MOD 2 - Increase Capacity

Submission attached.

I object strongly to this project on the unassailable solid engineering
based ground that solar and wind generation cannot under any
circumstances provide steady reliable power to a power grid. The
inherent capacity factor averages around 30% and there is no known or
potential generation technology anywhere in the world that can provide
adequate fill-in generation for solar and wind systems, except coal,
gas or nuclear based systems. Accordingly these system should not be
built at huge expense to the public purse followed by vast ecological
destruction during building and subsequently when these systems fail and
hardware has to be disposed of.

Secondly I object strongly to these systems based upon the fact that
they rely on mining by child slave labour in under-developed countries.
Australia should NOT support such reprehensible actions.

MARYVALE SOLAR ELECTRICITY GENERATING WORKS IS NOT A FARM.
NSW DPE ARE MISREPRESENTING THIS DAMAGING PLAN BY USING INACCURATE TERMINOLOGY – AGAINST THEIR OWN SOLAR GUIDELINES.

I ABSOLUTELY OBJECT TO THE OBNOXIOUS & DESTRUCTIVE MARYVALE SOLAR DUBBO - MOD 2 - Capacity Increase from 125 MW to 230 MW + Increase to Battery Storage from 125 MW/375 MWh to 230 MW/375 MWh.

This Fake Green Energy Transition/Transmission Nightmare is an absolute disaster for Australia – as many rural victims already well know - with numerous, extensive detrimental impacts & NO genuine practical benefits whatsoever!
It is glaringly obvious that the Government’s plans are cruelly unjust, totally illogical, environmentally destructive & will prove to be completely flawed & phoney.
Only listening to ‘Garbage In Garbage Out’ Modelling Theory, the loopy WEF Globalists with their sinister, controlling ESG & ponzi scheme agenda - the Fake Green predatory leeches & colluding corporates feeding from the Fake Green gravy train – now has Australia unconscionably & cruelly heading for ruination, deprivation & CCP control of our critical energy infrastructure!

It is blatantly clear that the NSW & FEDERAL GOVERNMENT COULDN’T GIVE A STUFF ABOUT RURAL AUSTRALIA, THE HEALTH-COMFORT-SECURITY OF AUSTRALIANS, OUR PRECIOUS ENVIRONMENT -BIODIVERSITY-ECOLOGICAL HABITAT-TREASURED LANDSCAPES, AUSTRALIA’S LIMITED, IRREPLACEABLE, LIFE SUSTAINING FOOD PRODUCING LAND/UNCONTAMINATED WATER SOURCES or the ASTRONOMICAL AMOUNT OF TOXIC WASTE THAT LASTS FOREVER FROM FAKE GREEN SOLAR, WIND & BATTERY RUBBISH – CURSING US & FUTURE GENERATIONS!

The Government’s clear priorities are solely to meet the farcical Commonwealth Paris Agreement/Net Zero gobbledegook targets, Fake Green RenewaBULL Energy targets & Transmission Line access. They completely disregard as inconsequential – ESSENTIAL FOOD SECURITY, AUSTRALIAN INDEPENDANT ENERGY SECURITY, NATIONAL SECURITY, HUMAN HEALTH & WELLBEING - as clearly outlined by ongoing Solar Electricity Generating Works’ approvals to further entomb AUSTRALIA’S AGRICUTURAL HERITAGE in slave labour produced, inefficient, unreliable, contaminating, electronic junk!

Maryvale Solar is yet another scandalously destructive plan to rip-off Australia – based on THE ‘LIE’ – ‘LOW INTEGRITY ENERGY!’

