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State Significant Development

Response to Submissions

Merino Solar Farm

Goulburn Mulwaree

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 solar photovoltaic energy generating facility with a capacity of 450 MW and associated infrastructure, including grid connection and battery energy storage system with a capacity of 450 MW / 1,800 MWh

Attachments & Resources

Notice of Exhibition (1)

Request for SEARs (7)

SEARs (1)

EIS (17)

Response to Submissions (1)

Agency Advice (33)

Submissions

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Showing 1 - 20 of 296 submissions
Melissa Thompson
Object
Tirrannaville , New South Wales
Message
Along with my husband, I am one of the owners of Little Gundary, a 160-acre rural-residential lifestyle property and small productive agricultural enterprise at 352 Painters Lane, Tirrannaville. Our property shares its entire western boundary with the proposed Merino Solar Project. It would run the full length of our boundary, becoming a defining and unavoidable presence in our lives.
Our property is owned through a Self-Managed Superannuation Fund and represents our entire superannuation. It is our home, our livelihood and our long-term future.
We support renewable energy and recognise its importance to Australia’s energy transition. Our objection is not to solar energy itself, but to this project being placed in the wrong location, without appropriate regard for the people and landscape it directly affects.
It is apparent that this site is attractive to the proponent primarily because of its proximity to existing electricity transmission infrastructure, which reduces connection costs and improves project economics. That reduced cost to the developer comes at a very real and enduring cost to surrounding landowners, Council and the community.
Those costs include:
• loss of rural amenity and sense of place
• heightened and ongoing fire risk
• reduced land values and financial security
• mental health impacts from loss of safety and control
• long-term road, access and emergency response burdens
These costs are externalised onto the community, while the benefits largely accrue to an offshore proponent, with minimal long-term economic benefit to Goulburn Mulwaree once construction concludes.
The Merino Solar Project:
• is outside a designated Renewable Energy Zone
• is located within an area identified in Council’s long-term residential and rural-residential planning considerations
• would permanently industrialise land currently supporting rural living, biodiversity and small-scale agriculture
When considered alongside the proposed Gundary Plains Solar Project, the cumulative impact becomes stark:
• Merino Solar Project: approximately 3,600 acres, up to 1 million panels
• Gundary Plains Solar Project: approximately 2,700 acres, around 740,000 panels
Together, these projects would industrialise approximately 6,300 acres of the Gundary Plains with more than 1.7 million solar panels for an entire generation.
The NSW Large-Scale Solar Energy Guideline requires cumulative impacts to be assessed holistically. Considering these projects in isolation materially understates their combined effect on landscape character, amenity, fire risk, land-use conflict and long-term planning outcomes.
The NSW Large-Scale Solar Energy Guideline also establishes clear expectations for how large solar developments should be planned and assessed, including:
• minimising visual impact
• protecting rural character and amenity
• ensuring early and meaningful engagement with affected landowners
• assessing fire risk and emergency access
• considering cumulative impacts and long-term land use
In our experience, and as supported by community survey material provided separately, the Merino Solar Project has not been progressed in accordance with either the intent or practical application of the Guideline.
The project will be clearly visible from our home, working paddocks, Painters Lane and Braidwood Road. Despite being an immediately adjoining landholder, no site-specific mitigation has been proposed for our property, including buffers, screening or tailored fire-risk management.
Glare and glint impacts—explicitly recognised in the Guideline due to effects on amenity, livestock behaviour and road safety—have not been adequately assessed.
Fire risk is not theoretical. A previous grass fire on the subject land reached our boundary and was stopped only due to the chance presence of a neighbouring Rural Fire Service volunteer. Based on observed fire behaviour, a future fire could reach our home in under three minutes. This risk is compounded by the condition of Painters Lane, which is narrow, unsealed and already degraded.
Consultation has been reactive, generic and inconsistent. Adjoining landholders have not been treated as priority stakeholders. This has created confusion, distress and division within a previously close community.
EDPR has not completed or operated a solar project in Australia and has provided insufficient clarity regarding long-term maintenance, decommissioning and land remediation. Based on conduct to date, there is no reasonable basis to assume impacts will be responsibly managed once approval is granted.
This land is our sanctuary. It is where our family gathers, where our teenage daughter feels grounded and safe, and where we care for animals and land. The prospect of living beside an industrial development running the full length of our boundary, combined with fire risk, loss of amenity and ongoing anxiety would have real mental-health and wellbeing consequences. It will also directly and immediately impact our plans for the farm as we would not have the confidence to continue to invest in improvements including our farm stay, truffle orchard or to support multi-generational living for our family.
These impacts are permanent. They do not end when construction finishes.
The Merino Solar Project would impose severe, enduring and disproportionate harm on directly adjoining landholders and fundamentally alter the Gundary Plains for a lifetime.
For these reasons, and for the detailed matters set out in Appendix A, we respectfully submit that development consent should not be granted.
Attachments
Name Withheld
Object
GUNDARY , New South Wales
Message
I object to the proposed Merino solar installation for the following reasons:

FIRE

EDPR have identified over 100 families affected by their proposal. There are also many other including those living in Goulburn who will be affected by the proposal when a fire on the solar land cannot be fought and the winds are from the south or south-east.

Having a theoretical fire report as to the conditions on the solar factory land is really not relevant. The fact is that in the mid 1980’s a massive and destructive fire jumped Braidwood Rd to the west of the solar land, burned large areas of the Gundary Plains, jumped Windellama Rd, burned the Plains to Kooringaroo Rd, a dead end and currently the home of over 40 families, and was not able to be contained until it reached the coast.

