MOD 7 Infrastructure consolidation and remediation

Family from Kurnell with young children.
We are the Scarra Family. Proud home owners in kurnell.
We strongly object this mod proposal as a father of young children i cannot consciously look my children in the face if I was to allow capping of toxic chemicals so near to my child's pre school and their favorite tennis and basketball courts at the reccas.
They really enjoy viewing the wetlands around marton park and bird watching all of which is at risk if this pollution legacy is allowed to continue.
My recommendation would be to Reject Mod 7.
Demand off-site remediation, And look to rezone the space rezoning for tourism which would complement the new visitor center and the beautiful new whale watching station around the corner.
PFAS containment; floods risk wetlands (Mod7 Report (Sec 4 Pg 60
Fig 7-5 Pg 111)
• Threatened species; capping endangers runoff (Scoping Report
Pg 51: Fig 4-3 Pg 58)
• No audits & indefinite evade responsibility; PFAS cases harm
ecosystems. Zoning blocks green spaces (App G Pg 8, Sec 3 Pg 53,
Fig B-2 Pg 240)
Subdivision reduces accountability; jobs don't outweigh risks, we have to stop think short term and rather the longer term impacts to the environment especially within the Sydney basin.

The project is againts the environment

Objection to Modification 7 – Kurnell

I am writing to express my strong opposition to Modification 7 proposed for the Kurnell site. As a local resident, I am deeply concerned about the serious risks this project poses to the health of our community and the long-term well-being of our environment.

The proposal allows for the ongoing presence of dangerous contaminants on-site—including PFAS, hydrocarbons, and asbestos—under a plan to simply cap the pollution rather than remove it. This shortcut is reckless. In an area prone to heavy rainfall and flooding, these toxins could easily be washed into surrounding ecosystems like Botany Bay and local wetlands, contaminating the very places where we live, fish, swim, and enjoy nature.

This isn’t just theoretical—on 7 April 2022, Ampol spilled thousands of litres of hydrocarbons into the local environment during a rain event, exposing the community to harmful toxins. Despite this history, they are now seeking to avoid proper land remediation and instead push for permanent industrial zoning. This is a clear attempt to prioritise cost-cutting over community safety and environmental responsibility.

This modification would lock in more industrial development, increasing pollution, noise, and traffic, while stripping away precious green space. It would damage local tourism, harm wildlife, and limit future opportunities for sustainable development.

Kurnell is surrounded by unique and ecologically important areas like Towra Point and Quibray Bay—critical habitats for migratory birds and mangrove systems. These environments cannot be sacrificed for corporate convenience.

I urge the NSW Government to reject this proposal. We deserve better than a capped contamination site in our backyard. The land should be properly rehabilitated, as originally promised, and returned to the community as safe, open green space.

I am writing to express my strong objection to Modification 7 (Mod 7) for the proposed Infrastructure Consolidation and Remediation at the former refinery site in Kurnell.

The consequences of industrial activity in Kurnell have already been felt. To add to this disregard’s any consideration or concern to the people and local environment. It would be unfair and irresponsible for this project to be approved.

I urge the Department to reject Mod 7. Kurnell deserves to be a place that is safe and healthy to live.

Please choose community well-being.

I am writing to express my strong objection to Modification 7 (Mod 7) for the proposed Infrastructure Consolidation and Remediation at the former refinery site in Kurnell.

My family has called Kurnell home for over 10 years and now own our factory out there. It’s where my children grew up and where generations of us have lived and feel so lucky to have called Kurnell home.

The plan to leave dangerous contaminants like PFAS, hydrocarbons, and asbestos buried on site covered rather than removed is not a genuine clean-up. It’s a cost-cutting measure dressed up as remediation. Allowing toxic waste to remain in the ground puts our health, our wetlands, and our future at risk particularly as climate change brings more frequent and severe weather events that could disturb these materials.

Having lived through 2 natural disasters - the tornado and bush fire that spread throughout the coastline - we were so terrified of the impact the past use of the land could have if any of the residual oil caught fire.

The threat of dangerous harmful chemicals being so close to homes, day care centre, schools (not even in Kurnell but local suburbs) & eventually more tourists with the new wharf built scares our family. The amount of people that will be exposed to these dangerous chemicals is beyond just a tiny suburb. So many people work in Kurnell and visit the birth place of Australia, how could you allow a corporate giant who has more than enough profit to dispose of their own contaminated waste while knowing dramatically damage the land and people around them.