I object & do not consent to my family or I being subject to any of the unhealthy electrical force or contaminating impacts from Maryvale Solar or the associated Electrical infrastructure – including Transgrid’s Transmission Lines & Towers - up to 450,000 PV panels + approx. 180 shipping container style buildings housing batteries - occupying 4 hectares, the 132 KV Substation, Transformers, Switchgear, Circuit Breakers, Inverters, Cabling & other Electrical Infrastructure.
This is part of a destructive plague that is causing excessive increases in far more potent green house gases – such as man made Sulphur Hexafluoride (SF6) – 23,500 times more warming than naturally occurring CO2 – remaining in the atmosphere for more than 1,000 years!
SULPHUR HEXAFLUORIDE IS PROVEN TO BE LEAKING FROM SOLAR PANEL MANUFACTURING, INCREASING EXPONENTIALLY FROM GROSS RENEWABULL PROLIFERATION -THE EXTRA PLANNED SWITCH GEAR, CIRCUIT BREAKERS, etc.
The detrimental impacts of SF6 have carelessly & neglectfully not been taken into account at all by this plan or previously. Please address this gross error & account for this factually in full detail.
As these planned Solar Panels are NOT made from kale & carrots – it is essential to include the whole life-cycle of Solar panels in your phoney mumbo jumbo emissions targets & energy efficiency/costs comparisons - beginning with highly extractive mining industries, intensive coal fired power processing & toxic pollution – for you have clearly & probably intentionally excluded all of these vital facts.

TWO NEW PRECEDENTS HAVE BEEN SET by Oxley Bridge Rd Solar Determination Dec 2022 –

NEW MODERN SLAVERY CONDITION - requiring proof prior to construction that NO Slave Labour supply chain components be used in Solar/Wind/BESS construction.
The NSW Anti-Slavery Commissioner will now work with Wagga Council to ensure they strictly adhere to this condition.

WATER MONITORING CONDITION - TOXIC CONTAMINATION RISKS ACKNOWLEDGED – EXPERT TESTING/REPORTING, CONTAMINATION RESPONSE PROCEDURE, etc.
DPE is yet to consider & assess the LIKELY SERIOUS/IRREVERSIBLE ONSITE & SURROUNDING LAND/WATER TOXIC CONTAMINATION RISKS FROM THE SOLAR PANELS DURING THE WHOLE OPERATIONAL LIFE OF THE MARYVALE SOLAR EG WORKS – from degraded, aged, inferior, broken, hail fractured, burnt, etc. Solar Panels.

https://apps.planningportal.nsw.gov.au/prweb/PRRestService/DocMgmt/v1/PublicDocuments/DATA-WORKATTACH-FILE%20PEC-DPE-EP-WORK%20PPSSTH-149!20221124T045856.774%20GMT

**New Condition Inserted C4A - Dealing With Modern Slavery.
Commonwealth Modern Slavery Act 2018

NSW Local Council Act 1993
428 Annual Report
438 ZE Duty to Ensure Goods & Services Are Not Procured From Modern Slavery.

This applies to NSW Government Hosts, to those Procuring & those who have a Power Purchase Agreement with Solar/Wind/BESS Energy producers whose construction has used Modern Slavery Supply Chain Sourced Components.

Dr James Cockayne
NSW Anti-slavery Commissioner
M: +61 0455 255 453
[email protected]

Carolyn Kitto ‘Be Slavery Free’
Ph: 0438 040 959
[email protected]

**Amended Condition C8.
Prior to Commencement of Any Works - Storm Water Management Plan.
On Site & Discharge From the Site.
Testing Points & Regular Water Samples, Suitably Qualified Person.
Response Procedures if CONTAMINATION is Found.
Availability of Results.

UNACCEPTABLE OMISSIONS
*There is NO Decommissioning Plan Surety Prior to Construction
*NO Toxic Waste Management Plan
*NO Adequate Hazardous Toxic Fire Risk Recognition backed by NSW Fire & Rescue Research
*NO Large-Scale Evacuation Plan for Wellington area people + stock & NO Compensation Plans
*NO Acknowledgement or Reputable Medical Assessment of the Harmful EMR Health Risks
*Heat Island Effect Impacts have never been properly or accurately addressed at all commensurate with the large-scale (30 m impact only applies to a tiny Solar Works as researcher Professor Greg Barron Gafford clearly explained at the Shepparton Hearing.)
*All of these huge concerns will now be even more detrimental with this capacity increase – much larger panels & more batteries.

*Geopolitical Forces, the Energy Crisis, Cost of Living Crisis, FOOD Security, Independent Energy Security & National Security make it glaringly obvious that this plan is in NO WAY BENEFICIAL TO THE STATE OF NSW/AUSTRALIA OR ENERGY CONSUMERS so must be totally rejected, along with the whole idiotic & cruel Fake Green Transition & Transmission Nightmare, before further energy deprivation sets in, more businesses collapse, essential Coal & Gas companies desert Australia & people unnecessarily suffer & die.