That fire was able to be fought but still travelled to the coast, burned thousands of stock and wildlife and badly injured volunteer firefighters.

When a similar fire starts on or burns onto the Merino solar land the physical constraints imposed by the installation including the nature of the fire including sub-station, battery and inverter fires, the 8 foot high perimeter fence, the massive number of panels and the rods that run between the rows of panels will make it impossible to effectively fight a fire if at all. As a consequence the people living on Windellama Rd and Kooringaroo Rd and beyond to the east will be faced with a catastrophic life threatening situation.

The prevailing winds across the Plains are west to north westerly which would quickly push a fire onto the solar land and from it to Windellama Rd and to the east. Goulburn winds are frequent and fierce. In September 2024 BOM recorded gusts of 96 kph. On 26.11.2 5 we experienced westerly gusts of 91kph. This is not unusual on the Gundary Plains. Look at The Bureau of Meteorology weather records. Grass fires are fast and unpredictable, affected by the wind gusts.

How will the residents of the Gundary Plains be warned of a fire especially at night. How fasts will EDPR respond keeping in mind how fast a fire driven by 92kmp gusts will travel.

LightsourceBP, the British company that wants to build a solar factory a few kilometres to the east of the Merino one stated in one of its pamphlets after their drop in session that solar farms increase the risk of fires. LSBP should be asked to explain why the fire started in their Wellington solar farm recently. This fire jumped the road and threatened the Wellington jail.

A sub-station fire is a real possibility.
On Sunday 9.10.22 a fire started in a transformer at the Canyonleigh substation near Goulburn/Gundary. The emergency crews that attended had to wait a number of hours before they could access the property. As advised to us on 14.10.22 by the RFS, the fire was still burning on 14.10.22. We were told that transformer fires are difficult to extinguish and control. The temperature of oil fires ranges from 960 to 1200 °C.
The officer from RFS Southern Tablelands Zone (one of the brigades attending) told us that, once those fires grew to a certain size, the retardants that they normally use become ineffective and that the only way that the fire could be controlled was to cool it down by spraying a lot of water on it. He said that the issue with fires on solar installations was the fact that very high voltage was involved and that specialist information was required. The amount of water that LSBP has provided for i.e. 180,000 litres of water would last for only 4 hours. They have provided no water tank anywhere near the battery.
The release of oil and/or the water used to cool the burning oil in a sub-station fire on Windellama Rd would cause major environmental pollution of the Gundary Creek flood plain which is part of the Sydney water catchment and runs through a number of properties.
For general information abut the fire see the Goulburn Post link below:
https://www.goulburnpost.com.au/story/7934936/emergency-crews-attend-substation-fire-emitting-cloud-of-black-smoke/?cs=181

This was the second sub-station fire in NSW in 2022.. There was a substation fire at the Tallawarra Power Station in Yallah in June 2022 and it impacted nearby residents in Wollongong, Unanderra and Shellharbour. Paul Baxter of the Fire and Rescue NSW described it as “a large Transgrid 33 KV (sic) transformer, a very dangerous operation, …” (see link https://wattclarity.com.au/articles/2022/06/18june-transgrid-330kv-substation-at-tallawarra-power-station-on-fire/). 16 Fire trucks attended but were unable to enter the site until they could confirm the power had been shut off and some 60 fire fighters attended along with Police and Ambulance. Details were on ABC Illawarra.
There are many instances in other states of transformers catching fire (Victoria) and the solar factories having to be closed down.

The report has completely failed to properly realistically assess the impact of the toxic smoke and fumes from a sub-station or battery fire and their impact on the neighbours and the residents in Goulburn which, as the crow flies is approximately 5 kms away. Stock, domestic animals and our soil and water supplies including household drinking water will also be affected.

The very real threat of fire from this proposal and the inability to properly fight the fire supports the position that this land is the completely wrong place to build a solar factory.

Mundy Street Bridge (from Sloane St, crossing the railway line to Braidwood Rd)
This brick bridge is so old the Council has no record of any weight limit. It is showing signs of stress at street level where the cracks have been patched with metal plates.
It is the only bridge that oversize trucks can use to access the proposed Merino site, has no weight limit recorded by Council as it is so old. It is made of bricks and if it is damaged by the trucks carrying 477 tonnes (the transformer) or 170 tonnes (other equipment) plus the weight of the vehicle, and becomes unusable or unstable it will close the Southern Railway line which it crosses. Not only will it prevent passenger travel but Veolia, the company which runs the Woodlawn incinerator at Tarago, ships approximately 110 – 132 train containers of waste to Tarago each week using this railway line. This is two trains per day, six days per week. These will either cease completely or will have to be transferred to trucks which will have to go south to Collector and turn around and use a very narrow road to get to the incinerator if that road does not have a weight limit on it. If the proposed extension to the incinerator is approved the number of container loads will increase significantly.

If the Bridge cannot be used it will also stop all truck and caravan access across the Bridge to/from Braidwood Rd including farming equipment, trade trucks, livestock trucks and tourist caravans. It will also prevent access to the Showground for regular trotting and other events including the yearly show, the yearly circus, the yearly rodeo. It will prevent access to the Goulburn Brewery and will completely disrupt Divall’s earthmoving and bulk hauling business which is on the showground side of Braidwood Road.

Braidwood Road is the road that is part of the access to the South Coast.

