and water. The site is already designated contaminated land because of the previous aluminium smelter, and has yet to be remediated. Construction will cause further water contamination with uncovering of persistent chemicals, including PFAS and PAH, and heavy metals. As this work has not yet taken place, the exact details of current water contamination and soil contamination and the risks presented by further construction are not yet known. This is a further red flag to the project, without knowing this information, and the extent to which the soil and water can be decontaminated, the project cannot be mitigated adequately to protect water bodies.  



Risk of major industrial accident in a bushfire zone: 



The proposed site covers an area at Category 1 risk of bushfires and has experienced previous significant fires. With a flammable fuel, this presents an additional major risk of industrial accident, and whilst mitigation factors are suggested, there is considerable risk that these are inadequate. The Royal Commission into the Bushfire season 2019-2020 concluded, ‘Catastrophic fire conditions may render traditional bushfire prediction models and firefighting techniques less effective’. Given the proximity to community, and the potential risk to workers and firefighters, this is a major concern.  



Lack of transparency on the Economic Case: 



The economic case for this power plant has not been made. Government funding here crowds out private sector competition on cleaner and better alternatives, and distorts the energy sector. No private company has taken this on as it is not an economically viable project.  



Large scale battery storage is already a viable current technology and is the necessary future for the energy sector. Significant investment here instead would solve any shortage of energy for NSW. 



There is a lack of transparency in the information provided regarding the long-term plans for the power station. No gas source currently exists in Hunter valley and a proposed pipeline from Queensland is meeting determined, well-founded opposition. The intermittent solution to fuel this power station, is highly polluting diesel, and this will be in place for at least six months of operation. This presents an additional occupational risk to workers’ respiratory health, as well as to the cardiorespiratory health of the local population.  



Whilst not covered in this proposal, if the source of gas is from coal seam gas or fracking, that raises additional and significant concerns regarding climate change. Groundwater and air pollution hazards of such extraction are well documented and these will have an impact on health and biodiversity. 



Conclusion: 



The Kurri Kurri gas project is a divisive decision which if it goes ahead, will raise significant distrust of government. The project has no economic justification, will contribute to the climate crisis, exacerbate poor air and water quality, and is counter to the NSW government’s commitment and moral obligations to mitigate the climate crisis.  



The NSW Government should be visionary in championing renewable energy sources. Battery storage now offers a viable solution to previous intermittent supply of renewable energies, and the NSW government has an unprecedented opportunity to lead in investing in, supporting and harnessing this technology.  



Taking all this into consideration I strongly urge the NSW government to reject this proposal.

Gas is a fossil fuel that results in large volumes of greenhouse gases being emitted in its production and use; funding this gas-fired power plant instead of investing in renewables is incompatible with climate goals.

I object (see attached)

I have serious concerns about this proposed gas power station. As we continue to feel the impacts of climate change amid the growing consensus that no new fossil fuel infrastructure can be built, we are extremely concerned that this proposal will add a large amount of unneeded new fossil fuel capacity to the electricity grid when we need to be phasing out fossil fuels. I also do not believe the justification provided for this project in the EIS is backed up by evidence.

The chair of Australia’s Energy Security Board said a taxpayer-funded gas-fired power plant in the Hunter Valley makes little commercial sense given the abundance of cheaper alternatives flooding the market. Gas is one of the most expensive sources of power generation and will only exert upward pressure on electricity prices. If build, this project will be a very expensive white elephant.

I urge you to you reject this proposal on economic and environmental grounds.

Yours sincerely.