**REFERENCES**

**Solar's Slave Labour Supply Chains
The graphs indicating companies & solar panels connected to Xinjiang are in the following 2 links:-
https://desdemonadespair.net/2021/05/forced-labor-from-chinas-uighur-muslims-behind-global-supply-of-solar-panels.html

**Xinjiang Solar Panels - Uyghur Slave Labour/Concentration Camps/Genocide - 'In Broad Daylight' - Professor Laura Murphy
https://www.shu.ac.uk/-/media/home/research/helena-kennedy-centre/projects/pdfs/evidence-base/in-broad-daylight.pdf

**The Office of the United Nations High Commissioner For Human Rights
https://www.ohchr.org/sites/default/files/documents/countries/2022-08-31/22-08-31-final-assesment.pdf

**Australia ratifies International Forced Labour Protocol | Australian Minister for Foreign Affairs Minister for Women Marise Payne
https://www.foreignminister.gov.au/minister/marise-payne/media-release/australia-ratifies-international-forced-labour-protocol

**Implementation of the Magnitsky Act is another avenue to ensure this shamefully unethical industry is not exploited in Australia.

**BLOOD BATTERIES - THE DARK SIDE OF ELECTRIC VEHICLES - Gravitas Plus YouTube
https://m.youtube.com/watch?v=RFHvq-8np1o

**THE DISTURBING REALITY OF COBALT MINING FOR RECHARGEABLE BATTERIES.
CLEAN COBALT IS A FICTION – THERE IS NO CLEAN COBALT - IT'S ALL MARKETING!
People need to get educated so they are agitated about it enough to do something to change this.
https://www.news.com.au/finance/business/mining/harvard-professor-explains-heartwrenching-source-of-electric-vehicle-iphone-batteries/news-story/db881f47c76db89581409c092a740c4c
Joe Rogan exposes sad truth about cobalt used in electric vehicle, iPhone batteries | news.com.au — Australia’s leading news site.
Cobalt is in all iPhones, tablets & crucially EV's - it maximises charge & stability.
Before anyone knew what was happening the Chinese Government & Chinese companies took control of almost all of the big mines in the Congo, with the local population displaced & the Congolese people under duress - digging in subhuman, gut wrenching conditions - using all raw human force - clanking the cobalt out of the ground!
Throughout the whole history of slavery, never has there been more suffering that generated more profit than was linked to more lives of people around the world than what is happening today in the Congo - mining cobalt in appalling, heart wrenching & dangerous conditions!

I object to this modification. See attached.

MARYVALE SOLAR ELECTRICITY GENERATING WORKS

– DUBBO - MOD 2 -

1/2/2023

I would like to put in my objection to the Maryvale solar electricity generating works at Dubbo. Who is protecting our finite food producing land from these toxic developments? Why is there not any bond or plans for decommissioning? Why is there NO adequate hazardous toxic fire risk recognition plans. The rush to get these developments up and running is going to cost the Australian people, irreversible damage to the environment and our ability to feed ourselves in the future.

I strongly oppose the expansion of the Maryvale Solar generating works. These solar project support modern slavery as most solar panels are manufactured in the People's Republic of China using Uyghur muslim slave labour. The cobalt used in the production of lithium batteries (needed to "back-up" these generation systems, is mined by adults and over 40,000 children in the Democratic Republic of the Congo where illness and death is commonplace. Allowing companies to source materials for their projects means Australia is SUPPORTING MODERN SLAVERY. The government must REQUIRE PROOF that any components used in the expansion of this project are NOT produce using slave labour, with the NSW Anti-Slavery Commission to ensure the developer adheres strictly to the condition. Solar projects also use high residual herbicides (eg. Velpar) to suppress vegetation beneath the panels. This chemical leaches into groundwater and entering surface water via stormwater run-off ( due to lack of vegetation to contain water movement). This presents a toxic contamination risk to surrounding water courses. Project assessors must demand monitoring of water via expert testing. Evidence from the US. Department of Energy demonstrates solar is the least efficient form of 'renewable' power generation at around 25% capacity factor. The only aspect of this process that is free, is the sun. The government must commit to providing RELIABLE, AFFORDABLE energy, and limit the expansion of renewable energy projects across valuable food-producing land. Food security must be prioritised. Additionally, the developer must be required to provide a decomissioning plan (including estimated costs and disposal methods) to ensure funding will be available to removal the toxic waste contained in the panels and batteries. Finally, there must be a assessment of the Fire Safety risk presented by these projects, and ensure a plan is in place to prevent and maintain potential fire outbreaks from this infrastructure that will release the toxic chemicals contained in these components into the environment, exposing the public to health risks from tetragenic and carcinogenic fumes.