There is no work alternate access to Windellama and Braidwood Roads for trucks of this weight and size. The Garroorigang Bride has a height limit of 2.7m and the other possible roads, e.g. over Rocky Hill have a 5 tonne weight limit.

The inability to provide safe truck access to the solar land that will not damage existing infrastructure supports the position that this land is the completely wrong place to build a solar factory.

Community Benefits

EDPR proposes to donate $20,000 each year to an elite group in Goulburn called the “Goulburn Group”. This group is a group of political activists which restricts membership and blocks access to its face book page. It is not possible to find the names of the people on its committee on the internet. This is not a community group. There is no explanation as to what the “Group” will use the money for and whether it will in fact be used to support needy residents of Goulburn.
Appropriate recipients would be Riding for the Disabled, Rotary, The Lions Club and the many Church groups that regularly feed the underprivileged, homeless and those that need a helping hand.
There are many other groups in Goulburn that would benefit from $20,000 per annum.

State Environmental Planning Policy (Transport and Infrastructure) 2021 (SEPP)

Goulburn has been designated as a regional city.
The State Environmental Planning Policy (Transport and Infrastructure) 2021 (SEPP) provides as follows:
“2.42 Determination of development applications for solar or wind electricity generating works on certain land.

(1) This section applies to development in a regional city for the purposes of electricity generating works using a solar or wind energy source that is—.

(a) State significant development, or.

(b) regionally significant development. .

(2) Development consent must not be granted unless the consent authority is satisfied that the development—.

(a) is located to avoid significant conflict with existing or approved residential or commercial uses of land surrounding the development, and (b) is unlikely to have a significant adverse impact on the regional city’s —.
(i) capacity for growth, or

(ii) scenic quality and landscape character.

(3) In determining whether to grant development consent, the consent authority must consider measures proposed to be included in the development to avoid or mitigate conflicts referred to in subsection (2)(a) or adverse impacts referred to in subsection (2)(b). “


- The proposed Merino solar factory does not comply with the above requirements including mitigation measures and should be rejected. The first portion of the proposed project will be on land that has been mapped under the SEPP (T
Attachments
Granton Smith
Support
ORANGE , New South Wales
Message
There is a great need in Australia for more, abundant, responsibly produced and affordable electricity to be brought on stream - to serve the needs of growing communities and to help achieve our goals for carbon emission reduction. Solar energy, firmed with batteries, remains the quickest to build and deploy and most cost-effective solution when it comes to new energy production. Ask any homeowner who has installed solar on their own roof, and they will quickly tell you of the cost-saving benefits. There is also a need for energy production at varying scales and at various locations. There is no doubt that the energy grid of the future is one that is based around smart, scaleable and distributed generating infrastructure.
I have reviewed the documents and proposal for the Merino Solar Farm near Goulburn. I am wholeheartedly in support of this development. This is a well-sited location for solar PV. The location has been carefully chosen. focussed at the end of the Goulburn Airport runway, which limits the size and scope of what may be built there. The project has no impact on the planned future town expansion. The project also has ready access to existing power transmission infrastructure, removing the need to build large power lines over long distances (and impacting many more landowners). Neighbour consultation has been carried out and the design modified based on community feedback. There is a plan in place for a benefit‑sharing program that will operate into the future, ensuring the locals share in the advantages, amongst which are benefit payments of $382,500 per year (plus CPI) for the project's 35-year lifespan. The project is a $1.2 billion investment into the Goulburn region, creating over 500 jobs during construction and 10-12 permanent jobs during operation. The solar farm is truly a "farm", producing not only electrons, but through agri-voltaics, fibre as well. This is a win-win; sheep do better under the shade of solar panels, as has been the experience of farmers in other parts of NSW. They will also assist with keeping the pasture from interfering with the operation of the solar trackers. Agreements with host landowners are in place to fund the clean-up and restoration of the land at the end of the project’s life. Solar PV panels can now be recycled in Australia and the valuable component materials recovered for re-use, promoting a true circular energy economy.
In closing, this is an important large-scale solar & battery project that will go a long way to addressing future energy needs in NSW and across the National Electricity Market. I humbly rerquest that this project is looked on favourably for support to move forward.
Name Withheld
Support
Downer , Australian Capital Territory
Message
I am writing to express my support for the proposed Merino Solar Farm in the Goulburn region.
This project will contribute to Australia’s clean energy future and will bring economic benefits to the Goulburn region. I note that the solar farm is to be located on land next to the airport which is unlikely to be used for residential development. I also note that the landowners hosting the farm will continue to run sheep on the land, and this will have a positive impact as the panels will provide shade for the sheep. This is a good example of solar and agriculture working together providing benefits to farmers.
Name Withheld
Support
Giralang , Australian Capital Territory
Message
NSW has committed to achieving net-zero emissions by 2050, and with several coal-fired power stations set to close over the coming decades, the state needs significant amounts of new renewable generation to keep the lights on and electricity affordable. This project would help meet that need; a 450MW solar farm at the proposed location would generate enough electricity to power Goulburn and surrounds. The Southern Tablelands are well suited to solar generation, with an excellent sunshine resource.

Like any infrastructure project, the solar farm would create many jobs and plenty of opportunities for local businesses to provide services, materials, and accommodation. Once up and running, the facility would employ a number of people on an ongoing basis for operations and maintenance. Hosting landholders would also receive stable lease payments over the project's 30-plus year lifespan, and Goulburn Mulwaree Council would benefit from rates revenue that could support local services and infrastructure for decades. All of this benefits the local economy.

