Kamay Battery Energy Storage System

This dangerously hazardous Kamay BESS risks human lives, irreversible ecological harm and coastal hazards.

The project site sits on a low-lying peninsula vulnerable to coastal erosion and saltwater intrusion.
Exposing large-scale electrical and chemical infrastructure to these coastal risks over its limited lifespan ignores the Precautionary Principle and creates long-term hazards for the local environment, residents and visitors.

A large battery facility presents the possibility of an emergency requiring specialised fire response, exclusion zones or evacuation. The consequences could be particularly serious on the Kurnell peninsula if emergency access or evacuation routes were compromised. I ask the Department to require detailed modeling of a worst-case battery incident, including simultaneous access by emergency services and evacuation of surrounding communities. The assessment should also consider cumulative development in the Kurnell area rather than assessing this facility in isolation. If the project is approved, the developer should be required to fund any additional emergency infrastructure or equipment made necessary by the development. The host landowner and developer should also jointly provide a legally enforceable financial bond sufficient to cover complete decommissioning, battery removal, waste disposal and rehabilitation.

The proposal involves up to 150 MW of power output and 300 MWh of storage using Lithium Iron Phosphate battery chemistry. The EPA’s advice confirms that the project includes battery infrastructure together with fire and stormwater management systems. I am concerned about the consequences of a serious thermal event, including smoke, heat, damaged battery materials and the possibility of contaminated firefighting water. The Department should require an independent assessment of the worst reasonably foreseeable fire scenario, not merely an assessment based on normal operation.
The developer should also be required to demonstrate that emergency services have sufficient access, water and equipment. Any approval should include a substantial decommissioning bond provided by both the host and developer.

Statement of Opposition to the proposed Kamay Battery Energy Storage System (BESS) – Kurnell - SSD - 92494458

I am a proud Dharawal woman, and a Kurnell resident. I strongly oppose the approval of the Kamay Battery Energy Storage System (BESS) at Kurnell . Kurnell is not just a place—it is sacred land. It holds deep spiritual, cultural, and historical significance for my family, my ancestors, and our wider Dharawal community.

Kurnell tells an important story—not only of Australia’s colonial history, but also of the world's oldest living culture. For Dharawal people, this land holds ancestral connections that go beyond physical boundaries. My ancestors are buried here. They fought to protect this land, and as their descendant, I feel a deep responsibility to continue that fight.

It is heartbreaking and deeply disrespectful to witness toxic waste being poured into the land where our ancestors lay to rest. The continued industrial activity, particularly by AMPOL, has caused significant harm to the environment, the local community, and the cultural integrity of this sacred site.

This land should be respected and preserved as a place of peace, memory, and cultural continuity—not degraded into a toxic wasteland.

The flora and fauna of Kurnell are an inseparable part of Dharawal identity. Our stories, totems, and cultural teachings are embedded in the landscape. Clean air, clean water, and a healthy environment are essential—not just for wildlife to survive, but for our cultural heritage to flourish.

AMPOL previously committed to cleaning up chemical spills and environmental damage. However, these commitments have not been fulfilled. Instead, we continue to witness pollution in our waterways, the air we breathe, and the soil beneath our feet.

AMPOL has a responsibility to protect the health and safety of Kurnell and surrounding communities. To date, this responsibility has not been met. The ongoing contamination must be addressed—immediately and fully—before any new development or modification is considered.

This should be rejected outright. Instead of further industrial expansion, the land should be rezoned and restored, with recognition of its cultural, historical, and ecological value.

Kurnell is not just land. It is living culture, sacred ground, and the heart of a story that deserves protection and respect.

The NSW Government’s environmental assessment advice states that a BESS would be classified as hazardous industry under the flood-prone land package and that Sutherland Shire Council’s flood provisions require the proposed BESS, including battery pads and arrays, to be outside the probable maximum flood extent. I believe this issue deserves particularly rigorous scrutiny. The Department should require the applicant to demonstrate that every component of the facility will remain safe during extreme flooding, including climate-change scenarios. The assessment should also consider what happens if flooding prevents emergency access or affects drainage from the site. I request that no approval be given unless flood safety is independently demonstrated.

The NSW environmental assessment advice specifically identifies the Giant Dragonfly (Petalura gigantea) as a species that has been observed during biodiversity surveys in the broader area and may use habitat near the proposed site.
This demonstrates that biodiversity impacts cannot be treated as a minor consideration.
I request a thorough assessment of direct and indirect impacts, including construction disturbance, drainage changes, lighting, noise, fire and potential contamination.
The Department should require independent ecological monitoring before, during and after construction.
If the project is approved, the developer should pay for all required environmental monitoring and rehabilitation.

As Kamay BESS is based on market manipulation, subsidy rip-offs, economic inefficiencies and ever increasing network risks, this places seriously unjust pricing burdens on energy consumers.

The $165 million cost for the Kamay BESS introduces high capital expenses into the network, which are unfairly recovered through consumer power bills - which are already totally unaffordable thanks to astronomically costly
RUIN-A-BULLS that don’t even work most of the time!

Because large batteries suffer from rapid capacity decline, consumers bear the financial burden for an asset that offers diminishing returns, conflicting with the NSW Government’s claims and the National Electricity Law’s requirement of cost-efficient energy.