I object to the proposed Hunter Power Project for the following

1 . IT IS UNNECESSARY AND WILL NOT REDUCE POWER PRICES IN NSW
This project is not needed to produce power for the grid now or into the future.There will be sufficient renewable energy plus many reliable , innovative storage solutions such as batteries and pumped hydro. The renewable solar-hydro energy plant to be built by AGL and RayGlen on the Liddell coal-fired power station site in the Upper Hunter which was announced on 8/6/21 is an example. https://www.abc.net.au/news/2021-06-08/solar-hydro-plant-to-be-built-on-liddell-power-station-site/100198274 . Further stability of the grid will be achieved by using tools within demand management programs led by energy providers and distribution network providers . That gas from this project is not needed is backed up by a report by AEMO,the Australian Energy Market Operator, which also says that any future shortfall of electricity supply will be met by renewables, storage and demand management.Tony Wood, energy program director with the Grattan Institute, quoted in The Guardian on 18/5/21 said the Kurri Kurri plant was not "just not necessary" . "It's not necessary for prices, it's not necessary for reliability and its not necessary to bring down emissions."Kerrie Schott, chair of Australia's Energy Security Board has said in the Guardian on 30/4/21 that a tax-payer funded gas-fired power plant in the Hunter Valley makes little commercial sense because of the abundance of cheaper alternatives .Kerrie Schott said"Nobody is going to build it from the private sector because it doesn't stack up. Because its expensive power, it's hard to see it makes commercial sense". This project would be a complete waste of each Australian taxpayer's money and the energy produced from the proposed gas plant would be more expensive than from other sources.The money would be better spent on renewables and storage methods.

2 THIS PROJECT WOULD RELEASE GREEN HOUSE GAS EMISSIONS WHICH EXACERBATE CLIMATE CHANGE

Coal Seam Gas or Methane which would be used in this project is 80 times more potent as a green house gas than carbon dioxide over a 20 year period . It is unconscionable to use this fossil fuel which further contributes to Climate Change which has such disasterous impacts on every living thing on the planet eg, further dystopian days , weeks and months which Australia experienced during the last bushfires.
The IEA, the International Energy Agency , in the IEA Global Energy Report Review 2021 Flagship Report states that in order to reach net zero emissions by 2050 which is required if the world's average temperature is to not rise above 1.5 degrees centigrade , no new fossil fuel projects should be permitted.

3. PROBLEMS WITH GAS PIPELINES.
"Australias's proposed gas pipelines would generate emissions equivalent to 33 coal-fired power plants " The Guardian 2/2/21, The Global Energy Monitor report says that the emissions from these pipelines will add to the threat of undermining the goal of net zero emissions by 2050 . These emissions will also increase bushfire danger .
The proposed Queensland Hunter Gas Pipeline is one of those pipelines which will result in toxic fugitive emissions of methane. This pipeline is proposed to be the conduit of CSG from the Santos Pilliga Gasfield .
There will be huge engineering challenges casued by this pipeline in the black soils of the Liverpool Plains. This pipeline will cause the destruction of fertile soils, possibly alter the water supply to some landholders.This pipeline will cease at worst or interupt at best ,farming pursuits. Landholders do not want this pipeline in or on their land. Some property owners had bought land without knowing a gas pipeline had already been approved.

4. SOURCE OF GAS.
CSG for this project is supposed to come from the Santos Pilliga Gasfields. The gasfieds are situated on top of one of the few recharge areas of the Great Artesian Basin, and there is a great possibility that the integrity of the Great Artesian Basin will be breached by toxic contaminants and depressurisation . There are fears of methane escaping from farm bores.
5. LACK OF JOBS ON THIS PROJECT
There will only be 10 onging jobs on this project once construction has ceased.

6. THIS PLANT WILL ONLY BE OPERATING 2% Of The Time.

6. STRADDED ASSETS

The Hunter Power Project at Kurri Kurri will become a stranded asset because it is uneconomic .This was explained in the AEMO report , the Energy Security Board's findings and the Grattan Institute's findings.
The Queensland Hunter Pipeline will be a stranded asset because it will not be needed to convey expensive gas to a very expensive unnecessary gas -fired power plant.

Please do not approve this project as it will be an unconscionable waste of every Australian taxpayer's money.
It is unnecessary as there are suitable , cleaner ,more healthy energy sources and storage solutions available Renewable energy sources, storage solutions and demand management means that "dispatchable energy "is redundant . The toxic green house gas emissions from this project will exacerbate the effects of Climate Change and the world will not reach net zero emissions by 2050.