The Government is not meeting its expectations to produce long-term, reliable, and affordable energy generation infrastructure that will support growth of industry and provide economic benefit for local communities into the future. It is proceeding to burden the next generation with cleaning up the errors on this one. Has no-one learnt from the past - tobacco, asbestos?? Wake up and examine the evidence critically and evaluate the decisions to proceed down this path of UNRELIABLE, SCANDALOUSLY EXPENSIVE power generation. Australia produces just 1% of the globe's CO2 emissions (which, by the way, is the key reactant in the photosynthesis reaction that occurs in plants to SEQUESTER CO2 FROM THE AIR!!). Trees are the best 'factories' to remove CO2 from the air. Renewable energy projects are the best destructors of those trees.

Maryvale Solar Farm - MOD 2 Capacity Increase
There is NO Decommissioning Plan or Toxic Waste Management Plan in place. Approval should not be granted until such time as acceptable plans for decommissioning with cash bonds tendered and responsible environmentally sound waste management plans are tabled for the DPE and EPA to critically access. This practice of kicking these major environmental matters down the road with the irresponsible attitude of addressing them sometime in the future (by then the developer has flown the coop), must come to an end. Contamination of soil profiles and waterways by heavy metals and BPA is NOT sustanable.
Ian McDonald
Walcha Grazier and Conservationist

I object to this project for the following reasons:

Australia has limited arable land for food production - we should not be using this limited resource for any other purpose.
There is no plan in place to ensure the end of life cycle process for the solar panels will be safely removed and recycled, without which toxic elements from the panels will leech into the soil causing irreparable damage.
What safeguards are in place to ensure these products are produced free from slave labour?
How will fires be managed and controlled to prevent release of toxins from the panels and prevent loss of life and property to neighboring landholders?

I have to object to the significant extension of the Maryvale Project in that it is seeking an increase in size and capacity.
I however find no reference to their guarantee that the project meet the requirements of the Modern Slavery Act. The conditions of the Modern Slavery Act must be included in consideration of this and all projects.
I also note that there is no provision for decommissioning and again the requirements for decommissioning must be included ahead of any such proposal being considered for approval.

Decommissioning and Site Rehabilitation. The planning authorities have failed to implement a bond system for the eventual decommissioning and site rehabilitation of renewable energy projects. Instead, they are relying on guarantees given by the developers. If the government is not prepared to underwrite these guarantees, it is acknowledging that the validity of these guarantees is questionable. As such approval of these projects must be refused.

Maryvale Solar Farm, Dubbo Region.

"FARM" is such a nice smooth gentle word, reminiscent of Ye Olde McDonald . . . and bringing forth images of fluffy white lambs gambolling around on a velvet field of luxuriant green.

"INDUSTRIAL" is what this thing is, a vast mechanical works taking up good agricultural land, full of toxic materials. And self destructing in high winds and hail.

There is considerable community push back to renewable projects. In the US over 102 solar farms and 371 wind farms have been rejected up to October 2022. Source robertbryce.com. The US communities do not want them, and nor do the Australian communities.

I object to paying subsidies. If it is so good, let it stand on its own merits. I note that Andrew Forrest's Squadron Energy has paid $4.1BLN for the Swiss CWP Renewables Australian portfolio. Two conclusions can be drawn from that:


1.That the subsidies paid and preferences granted to renewables are EXCESSIVE.

2.That Australia is buying back the enterprises we licensed out at ENORMOUS cost.



I especially object to providing subsidies from the Government, as money is better spent directly on the environment, and the contingent liabilities will reduce our credit standing.




