MOD 3 - Additional Adit

MOD-3 Submission – Snowy 2.0 Additional Adit
https://www.planningportal.nsw.gov.au/major-projects/projects/mod-3-additional-adit
I wish to make the following comments on the Snowy 2.0 MOD-3 proposal for an additional Adit.

INTRODUCTION
Snowy Hydro 2.0 has now placed yet another major “modification” (MOD-3) on public exhibition. It is another huge tunnel (“Adit”) and associated infrastructure within the Kosciuszko National Park.

INADEQUACY OF PUBLIC EXHIBITION PERIOD
- The Public has been given just 13 days to provide comments on this very complex proposal.
- The exhibition period is inadequate.
- The proposal should be re-exhibited for at least three months.

ADDITIONAL COSTS TO TAXPAYERS
- The purpose of this proposal seems to be to give Snowy Hydro a quick go-ahead to purchase yet another Tunnel Boring Machine at huge cost, to replace the failed “Florence” TBM.
- I can find nothing in the documentation which identifies the additional costs that this MOD-3 will incur. These should include construction costs, machinery purchase including the proposed new TBM, and the additional long term restoration costs.
- An approval would presumably enable Snowy Hydro Ltd to commit huge expenditure to commissioning another TBM. The past record of the Snowy Hydro’s TBMs is unimpressive.

IRREVERSIBLE DAMAGE TO KOSCIUSZKO NATIONAL PARK
- The damage Snowy Hydro’s project has already done to the National Park and its natural landscapes and ecosystems is irreversible and cannot ever be restored.
- The new Adit proposed would further interfere with groundwater and unique natural surface features including wetlands.
- The supporting information is voluminous but inadequate and fails to explain the cumulative and compounding impacts that this new “Adit” would have on the Kosciuszko National Park’s ecosystems and landscapes.
- The resulting spoil would add to the huge pile of waste rock being dumped in the KNP, and the spoil proposal for this MOD-3 needs to be referenced against the Main Works EIS. Dumping of the excess spoil will permanently sterilize many hectares of undisturbed park.
- Nor is there a restoration plan to remedy the impacts that this proposal would have on the landscapes and ecosystems of Kosciuszko National Park.
- Snowy 2.0 makes no comment or acceptance of long-term impacts nor the compounding effects of this and other Snowy 2.0 works.
- One can only conclude that the great Kosciuszko National Park has become an engineers’ nightmare for Snowy Hydro’s unresolved projects with scant regard for the purpose and values of this National Park.

DRAINAGE OF WETLANDS:
- Despite the claims by Snowy 2.0 that the MOD3 works will occur in the existing project footprint there has been no recognition of drainage of wetlands in the surrounding areas on Kiandra Plain, on both sides of the Snowy Mountains Highway.
- The wetlands in this area include significant and unique string bogs, the subject of much past scientific research, and they are likely to be drained and irreversibly damaged.
- The largest of these bogs is south of the junction of the Coppermine firetrail and the Snowy Mtns Highway.
- This proposal must be reviewed by expert scientists with expertise in the hydrology and ecology of wetland bogs and mires, and a public report prepared.

FAILURE OF THE SH-2 PROJECT TO PRODUCE ECOLOGICALLY SUSTAINABLE RENEWABLE ENERGY
- This latest modification proposal to the Snowy Hydro 2 project further confirms that Snowy Hydro and its Government owners have no intention, and perhaps no capability, of producing ecologically sustainable renewable energy from this project.
-Permanent and deep damage is being done to the integrity of the landscapes and ecosystems of Kosciuszko National Park by every aspect of the Snowy Hydro 2.0, from the failed tunnelling to the above-ground transmission lines, plus the extensive infrastructure scars.
- There are many ways for Australia to produce renewable energy by ecologically sustainable means, and wrecking a great National Park is NOT one of them.

MOD-3 SHOULD BE REFUSED
- The MOD-3 proposal should be refused. No number of environmental conditions attached to an approval would justify the irreversible environmental damage which will be caused by proceeding with this proposal.

CONCLUSION
This whole SH 2 project should be put on hold and a Commission of Inquiry called to consider the environmental, economic and public policy justification for its continuation.

Lorraine Cairnes
Sydney NSW
3rd September 2024

Agency advice on Snowy 2.0 Main Works MOD3

Agency advice on Snowy 2.0 - Main Works MOD3