Burning coal, oil and gas is driving climate change and even the extremely conservative IEA is now calling for an end to construction of new fossil-fuel-dependent infrastructure. I am aware of no objective expert opinion that says a new gas power station is necessary and it has not been technically justified by the proponent. I understand that the proposed new gas station is claimed to be intended to run very rarely, but I also understand that it is a large commitment of capital and that the owners will be keen to maximise returns and use the plant as much as possible.
AEMO’s Electricity Statement of Opportunities report (2020) found that New South Wales was not expected to exceed the Reliability Standard at any point between now and 2028-29 in absence of this new gas power station. For the Interim Reliability Measure, a capacity shortfall of only 154MW was identified after the Liddell closure in 2023-24.
AEMO expects this small gap to be filled by the New South Wales Government’s commitments under its Emerging Energy Program. With new clean dispatchable capacity already on the way and in the pipeline, there is need to build a new gas power station in New South Wales. Rather, the offered Commonwealth funds should be used to suport the urgent energy transition to renewables and away from fossil fuels.

This is a submission on behalf of the Hunter Loop of Knitting Nannas.
We strongly object to this project.
Please see the attached document for details

I wish to lodge my objection to the proposed Kurri Kurri Power Station. This proposal is wrong on so many levels, but my major objections are
- It is not necessary, apparently it is only proposed that it will operate 2% of the time, which is the equivalent to one week a year
- I object to the use of public money to fund this, money that would be better spent on hospitals and other allied health requirements, education, etc.
- this is outdated technology
- I object on environment grounds - we should be using renewable energy sources, not fossils fuels, which includes gas, and certainly not using diesel which I understand has been indicated will be used initially

I object to this project because it will add to emissions causing climate change. I went through the black summer bushfires, had my property burnt, spent a month preparing, then weeks fighting for my property and surrounding properties. We are already experiencing harm from climate change and the science explaining why is well established and available. It is utter madness that our governments continue to ignore this science and are putting us at risk.
The International Energy Agency has made it very clear that if we are to meet our commitment under the Paris Climate Agreement to stay below 2 degrees of warming, above pre-industrial levels, we can have no new fossil fuel projects or expansion of existing projects. Have you actually read this report – I strongly suggest you do and make some sound energy policy instead of these adhoc, random, poorly thought out announcements.
Further, this proposal makes no economic sense. It is a product of a complete lack of coherent energy policy. It commits $610 million of taxpayer funding to infrastructure that the energy sector has already deemed unnecessary, and that will sustain just 10 jobs a year. Why is our hard earned, taxpayer funds being put into this project? Get real and get behind renewables instead of running from the dinosaurs on the backbench.
Regards
Very concerned Upper Hunter citizen and taxpayer.

I object to the project because both AEMO and the AEC have said we do not need that much capacity. We have already seen the private sector shy away from investment because of threat of government intervention, making a very uneven playing field.
Kurri Kurri seems to be a very poor choice of location as I understand there is no readily available gas supply. Who will have to provide the gas pipeline, or will we have to see enormous LNG storage there. Will the state, the federal government (either way tax-payers) have to pay for the pipe-line, or is the private sector expected to provide it. If so they are going to want a guarantee of purchase, which will not really suit just a top-up electricity provider.
I understand it is to run on diesel for the first few months or years. This will be disastrous for our emissions, the air quality in the local area, and the cost. Diesel is known to be the most expensive and dirtiest way to produce electricity.
Even the IEA has said we should not be building any new fossil fuel projects. We would do much better with battery or pumped hydro.

Please refer to our attached submission.

This project is a moral outrage and a gross insult to the intelligence of the electorate. There is
1. No need for this electricity generation as govt experts have all reported.
2. No need for fossil fuel generation- renewables are available
3. No economic argument for gas - the most expensive option.