Regarding concerns about the use of the land, solar farms are generally quite compatible with farming - particularly sheep grazing - which can continue between and beneath the panels. Good project design also typically includes native vegetation plantings and biodiversity corridors that can actually improve ecological outcomes compared to open paddocks. Unlike many other forms of development and contrary to popular belief, solar farms are also reversible—at the end of the project's life, the land can be returned to its previous use.

The Goulburn area is technically well suited to a project like this. Beyond the strong solar resource, the region has relatively moderate temperatures and lower humidity, both of which help solar panels perform efficiently. Grid connection should be straightforward given the proximity to existing transmission infrastructure, and there is suitable cleared land available without significant competing land-use pressures.

We would encourage the proponent to put in place strong community benefit-sharing arrangements, which have become increasingly common for projects of this scale. These might include a community benefit fund, commitments to local hiring and procurement, or even opportunities for local residents to invest in the project. Done well, these arrangements ensure that the people living closest to renewable energy projects share directly in the benefits.

In summary, I supports approval of this solar farm. It represents a sensible and timely investment in NSW's clean energy future, with real benefits for electricity consumers, the local community, and the environment. I encourage the NSW Planning panel to approve the application, with appropriate conditions to address matters such as visual amenity, biodiversity, and ongoing community engagement.
Name Withheld
Object
GOULBURN , New South Wales
Message
I am writing to formally object to the proposed Merino Solar Farm Project.

Goulburn holds a unique and important place in Australia’s identity. As Australia’s First Inland City, it is renowned for its open green spaces, rolling hills, productive agricultural land and rural character. These qualities are not only part of Goulburn’s history, but are central to its present-day identity, liveability and long-term appeal. The proposed Merino Solar Farm threatens to permanently alter this character in a way that cannot be undone.

The large-scale installation of thousands of solar panels across open farmland would fundamentally change the visual and environmental landscape of the area. What is currently a region defined by expansive views, agricultural activity and natural scenery would become an industrialised energy zone. Once these panels are installed, the landscape will never return to its original form. This represents an irreversible loss of the very attributes that make Goulburn distinct from metropolitan areas.

My family owns property that directly adjoins the area proposed for this development, which is my aunt and uncles home. This property was purchased specifically because of its rural outlook, open views and proximity to productive farmland. The expectation at the time of purchase was that the surrounding land would remain agricultural in nature, consistent with zoning, planning controls and the established character of the area. The introduction of a large-scale solar farm immediately adjoining their land breaches that expectation and significantly diminishes the enjoyment, value and purpose of their property.

Beyond the physical impacts, this proposal has caused significant stress and anxiety for my family. The prospect of living next to an industrial-scale development, with associated visual dominance, potential noise, fencing, lighting and ongoing maintenance activity, is deeply distressing. Their home is meant to be a place of peace and security. Instead, this proposal has introduced uncertainty, worry, and a sense of powerlessness over decisions that will permanently affect their life and wellbeing.

While I support renewable energy and the transition to sustainable power sources, the location of such developments must be carefully considered. Not all land is suitable for industrial-scale renewable infrastructure. Agricultural regions like Goulburn should be protected for food production, rural living, and environmental values. Prime rural landscapes should not be treated as expendable simply because they are outside major cities.

There are numerous alternative locations and approaches that would allow solar energy to expand without sacrificing rural landscapes. Solar infrastructure should be prioritised on already-developed or degraded land, including:

Rooftops of residential homes

Commercial and industrial buildings

Warehouses and shopping centres

Car parks and transport hubs

Existing urban and metropolitan areas

Mandating solar on new homes, encouraging retrofitting of existing buildings, and utilising urban spaces such as car parks and large commercial roofs would generate substantial renewable energy without destroying rural views, farmland, or community identity. These options distribute generation more evenly and avoid placing a disproportionate burden on regional communities.

It is unreasonable for rural landowners to bear the visual, emotional and lifestyle impacts of developments that primarily benefit distant populations. Projects of this scale should not be imposed on communities that have deliberately chosen a rural lifestyle and invested their life savings into properties defined by open space and natural surroundings.

Goulburn’s landscape is not an empty canvas for industrial development. It is a living, working environment with historical, cultural and personal significance to the people who live here. Once lost, this character cannot be replaced.

For these reasons, I strongly object to the Merino Solar Farm Project and urge the decision-makers to reject this proposal. Renewable energy development must be balanced with genuine protection of rural landscapes, community wellbeing and agricultural land. Goulburn deserves thoughtful planning that respects its identity as Australia’s First Inland City, rather than development that erodes the very qualities that make it special.

