MOD 2 - Remediation and Ground Consolidation

This Modification provides an opportunity to consider a range of issues that require review

See attached correspondence and report

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To whom it may concern.
RE: MOD 2 - Remediation and Ground Consolidation
Snowy Valleys, Snowy Monaro Regional

The Conservation Commission of the Australian Speleological Federation, (ASF) would like to make the following comments on the proposed remediation and ground works.

The MOD 2 - Remediation and Ground Consolidation document, states that: 'depending on the outcome of the works, further ground consolidation may also be required to be undertaken from the surface outside the construction envelope directly above the TBM cutting head'.
The Commission notes that in relation to the above, the report has identified a further 50 metres of material similar to that of the current 'sink hole' and that this is found in front of the current position of the TBM.

From this it can be strongly inferred that more remediation works will be needed, apart from those dealing with the current problem. The Commission can only conclude from this, that a considerable amount of grouting is going to be required. This then means, that more surface disturbance will occur than is currently being acknowledged due to the need to bring in the heavy machinery required to undertake the work.

This surface work will further impact native vegetation and habitat of a National Park adding to what are already considerable impacts from this project. The Commission notes that this project has broached environmental conditions via pollution of creeks: (see https://www.abc.net.au/news/2023-08-18/snowy-contractor-we-build-pollution-fine-national-park/102748550), and currently views further surface works with alarm.

The Commission recommends that all surface work relating to this MOD has officers from the NSW EPA present at all times along with suitably qualified NPWS staff. Further that all reports concerning these remediation works are made available to the public. This is public land and as such the general public is the biggest stakeholder and must be kept informed.

In good faith.

Dr Clare Buswell
Chair, Conservation Commission
Australian Speleological Federation.

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