Please find submission attached

Concern for the environment degradation caused in my local area by coal mining and drilling for coal seam gas led me to a public information event in Coonamble in July 2019 where I had the opportunity to hear:
Mark Ogge from the Australia Institute who spoke about the devastating economic impacts of unconventional gas in regional areas, explaining a phenomena I had observed that gas projects DO NOT bring employment and economic advantage (see Mark Ogge, The Australian Institute – The Economic Impacts of Unconventional Gas - YouTube). The Kurri Kurri power station is expected to provide a mere 10 ongoing jobs; it would be more productive and socially responsible for those engaged in its construction to be employed in projects such as creating public housing
Bruce Robertson from the Institute of Energy. Economics and Financial Analysis who explained the chaos of the domestic gas market (or rather lack of a market) (see Bruce Robertson, IEEFA, Narrabri Gas Project & domestic gas markets - YouTube). We know that existing gas power stations are vastly underutilised and that a new gas facility WILL NOT reduce power prices in NSW.
Nicky Ison from the Community Power Agency who provided an overview of the potential of Australian renewables and explained why we no longer needed investment in gas (see https://www.youtube.com/watch?app=desktop&v=2ITdhMkUAeM&feature=youtu.be). The rapid development and uptake in renewable energy, together with big batteries, has led Australia’s Energy Market Operator to conclude we simply DO NOT NEED new gas projects to meet demand.
The proposed pipeline required to carry the gas to the facility is still in planning and meeting with determined resistance from communities across the proposed development: no pipeline means no gas means no working facility and an appalling waste of taxpayers’ money.
In the context of climate change, and the fact that gas is a powerful driver of that climate change, it is simply unconscionable for the Federal Government to be attempting to force the advancement of this project. As the press release from Nature Conservation Council, 15 May 2021 (release here) observed: ‘The $600M the Federal Government is squandering on a Kurri Kurri gas plant would be better invested in big batteries’
I have attached the above as a pdf as the links do not appear to be retained in this submission format.

• This would seem to be a political decision. All experts have advised that it is not economical and it is fact not needed. If the private sector is not willing to be involved than one must think that this project is an inappropriate use of pubic funds. It appears that once again the community was not consulted. The project seems to be shrouded an outcome of secret deals.
•A gas funded future is not a cheap option and this project is an expensive outlay with no prospect of providing a cheaper gas price. The Snowy Hydro already operates a gas power station not far away at Colongra on the Central Coast which is used less than 1% of the time.
• This project will provide little if any long term benefit to the local community. Ten ongoing jobs at the gas plant will not counter the harm done by the increase in pollution. The money if invested in greener alternatives could facilitate a transition away from fossil fuels, reduce pollution and bring new jobs to the local area.
• Gas is a polluting fossil fuel and extraction and transport of it is bitterly opposed by communities in the North West and Hunter. We don’t need or want to create new demand for destructive unconventional gas.
• This gas plant does not recognises or assist NSW with it's commitment to net zero emissions by 2050. This plant will be just another step toward dependence on fossil fuels by creating 14.8 tonnes of greenhouse gases over the 30 years it operates. This at a time when the International Energy Agency is stating it is critical to have no new fossil fuel projects.
• Using diesel to run the power station for the first 2 years will add fine particle (PM2.5) and oxides of nitrogen (NOx) pollution. Annual average PM2.5 levels at the nearest monitoring station already exceed national standards and ozone, which forms in the atmosphere as a pollution by-product of NOx emissions, already “occasionally” exceeds assessment criteria nearly every year.
• The baseline studies are not complete as there is no detailed investigation of existing water or soil contamination on the site provided with the EIS. Contaminants of concern include fluoride, cyanide, Polycyclic Aromatic Hydrocarbons (PAHs), aluminium, heavy metals and potentially PFAS.
• It would seem the people of the Lower Hunter are going to suffer further to pollution because the government will not embrace a transition to a fully renewable energy grid. • Gas is a polluting fossil fuel and extraction and transport of it is bitterly opposed by communities in the North West and Hunter.
• The Federal Government is touting this plant as “hydrogen ready,” but the EIS says that though there is potential for the gas turbines to be fired on a certain percentage of hydrogen in the future, that “would require some modification to the power station and gas turbines.”

• I strongly object to this project and believe it is inappropriate for NSW, Australia or the world. Our children and grand children have a right to better future and importantly a healthy environment /planet. To move ahead on this project shows Australia to be out of step with best practice and other nations of the world.