As each new solar works and wind construction come online it makes the grid less and less reliable. Up to 50% renewables is just about manageable with 33% spare capacity in fast response coal and gas. No country has successfully gone beyond that. Doubling down with more renewables makes it less reliable. No judicial area in the world has achieved 100% renewables, even with 100% spare capacity.



I ask the proponent to itemise:

1. Public monies. Detail the description and dollar amount of each subsidy, and other benefit, both direct and indirect, to be received from the public purse in a time line. Indirect benefits, including the value of a government guarantee, need to include an actuarial calculation.


2. Itemise the amount of materials needed to manufacture and construct all parts of this project. Including rare earths, where they are going to be sourced from and disposed to.


3.Itemise the amount of CO2 released in all aspects of creating this project, and compare it with the anticipated CO2 to be saved. with timeline, including from the loss of vegetation from the site and connecting roads and transmission lines.


4. Detail the change to global carbon dioxide levels and temperature to be achieved by this project both in gross terms and net after 3. above.


5. A calculation of energy in to energy out of this project.


6. Detail how the panels and BESS will be recycled or not, frequency and amount of material to be disposed of and where.


7.Detail the number and skill level of the jobs to be created and to be exported.




I request the Planning Department:

1.That the project receives NO subsidy and NO preferences.

2. Upfront, To require a bond or irrevocable third party AAA guarantee for damage repair, removal, rehabilitation, and toxicity to third parties.


3. To ensure that NO SLAVERY or CHILD LABOUR is used in the manufacture of any of its components.


4. To require the proponent to publicly provide annual reports for the project, including itemisation of each government support, and where those are indirect, an actuarial calculation of their value to the proponent and cost to the economy, and detail their 5 min generation and supply.

5. To provide annual ESG reports.

6. To make the project, and its owner, and its ultimate owner non transferrable.


7.That adequate environmental safeguards be required for fire and toxicity.


8.The fire and toxicity of BESS, especially, have adequate safequards.

9.Require the proponent to provide and pay for their own connection costs to the grid upfront.

10.Require the proponent to pay the costs of transmission upgrades based
on their proportionate capacity, upfront.
11.Require strict limits on the frequency and voltage of acceptable supply.

12.Impose severe penalties on supply contracted for but not delivered.

13.Require effective discontinuation to enable supply to be cut when not wanted.

14.I further ask the Planning Department to apply the Precautionary Principle in relation to the uncertainty of the net benefits, and the known and likely risks to the environment, to reject the proposal.

15.If granted consent, that it be subject to the some 60 conditions which the NSW Independent Planning Commission have designed to:

prevent, minimise and/or offset adverse environmental impacts;
set standards and performance measures for acceptable environmental performance;
outline how the land can be returned to its current use following decommissioning and rehabilitation of the site;
require regular monitoring and reporting; and
provide for the ongoing environmental management of the development.

Regarding the Dubbo Regional Council, I ask the Planning Department, to enquire from Council
I. What is the contingent liability for Council and the ratepayers if the proponent, and/or the land owner walks away, or is unable to remediate the site, or clear residual toxicity?
2. Where will you provide disposal facilities for these panels and these batteries, not in 12 or 15 years, but starting now for damaged items?
3.How will you manage the flames and toxic fumes from fires that the Rural Fire Service refuse to attend?

REJECT THE PROPOSAL.

TO: NSW Major Projects regarding Maryvale Solar - doubling capacity.

POLLOCK LIMIT for solar capacity is already well EXCEEDED

Monckton, 13/1/23 writes on Francis Menton's website that:
Pollock consulted widely among grid operators, generators and academic experts. He found widespread puzzlement that after a certain point – varying from species to species and grid to grid – adding more renewables either did not increase that species’ share of total grid output or resulted in ever-growing capacity-constraint payments or do-not-generate orders to renewables generators at times of high wind, strong sun or low demand. He investigated, worked through the math and found he could answer the industry’s question. He proposes – justifiably, in my view – to submit his result to a leading journal for peer review.

