MOD 3 - Diesel Fuel Operation in Year 1

OBJECTION TO SSI 1259OO60 MOD 3 HunterPower Project(Kurri Kurri Power Station) Modification 3

I object to this project which will require an increase in the use of diesel fuel for the first year of operation from 175 cumulative hours per calender year up to 1,1000 cumulative hours in 2025 in order to facilitate the commissioning of the project in late 2024 .

I object to this modification project for several reasons especially the lack of information in Snowy Hydro's Modification Report.

Snowy Hydro states that this modification is necessary because of the delay in obtaining gas via a pipeline which is yet to be constructed. The reasons given for this delay are wet weather, hot weather and industrial action. The report omitted the main and most relevant reason for the delay in the pipeline construction which is the lack of landholders' consent to have this gas pipeline on or near their land. Many communities also object to this pipeline. Some of the landholders' objections are the unsuitable unstable soils for this pipeline such as the blacksoils on the Liverpool plains and the adverse impacts on their water sources.

The modification report also states that this gas pipeline is not expected to be completed untill late 2025. The amount of landholder and community objection to this pipeline would suggest that it may never be constructed . Thus the request to use diesel in the gas generators for one year would be pointless as the construction of the pipeline is uncertain and the gas may never be delivered.

The omission of the extra cost of this modification in the modification report is reprehensible . It was reported (31.8.2024 Reneweconomy.com.au )that the cost was already almost one billion dollars when the original cost of the Kurri Kurri Power Station was stated to be 600 million dollars. Australian taxpayers are the major financiers of the Kurri Kurri Project and need to know the extra cost of using diesel for 1,100 cumulative hours in the calender year 2025.

The extra cost to the health of the public and the environment as a result of the extra emissions resulting from the modification is not stated. This is an egregious omission.Diesel is a dirtier fossil fuel than gas. The report states that the modification will result in about an 80% increase in greenhouse gas emissions yet the proponent states in the modification report that the environmental impact statement does not need to be updated.This does not even pass "the Pub test". The proponent states in Section 6.2.5 that "The proposed modification would potentially result in a change in greenhouse gas emissions of 25,000 tonnes or more of scope 1 and 2 emissions ( CO2e) ". These extra emissions will exacerbate the adverse impacts of Climate Change such as unpredictable and extreme climate variability with longer and more severe droughts,more frequent and intense bushfires , a longer bushfire season and higher and unpredictable rainfall with resultant floods, all of which adversely impact human life , the environment and the economy.

This project is inconsistent with the Net Zero Plan Stage 1 :2020-2030 which is the foundation for NSW'S action on climate change and goal to reach net zero emissions by 2050.

The effect of the increase in air contaminants should not be dismissed as they are in Section 6.1 which is using old data from 2016. Sulphur dioxide can damage trees , plants,waterways and exacerbate existing heart and lung ailments in people.Nitrogen dioxide and other Nitrogen oxides are harmful to the human respiratory system.Volatile organic compounds(VOCs) also have deleterious effects on the respiratory system as well as the central nervous system .VOCs react with Nitrogen oxides to form ozone which results in the formation of fine particles which are harmful to human health.

The project modification requires the use of B-double tankers making 24 trips per day for twelve hours between 6am and 6pm to deliver the required amount of diesel. This doubles the number of tanker movements and increases the time of tanker movements by 4 hours each day. This would have an adverse impact on other road users and on those people within hearing distance of the tankers.

The modification project does not take into account the amount of renewable energy and storage which has been constructed since the original EIS was released nor does it take into account the projected amount of extra renewable energy and storage which is planned to be online by 2025. Renewable energy and storage is a clean source of energy which lacks the adverse impacts of fossil fuel sourced energy.The projected amount of renewable energy should have been included in Section 7 of the report. Justification for the proposed modification . This information would have further illustrated the lack of justification for the proposed modification.