Thank you for considering my submission.
Toby Eagles
Object
TIRRANNAVILLE , New South Wales
Message
I strongly oppose this development. I am a neighbouring home and land-owner to this development. I purchased my land in 2016 and built a new house in 2021 on the land moving in in 2022. I purchased this land having been amazed at the beautiful view from the property which overlooked a field full of canola which was stunning and in turn I made an offer. The house that I chose to build on this land took this amazing view into consideration and has four huge sliding glass doors with easterly facing views to take in the amazing lanscape from the kitchen, dining, lounge, laundry and master bedrooms. If this project goes ahead, the view from my house will be significantly impacted as we look directly towards this solar farm. The afternoon glare off these solar panels would greatly impact us in a negative way. When I built this property, I was not given any indication that this project was in development. If I had known I may not have purchased and chose to build this way. Although the developers may claim that this project has no impact on property values, I would have to strongly disagree as I know personally I would have not paid the same price for the land had I known. I have also been made aware of neighbours that have had difficulty selling their properties (either accepting less or unable to sell) due to this project or the neighbouring Gundary solar farm.
When purchasing this property I had been told that being within a 10km radius of the town, future development may allow for subdivision in this area. I had this in mind when purchasing this property to hopefully be in a position in the future to subdivide and help my children out in an ever so difficult housing crisis that is happening in Australia. I would also like to put a second residence on the property due to my ageing parents and in laws and to boost market value, however all of these plans are dependent upon this project and the problems that it presents.
If this project is approved, I am led to believe that it will be the largest in Australia, therefore the impacts that come with it will be heightened from any previous developments. There is a real risk with fire danger. Living uphill from this development terrifies me as I know that fire travels uphill. Along with any fires that could occur I fear that the lithium batteries if on fire will need to be left to burn out causing toxic fumes to spread to my property for days. Not something I would care to happen with my young family so close. Along with this there is the uncertainty that insurance would not cover the damage caused by such a fire. The noise of this project would also be a concern, the development of this area with trucks and machinery during construction would take many months (12-24) to complete and would ruin the ambient lifestyle we currently enjoy on our property. Once the project is complete, although the developers insist the noise would be minimal, on a quiet night at my property neighbours are easily heard having conversation due to the layout of the land and the way that the noise travels in this area so I am certain that the noise that is generated by the solar panels moving and the batteries would be irritating.
Since living at this property, we have only once had one person approach us about the development. We have had a few letters in the mail about the development, and any other information has been passed on by neighbours that have been keeping up with the developments online. Considering our house is listed in the EIS as having moderate visual impact from this development and an intermediate assessment be carried out, the lack of consultation at my property with me to photograph from my residence is insulting considering the location of my property to The Merino solar farm project. If my property has had such little direct contact, how many others are in the same category and are unaware of the process to object. The process to object is not an easy one and this gives unfair advantage to this big company to undermine the residents some of whom may not be computer literate. With such a short timeframe given to review the huge documents involved with this project how can anyone truly grasp the information given entirely. I must wholeheartedly object to the Merino Solar Farm development as I believe it will greatly and negatively impact on my existence in such close proximity to this project. The lack of consultation with not only my family but also neighbours in the area has put a great strain on the mental health of us all, the worry that our existence here is soon to be changed for the worse and having this company ignore us and our concerns.
Thank you for your consideration in stopping this solar farm from going ahead.
James Cheetham
Object
TIRRANNAVILLE , New South Wales
Message
To Whom it may concern,
I object to the Merino Solar Farm proposal and request that the consent authority refuse the application or, at minimum, require substantial redesign and further assessment. While I acknowledge the importance of renewable energy, this project presents unacceptable local, cumulative and long-term impacts that have not been adequately addressed in the EIS.
1. Understatement of cumulative impacts
The EIS treats cumulative impacts, particularly with the nearby Gundary Solar Farm, as secondary and manageable. This is not credible.
• Two utility-scale solar farms within approximately 1 km will fundamentally change rural landscape character, not merely create “low to moderate” impacts.
• Combined effects on traffic, housing pressure, visual dominance, community division and agricultural land loss are greater than the sum of individual projects.
• The EIS does not adequately consider future solar and transmission developments in the district, despite strong policy signals that more projects will follow.
Cumulative industrialisation of the Gundary and Tirrannaville rural area is occurring by increment, not by transparent regional planning.

2. Visual and landscape impacts are minimised rather than avoided. The claim that all nearby dwellings experience “low visual impact” is questionable:
• The Project covers hundreds of hectares with industrial-scale infrastructure up to 9 m high.
• No mandatory landscaping or screening is proposed, relying instead on setbacks alone.
• Visual simulations and modelling cannot substitute for the permanent loss of open rural vistas and sense of place.
• The assertion that mitigation is “not required” ignores the lived experience of residents.
This approach prioritises developer convenience over genuine landscape protection.

3. Inappropriate location near a regional city growth area
The Project is located within 10 km of Goulburn, a designated regional city expected to grow.
• The EIS underestimates long-term constraints on Goulburn’s southern expansion, scenic quality and rural-residential interface.
• Industrial-scale solar development so close to a regional city contradicts the intent of orderly land-use planning.
• Once established, this infrastructure will effectively sterilise land for alternative future uses.
4. Agricultural land and soil impacts are downplayed
Although the EIS argues the land is low capability:
• The Project will remove large areas of land from flexible agricultural use for at least 35 years.
• This land is highly productive with the capacity to grow high performance pastures and crops including canola, wheat, barley, triticale, faba beans and lucerne. It would be considered some of the highest productive soils on the Southern Tablelands.
• Soil remediation promises are uncertain and rely heavily on future monitoring and compliance. The area is prone to flooding and soil erosion and contamination on site and further down the water catchment is a real risk.
• Grazing under panels does not replace the full agricultural value or adaptability of open farmland.
• Significant noxious weeds including african lovegrass and serrated tussock would prove very difficult to control within the solar panels. This has not been considered.
• The cumulative loss of productive rural land across the district is not meaningfully assessed.
• This represents a long-term erosion of regional agricultural resilience.

5. Traffic, road safety and rural amenity concerns remain unresolved
The Project will introduce heavy construction traffic onto narrow rural roads used by:
• School buses
• Farm machinery
• Local residents
The EIS relies heavily on management plans prepared after approval, rather than enforceable design limits now. This shifts risk onto the community.