He discovered a counter-intuitive and unexpected fact hitherto entirely unknown in the industry: namely, that the maximum national renewables fraction (the maximum share of total output on a national grid contributable by a weather-dependent renewable species without either prohibitively costly and logistically unfeasible static battery backup or wasted generation covered by cripplingly expensive capacity-constraint payments or disconnect orders) – is equal to the mean national capacity factor of that species (the average share of that species’ nameplate capacity that is achievable given national average annual weather patterns). Surprisingly, the mean national capacity factor of a renewable species – the greatest penetration achievable without great cost and waste – is its Pollock limit in that national grid.

Now, Monckton and Menton are having a bit of a spat about the effect of overbuilding, which is so great about our democratic system and the advancement of science. In a sense, both Monckton and Menton are absolutely correct. And I love maths.


Monckton says that the optimum proportion of renewables is equivalent to the % capacity they can produce. i.e. if it is 30%, then the optimal amount of renewables is 30%.
Any more than that, then you have overbuilt your system, and at some point you will have surplus electricity left over, which is often sold at negative prices, eg Germany pays Poland to take its surplus electricity.
Now Australia is in a pickle because we have nobody to sell this electricity to.
As a refinement in Australia, maybe you can fill up batteries, or pump water uphill, but that is not going to take much. A second refinement maybe, is that the wasted capital on overbuilding may be less than the capital cost of batteries, or rapid response backup, but that also is not going to take the percentage a lot higher.
Monkton was right if you are not going to overbuild, but then too Menton is right that a small amount of overbuilding is cheaper than its alternatives.

Sources: Wattsupwiththat, 11/1/23,Manhattancontrarian,13&15/1/23

Best wind farm in Australia got up to 48.4%, and best solar got 26.4%. BUT don't get carried away by the extremes. The 15th best wind was only 35% and solar was 22%. And there are at least 100 each of these things. I believe the average is 29% for wind and 18% solar, AT BEST. Even with 10% overbuild, we only need 33% wind and 20% solar penetration. THESE ARE SMALL NUMBERS.

Let us hope this maths penetrates the subsidy providers and State approvers.

Solar falls away quickly in the evening and has minimal contribution to the early morning peak.

One consequence of overbuilding renewables is negative prices. AER's State of the Energy Market, 29/9/22, comments:
Negative prices tended to occur when electricity demand was low and weather conditions were optimal for renewable generation. While historically occurring overnight, they are now more common during the middle of the day when solar resources are producing maximum output and demand is relatively low, AND
Between October to December in 2021, prices were negative in South Australia 27% of the time and in Victoria 22% of the time.
I am not suggesting negative prices occur during peak demand. I am trying to highlight that overbuilding is already occurring in Australia, and has consequences.

This POLLOCK LIMIT revelation is going to take some time to be fully appreciated. What I think it means, is that mathematically we can only use 29% wind and 18% solar, and we are already at 36% wind and way in excess of solar, at least 5 times in excess. There are times when the wind does not blow and the sun does not shine, and the cost of storage is exorbitant.

I am open to receiving any update to figures, or improvement to my maths.

Maryvale extension and battery is not needed, is an injudicious use of capital, and a waste of public subsidies. I OBJECT STRONGLY.

My submission is attached.

Refer attached letter.

Please refer to the attachment.

I object to this project on the basis that increases the amount of prime agricultural land that is not subject to flooding that is being acquired for this project. Large areas of NSW cropping land were flooded during 2022 and crops were lost. By approving projects such as this on prime agricultural flood free land, food shortages will inevitably result as the effects of climate change become more profound. There is little detail in any of the documents that identifies a viable and workable fire control strategy despite the orders made in ss 26 to 28A of the project approval. There is no detail on any failure to comply with these conditions or any inspection strategy that keeps a close watch on the project. The recent fire on Suntop Solar Farm that was caused by a bracket falling onto a live wire and earthing highlights the problems involved. Whilst the fire at Suntop was extinguished without major damage it is not inconceivable that a fire within the Solar Farm at Maryvale could quickly become out of control and spread to other solar farms close to Wellington. Wellington Solar Farm and Wellington North Solar Farm are within 10km of this solar farm.. This project is just 15km from Wellington and is too close. Millions of solar panels could go up in smoke and a toxic smoke cloud could hang over Wellington and cause major damage to the population. The fire control strategy is totally inadequate.