Section 7. Justification for the proposed modification does not prove any justification at all because the claims for improved electricity dispatchability ,increasing reliability of supply and efficiency of supply of energy are incorrect. This is because this project does not supply energy 24 hours per day as the power station cannot operate for more than 10 hours before using all of the fuel reserve.

The claim that this project modification will support downward pressure on energy prices cannot be justified as the cost of individual components of the modification have not been given nor has the total cost been given. Some of these components are the cost of the extra 235 megalitres of water required, the cost of the disposal of the extra 34 megalitres of waste water produced, the cost of development of an extra 14.42ha since the publication of the EIS , and the cost of diesel.

I object to the modified project because of the omission of so much required information . There is no justification for this modified project. Please reject this project.

Thank you for accepting this submission.

Good news for everyone.

Please see the attached document

Please see attached objection.

I object to modification 3 as use of diesel could produce emissions of Polycyclic Aromatic Hydrocarbons (PAHs) which will increase the incidence of cancer in nearby residents.

See attachment

Please acknowledge receipt of submission

I am opposed to Mod 3 of the Kurri Kurri Power Station
I am a recently retired doctor with a career-long interest in the environmental determinants of human health
It has long been known that fine particulates from the combustion of fossil fuels give Australia one of the highest rates of asthma in the world.
The Climate Council has published a detailed review (“Kicking the Habit – how gas is harming our health”) which links asthma to exposure to gas cooking. It cites Australian studies which estimated that gas cooktops are responsible for 12% of the burden of childhood asthma, comparable to living with household cigarette smoke. Poorer households are at higher risk. The real figures are likely to be much higher owing to the many cases of mild undiagnosed asthma in Australian communities. Combustion of gas produces (as well as CO2) the pollutants nitrogen dioxide, formaldehyde, nitrous acid and ultrafine particles, which may all cause airway inflammation. Smaller children, with their higher rate of viral URTI’s, are most likely more at risk.
There are of course other very powerful reasons for not having methane as an energy source. There are significant rates of methane loss to the atmosphere when it is mined, and we know that as a greenhouse gas it is 84 times more potent than CO2. And burning gas here, or exporting it to be burned elsewhere, produces lots of CO2 and other pollutants. The most recent IPCC report calls for a rapid phasing out of fossil fuel production and combustion, and no new gas or coal mining, if we are to avoid much more catastrophic climate change. We are a long way from that position in this country, with conservative (coalition and labor) governments facilitating new coal mines and fracking.
Both gas and diesel are polluting fossil fuels. But what this application shows is Snowy Hydro has plans to burn a lot more particulate heavy diesel for longer. This will have a serious and negative impact on the health of the Kurri Kurri community, which was recently ranked in the top 10 worst asthma hotspots in the country.

“The Kurri Kurri gas plant’s original approval stated it would only burn diesel for two percent of the year (Page 29). This modification ramps that up to 12.5 percent of the year. That means there will be potentially six times the amount of harmful 2.5 particulate matter in the air for local people to breathe.


“The Kurri Kurri fossil gas plant should never have been built, particularly not with hundreds of millions of public dollars. Renewable energy firmed with big batteries should have been prioritised, and should be prioritised now. Renewable energy wouldn’t generate any harmful 2.5 particle pollution. It won’t make asthma rates worse, and it won’t contribute to dangerous climate change.”

My submission is to deny permission to run Snowy Hydro’s fast start, on demand hybrid hydrogen and gas plant entirely on costly and polluting diesel fuel for at least its first year. It is clear the over-time and over-budget project continues to fall miserably short of its clean energy ambitions.
The delay in construction of the pipeline to supply gas has been reportedly due to a combination of factors that include “wet weather [and] hot weather;”. This is the sort of weather that is being exacerbated by climate change, which is in turn being driven by fossil fuel emissions.
The already deplorable allowance that fuel burning equipment may be fired on diesel for the purpose of generating electrical power at the premises for up to 175 cumulative hours per calendar year, should not be increased.
Snowy Hydro says the proposed modification will result in an about 80 per cent increase of year one greenhouse gas emissions. This is unacceptable and should not be permitted.