6. Bushfire, battery and emergency response risks
While the EIS concludes that risks are “low”:
• The scale of the proposed BESS is unprecedented locally.
• Fire, evacuation and emergency response planning remains conceptual and no consultation with the local RFS has occurred.
• Grass fires have the capacity to grow in size significantly prior to fire crews being able to access and extinguish the fire placing local residents and assets in elevated danger.
• Rural fire response capacity is already stretched and relied heavily on by volunteers.
• Low-probability, high-consequence risks have not been adequately addressed.

7. Community benefit scheme does not offset impacts
The proposed Community Benefit Scheme:
• Lacks clear governance, guaranteed funding levels or enforceability.
• Does not compensate those most directly affected. Council can direct funds from the scheme to other areas away from the affected residence and landholders. For example, the sealing of Painters Lane will not be completed and money used elsewhere.
• Cannot offset permanent changes to landscape, amenity and land use.
• Community funds should not be used to justify inappropriate siting.

This Project places a disproportionate burden on a rural community for benefits that largely accrue elsewhere. The EIS relies on conservative modelling, deferred management plans and narrow impact framing rather than genuine avoidance.
I request that the Department:
1. Refuse the application, or
2. Require a major redesign with:
o Reduced footprint
o Mandatory visual screening
o Stronger cumulative impact assessment
o Clear regional planning justification
Paul Smith
Support
Lyneham , Australian Capital Territory
Message
The Merino Solar Farm will bring meaningful investment to the greater Goulburn region while supporting Australia’s Renewable Energy Target and providing reliable, grid-stabilising electricity to the local grid. Goulburn is often reduced to a handful of landmarks, such as the Big Merino and the supermax prison, which can obscure the town’s capacity for growth and innovation. The development of the solar farm is a clear opportunity to shift that narrative. Hosting renewable energy infrastructure would help position Goulburn as a more serious regional town that plays an active role in Australia’s clean energy transition, and not just a place for yuppies to stop and charge their electric vehicles between Sydney to Canberra.
Rob Cumming
Object
Ravenshoe , Queensland
Message
e-mail change to soils"soilmaster.com
Dreadful EIS that does not comply with SEAR's.
I have reviewed over 200 EIS's over the year's and this does NOT achieve pass grade. Only an "E"
Attachments
Name Withheld
Support
Gungahlin , Australian Capital Territory
Message
I am writing to express my support for the Merino Solar Farm Project proposed in Goulburn, NSW. This project represents an important step in accelerating Australia's clean energy transition: helping to lower costs, enhance energy security, and reduce greenhouse gas emissions for current and future Australians. It demonstrates the vital contribution that regional hubs like Goulburn can make in addressing energy challenges, given its location along key transmission corridors connecting major load centres; in this case, Snowy Hydro, Canberra, and Sydney.

The Merino Solar Farm will make a significant contribution to both State and National Renewable Energy Targets. NSW has committed to achieving net zero emissions by 2050, and large-scale solar projects such as this are critical to reducing our reliance on ageing fossil fuel assets. A project of this scale in NSW can avoid up to 500,000 tonnes of greenhouse gas emissions annually, by displacing electricity that would otherwise be generated by fossil fuels.

The Merino Solar Farm will use Goulburn’s abundant solar resource to power approximately 200,000 homes while providing reliable and dispatchable electricity via the co-located battery particularly during evening peaks to reduce load and pressure on the system. By introducing a substantial local generation source, the project will add strength and security to the electricity grid in the Southern Tablelands.

The development phase of the Merino Solar Farm is expected to create substantial local employment opportunities. This includes construction jobs, ongoing maintenance roles, and business for local suppliers and contractors. The project has also been designed to be compatible with the surrounding rural landscape character. While solar arrays occupy the land, it allows for potential co-use such as sheep grazing underneath the panels which can maintain the site’s agricultural value while contributing to clean power generation.

The approval of the Merino Solar Farm Development Application is a valuable opportunity for Goulburn and NSW to take another tangible step toward a more sustainable, and economically diverse future. The Project has already been awarded a revenue underwriting contract under the Federal Government's Capacity Investment Scheme in October 2025. It aligns with the State’s and Federal Government's energy strategy and supports the energy transition we urgently need.

For these reasons, I encourage the NSW Planning Panel to approve the Merino Solar Farm Project.
George Mortensen
Object
Quialigo , New South Wales
Message
I strongly object to the Merino Solar Farm Proposal and any amendments they may make to it. I have these objections due to this proximity to the proposed solar installation and due to its various serious effects as outlined in my submission.

Our property, "Silver Lining" 48 Faithfull Lane, Quialigo 2580, is only a few kilometres SE of the nearest point of the proposed Merino Solar installation.

I have attached my submission.
Attachments
Martin Perera
Object
Goulburn , New South Wales
Message
My objections as a resident of Goulburn to the proposed Gundary Solar project are as follows -

Location -
- This project will destroy the scenic quality and landscape character of Gundary Plains and destroy the very fabric of the Gundary community
- The project is within the Goulburn Regional zone and within the Goulburn City limits
- This land would be better suited to Hobby/Lifestyle property blocks
- Land such as this proposed project close to Goulburn will be urgenty required for future population residential growth within the city limits

The Site :
- The site is 7 square kilometres in the middle of over 60 homes.
- Most of the site is subject land under the State Environmental Planning Policy (Infrastructure) 2007 – see Regional Cities Map – Goulburn
- Goulburn is known for its wind but not for its daily solar exposure. This is confirmed by BOM data which shows Goulburn has 88.4 mean clear days/year (according to 35 years of BOM data).
- The site is immediately west of Bushfire Prone Land Vegetation Category 1 (High Risk).Fires are a risk on solar factories – panels, transformers, batteries, substation.The common prevailing bushfire winds are W & NW on the Gundary Plains where BP proposes to build this solar factory.