There are many concerns about what could happen to water during a major battery fire. A serious fire could require firefighting operations involving contaminated water and damaged battery materials. This is particularly important in a location surrounded by sensitive environmental areas. The project should have a fully engineered system capable of containing and safely managing contaminated firewater.
The Department should require the proponent to demonstrate the maximum firewater volume that could be generated and exactly where that water would be contained.
No contaminated water should be permitted to escape into surrounding drainage systems or environmentally sensitive areas.
The developer should be responsible for all costs associated with environmental damage caused by the project, backed by an appropriate financial security.

The visual impact of another large industrial installation on the Kurnell peninsula.
The BESS will involve battery infrastructure, electrical equipment, internal roads, fencing, lighting and associated buildings. The EPA confirms that these forms of ancillary infrastructure form part of the proposal.
The visual impact should be assessed from surrounding roads, residential areas, recreational areas and sensitive landscape locations.
Screening vegetation should not be treated as a complete solution if the infrastructure remains prominently visible.
I request a detailed landscape assessment and enforceable landscaping requirements.
Most importantly, all major infrastructure should be removed at the end of the project’s life rather than becoming a permanent industrial feature.

This proposed development is being considered in an area with a documented contamination history.
The NSW EPA has identified PFAS at and around the former Caltex Kurnell site, including detections in groundwater and surface waters, with investigations concerning off-site migration.
I am not suggesting that the proposed BESS caused this existing contamination.
My concern is that excavation, drainage and construction must not disturb contaminated material or change groundwater pathways.
I request independent baseline testing of soil, groundwater and surface water before construction.
The results should be publicly available.
If the project causes or worsens contamination, the developer and host should be legally responsible for the complete remediation cost.

All BESS contains equipment such as transformers, cooling systems and electrical infrastructure that can produce continuous or intermittent noise.
Noise impacts should be considered at the nearest residential receivers and during night-time conditions when background noise is lower.
I request independent acoustic modelling rather than relying solely on predicted compliance.
The Department should also require post-construction noise monitoring and immediate corrective action if limits are exceeded.
If complaints are received, residents should have access to independent investigation rather than being required to rely solely on the operator’s assessment.
The developer should pay for ongoing compliance monitoring.

Please see attached document.

I am not satisfied that the applicant has demonstrated that this is the most appropriate location for a BESS of this scale.
Electricity storage is important, but location matters.
The alternatives assessment should compare this site against other potential locations according to: distance from homes, emergency access, flood risk, biodiversity, environmental sensitivity, fire risk & traffic; existing industrial impacts and long-term land-use value.
If another location can provide the same electricity-storage benefit with substantially less risk to residents and the environment, that location should be preferred.

A planning approval should not simply assume that the future operator will always have the money to dismantle the facility.

Battery projects have a finite operating life, and the community should not inherit obsolete infrastructure.

I request that the Department require a legally enforceable decommissioning plan before construction begins.

More importantly, both the host landowner and developer should be required to lodge a substantial financial bond.

The bond should cover removal of batteries, electrical equipment, buildings, roads and foundations, waste disposal, environmental remediation and restoration.

It should be independently calculated, indexed and reviewed throughout the project’s life.

This project needs a credible end-of-life strategy for its batteries.
The proposal involves up to 300 MWh of battery storage.
The Department should require detailed information about how the batteries will eventually be removed, transported, recycled or disposed of.
This should include damaged batteries and batteries involved in fire incidents.
The proponent should identify appropriate facilities capable of accepting the waste and demonstrate that transportation and disposal will comply with environmental requirements.
The cost should remain the responsibility of the project.
A bond should be established at the beginning of the project to guarantee end-of-life management.

The project could create additional demands on emergency services.
The Department should obtain detailed advice from the relevant emergency agencies regarding the equipment, training, water supplies and response procedures required for a 300 MWh BESS.
If additional equipment or infrastructure is required because of the project, the developer should fund it.
The local community should not have to subsidise the emergency-response requirements of a private infrastructure project.
The approval should also require regular emergency exercises involving the operator and relevant authorities.

Decommissioning obligations are ineffective if the responsible company becomes insolvent.
The financial security should therefore be established before construction rather than relying on a promise that money will be available decades later.
I request that the host and developer be jointly responsible for a substantial bond.
The bond should remain protected even if the project changes ownership.
It should only be released once independent experts confirm that the facility has been completely removed and the land rehabilitated.
This would ensure that private development does not become a public liability.

Is the environmental monitoring sufficiently independent and transparent.

The project should have baseline monitoring before construction and ongoing monitoring throughout operation.

Monitoring should cover relevant water, soil, drainage and ecological indicators.

Results should be made publicly available rather than being available only to the project operator.

There should also be a clear process for responding to unexpected contamination or environmental changes.

The developer should fund this monitoring, but the monitoring should be overseen by an appropriately independent authority or expert.

A financial bond should remain available to deal with environmental problems discovered during or after the project’s life.

The facility requires significant energy from the grid just to run its climate control systems and prevent the batteries from overheating.
This ongoing power drain reduces the overall efficiency of the system, turning the BESS into an energy-wasting asset rather than an efficient solution for clean power storage.

I object because the project will introduce additional hard surfaces and infrastructure that may change stormwater behaviour.
The EPA confirms that stormwater management is part of the proposed ancillary infrastructure.
The assessment should demonstrate that stormwater will not be diverted onto neighbouring land or environmentally sensitive areas.
It should also address extreme rainfall rather than relying only on ordinary rainfall conditions.
I request continuous inspection and maintenance of stormwater infrastructure throughout the project’s life.
The developer should remain financially responsible for any environmental damage resulting from inadequate stormwater management.