Fire Risk -
- A significant fire risk for neighbours particularly the eastern and southern sides of the proposed solar factory on Kooringaroo Road from panels, batteries and substation fires.
- There is hampered fire fighting capability on solar energy generation sites to fight any fires that start or burns onto these sites.
- Many residents of Kooringaroo Road, on the eastern side of the site, live on a no through road and have no mobile phone coverage and therefore unlikely to be able to escape.

Mental Health -
- There has been and continues to be extreme mental health issues being experienced by many badly affected landowners.
- BP classify this mental health as “stress and anxiety” and therefore has no desire to accept what its proposal is doing to peoples’ lives and livelihoods.

Property Devaluation :
- BP and its operatives continually deny that neighbouring properties would be devalued.
- A number of properties have been withdrawn from market
- One family could not stand anymore and sold – they suffered a 36% devaluation of their property.
- BP has refused to discuss compensation.
- Neighbours and near neighbours’ properties will be devalued.
- Property values of surrounding properties will be drastically reduced. A reduced property value may impact on some owners’ mortgages while others will see their “superannuation” tied up in their property reduced significantly. The net effect is the taking of capital off small people (current landholders) and transferring the benefits to city bankers and multi-national corporations.

Electromagnetic Radiation :
- A very large electricity facility - 740,000 solar panels, 154 inverters, 154 batteries, 30/330KV substation
- Exposure to electromagnetic radiation is unknown
- Impact on tractor GPS guidance and Drone guidance is unknown

Destroys The Natural Environment :
- to save the planet as most of the existing trees will be destroyed including 2000 planted by Greening Australia, the Australian River Restoration Centre and a previous landowner. This will remove 1700 acres of grassland over which the Gundary Wedge Tail Eagles hunt. If the Tirranniville solar factory is approved the Eagles will loose over 3000 acres of grassland hunting area in total. A considerable number of native animals are at risk – wombats, wedge tail eagles, reptiles and open woodland birds and a large variety of ducks and swans.

Local Jobs :
- BP lied when they kept on insisting that there would be 400 jobs for Goulburn. Based on their Scoping Report, Goulburn would be lucky to get 87 jobs during the 9 Month peak period of construction

Abandoned and/or Derelict site :
- Solar farms should be required to lodge a rehabilitation security deposit with the NSW Government to cover estimated rehabilitation costs otherwise you and your children may be carrying the burden of the costs of rehabilitation through your taxes.
- There is no guarantee that the current solar farm Developers or Owners or Land holders will be around at the end of life of the facilities and there is nothing stopping the last company owning a facility going into liquidation, thus leaving no funds for decommissioning, remediation and rehabilitation and leaving the taxpayer the cost.

SOCIAL LICENCE :
- BP and Lightsourcebp have NO SOCIAL LICENCE
Name Withheld
Object
Raymond Island , Victoria
Message
I object to this project chiefly on the grounds that it is an inappropriate use of excellent farm land.
It also visually affects the outlook of all adjacent properties in what is a medium density rural living environment.
It may well reduce the value of the rural living and farm properties adjacent to the development.
There are much more appropriate tracts of land in areas of lower population density that could readily be turned over to the important use of solar power production.
Name Withheld
Object
Tirrannaville , New South Wales
Message
Please see attached PDF with full objection.
Attachments
Name Withheld
Support
Florey , Australian Capital Territory
Message
I wish to provide my support for the Merino Solar Farm project currently under public exhibition. In my view, the proposal reflects careful planning, a responsible approach to land use, and a clear commitment to delivering long‑term benefits for the Goulburn region.
The project team has demonstrated thoughtful site selection by locating the solar farm at the end of the Goulburn Airport runway, an area that ensures compatibility with airport operations while avoiding any interference with areas identified for future town growth. This careful placement shows an understanding of local planning priorities and the importance of minimising land‑use conflict.
I also acknowledge the constructive engagement undertaken with neighbouring residents. The removal of 8 hectares of solar panels from the original design to prevent direct impacts demonstrates a meaningful response to community feedback. The inclusion of a benefit‑sharing program for nearby households provides an equitable opportunity for those living closest to the site to share in the advantages the project brings.
The scale of economic contribution associated with the Merino Solar Farm is significant. An investment exceeding $1 billion, coupled with the creation of more than 500 construction jobs and ongoing operational roles, will provide considerable economic stimulus to the Goulburn region. Such investment supports both immediate economic activity and longer‑term regional resilience.
Notably, the project also supports the continuation of existing agricultural operations. Agreements with host landowners ensure that sheep grazing, including long‑standing family farming practices, can continue beneath the solar panels. This dual‑use approach reinforces the compatibility between renewable energy generation and productive farmland.
Additionally, the project incorporates responsible end‑of‑life planning through funding arrangements that guarantee full site restoration once operations conclude. This commitment provides confidence that environmental and land‑use outcomes will be responsibly managed over the entirety of the project lifecycle.
Finally, the annual community benefit payments—$382,500 per year plus CPI over 35 years—represent a substantial and enduring contribution to the local community, supporting initiatives that can strengthen social, cultural, and economic wellbeing.
For these reasons, I support the approval of the Merino Solar Farm project and consider it a positive, forward‑looking development for the Goulburn region.
Name Withheld
Object
DUBBO , New South Wales
Message
I object to the proposed Merino Solar Farm on the grounds that it is inappropriately located in close proximity to both Goulburn township and the rural locality of Tirrannaville. The proposal represents a significant land-use conflict with the established agricultural character and planning intent of the area. Land within the Tirrannaville locality is predominantly used for rural grazing and pastoral activities and supports productive agricultural landscapes, including remnant native grasslands such as kangaroo grass (Themeda australis) and wallaby grasses (Rytidosperma spp.). This land use aligns with the zoning under the Goulburn Mulwaree Local Environmental Plan 2009, which designates the area as RU1 Primary Production and RU2 Rural Landscape to protect sustainable agriculture, rural character, and environmental values. The introduction of an industrial-scale solar farm is incompatible with the objectives of these zones and would displace productive agricultural land, fragment rural landscapes, and undermine the long-term viability of pastoral enterprises. The proposal is therefore inconsistent with the relevant environmental planning instruments and fails the assessment test under section 4.15(1)(a) of the Environmental Planning and Assessment Act 1979. The site is also unsuitable under section 4.15(1)(c) of the Act due to its proximity to an established and growing regional city. Rural land surrounding Goulburn performs an important buffering and transitional role between urban areas and agricultural land. The placement of long-term industrial infrastructure in this location removes that buffer, creates ongoing land-use conflict, and risks constraining future urban growth and infrastructure planning.

The proposal fails to provide adequate separation distances from Goulburn township, Tirrannaville, and nearby rural-residential areas. Large-scale solar farms are industrial in scale and character and generate visual, traffic, noise, and landscape impacts that are inappropriate at the rural–urban interface. These impacts are amplified by the project’s proximity to sensitive receivers and have not been adequately avoided or justified. The land is located within the Mulwaree Ponds Catchment, an area known to experience high-rainfall events and periodic inundation of low-lying areas. The scale of ground disturbance, altered surface drainage, and installation of extensive infrastructure associated with the solar farm raises concerns regarding hydrological impacts within a sensitive catchment, contrary to sound land and water management principles.
For these reasons, the proposal fails to adequately consider impacts under section 4.15(1)(b), is located on an unsuitable site under section 4.15(1)(c), and is contrary to the public interest under section 4.15(1)(e) of the Environmental Planning and Assessment Act 1979. Approval would set an undesirable precedent for the encroachment of industrial-scale development near regional cities and undermine confidence in rural zoning protections. Accordingly, the proposed Merino Solar Farm should be refused.
Name Withheld
Support
Canberra , Australian Capital Territory
Message
I believe the Merino Solar Farm will play a meaningful role in supporting Australia’s decarbonisation goals by delivering large-scale renewable energy into the grid and displacing fossil fuel generation. Beyond emissions reduction, the project will stimulate regional economic growth, create skilled employment during both construction and operations, and contribute to long-term energy security and price stability. It will also attract further clean energy investment, strengthen local supply chains, and support Australia’s transition toward a more resilient, low-carbon energy system.
Lawrence Wu
Support
Canberra , Australian Capital Territory
Message
I am writing to express my personal support for the proposed Merino Solar Farm Project.
The Merino Project, designed to deliver approximately 530 MW of solar generation capacity alongside a 1,200 MWh battery storage system, represents a significant contribution to NSW’s transition toward a more sustainable, reliable, and affordable energy future. In my view, it is precisely the kind of forward‑looking investment the state needs to strengthen grid resilience, reduce emissions, and support long‑term energy security.
Beyond its energy merits, the Project represents a major economic and social opportunity for the region. It is expected to generate more than 500 direct and indirect jobs across construction, operations, local contracting, services, logistics, and supply chains—supporting livelihoods and reinforcing the local employment ecosystem. Its substantial capital investment will stimulate demand for local goods and services, boost regional procurement, and catalyse long‑term economic activity through multiplier effects. Small businesses, trades, and service providers stand to gain significantly from this inward investment, helping to enhance regional competitiveness and resilience.
I also support the Project because it is promoted by a globally respected renewable‑energy owner and operator with a demonstrated history of delivering sustainable, high‑quality infrastructure worldwide. The organisation’s strong emphasis on environmental stewardship, protection of local flora and fauna, and meaningful community engagement gives me confidence that the Project will be implemented responsibly and with genuine consideration for its surroundings.
From an environmental and social perspective, large‑scale clean‑energy developments like Merino present a practical pathway to reducing carbon intensity, diversifying regional economies, and ensuring that communities have a stake in Australia’s energy transition. With its careful design, focus on sustainability, and commitment to local benefit, the Merino Project stands as a future‑focused development that can meaningfully advance regional prosperity while contributing to NSW’s clean‑energy targets.
For these reasons, I respectfully submit my full personal support for the Merino Solar Farm Project and encourage its favourable consideration through the planning process.
Name Withheld
Support
Florey , Australian Capital Territory
Message
Merino project is the major renewable energy project which will further support the green energy pathway in Australia. The project is also the economy boost for the region as it is a 1 billion investment and will create more than 500 jobs during construction and maintain 10-12 during operation. There will be a lot of community benefits that it has reached agreements with host landowners to fund the clean-up and restoration of land at the end of project life, the farmers can continue their operations under the solar panels.

Pagination

Project Details

Application Number
SSD-59155459
Assessment Type
State Significant Development
Development Type
Electricity Generation - Solar
Local Government Areas
Goulburn Mulwaree

Contact Planner

Name
Megan Ramsdale