We all have to dispose of our chemicals properly - why don’t they?

The endangered migrating birds, whales and many other animals will be affected as these chemicals leech into the water.

By allowing this you are forever changing the land and locking it into industrial use forever.

Consequences of industrial activity in this area. The smells, the spills, the damage it’s already affected people’s health, homes, and the local ecosystem. To make this situation permanent is not only irresponsible, it’s unfair to those of us who have invested our lives here.

I urge the Department to reject Mod 7.
I know of no business that are allowed to dispose of their own contaminated waste however they feel fit without any standards or checks.
Ampol should be required to remove all contaminated material off-site, undergo independent environmental auditing, and be held to a clear, enforceable timeline. Kurnell deserves a future that is safe, healthy, and built on genuine care for the land and the people who live here not one built on buried toxins and broken promises.

Please choose long-term community wellbeing over short-term corporate convenience.

I strongly object to Modification 7 (Mod 7) of the Ampol Kurnell remediation project. This proposal seeks to abandon the original commitment to fully clean up decades’ worth of toxic waste and asbestos contamination at the former refinery site. Instead, it allows Ampol to leave harmful materials buried onsite, capped and hidden beneath future industrial infrastructure.

This approach is unacceptable.

Kurnell is a fragile, significant coastal environment surrounded by wetlands, ocean, and Botany Bay. Leaving toxic waste in the ground, even with a cover, risks long-term leaching into nearby waters, soil, and ecosystems. Asbestos, hydrocarbons, and other contaminants do not simply disappear, they pose serious health risks to residents, workers, wildlife, and future generations.

Mod 7 is not about protecting the community, it is about saving Ampol money.

Approving this modification would set a dangerous precedent, that large corporations can walk away from their environmental responsibilities when they no longer serve their business model. The community deserves a proper, transparent remediation process that genuinely cleans the land and restores it for safe future use.

We urge the Department of Planning and Environment to reject this modification and require Ampol to uphold its commitment to full site remediation, including the removal and safe disposal of all hazardous materials. The health of the community and the environment must come before profit.

Sincerely,
Nicola Caulfield
Visitor to Kurnell

Submitter Demographic: Resident - Family (Parents with young children, Kurnell homeowners)

We are the Mulder family, Claire (46), Matthew (42), Harrison (13) and Layla (6). We have lived in Kurnell for over five years. I strongly object to the Mod 7 Infrastructure proposal's plan to permanently contain and cap contamination on-site instead of fully remediating the land.

Ampol’s approach to leave toxic materials under a capped surface may lower costs but puts community health, environmental safety, and long-term land use at risk. Containment is not remediation—caps can fail over time, exposing toxins to soil and water, and putting public health in danger.

Capping the site rather than cleaning it denies the community a true restoration of the land and can prevent future remediation efforts. This sets a poor precedent for polluter responsibility.

The decision shifts risks from Ampol to the local community and externalizes costs, leading to potential environmental injustice, especially for future generations.

Best practice requires removing contamination where possible, particularly in sensitive or urban areas. On-site containment does not meet modern standards for environmental management.

The lack of transparent consultation and information about the contaminants erodes public trust in both the company and the approval process.

I urge the planning authority to reject the Mod 7 proposal until a full remediation plan with complete contaminant removal is implemented. The community deserves a truly clean and safe environment.

Many Thanks
Claire

I am writing to express my strong objection to the proposed large-scale battery storage facility in Kurnell.

My family moved to Kurnell just over a year ago, drawn by its rare combination of natural beauty, community spirit, and coastal tranquillity. We chose this suburb because we believed it would be a safe and healthy place to raise our children — surrounded by clean air, open space, and the ocean, not industrial risks and environmental hazards.

This proposal jeopardises that completely.

A battery storage facility of this scale brings serious and well-documented concerns: fire risk, chemical exposure, and the long-term degradation of a sensitive coastal environment. It has no place in a suburb like Kurnell, where families live, children play, and nature is still very much part of daily life.

We don’t want to raise our kids in a suburb where danger sits quietly behind fences. We want them to grow up outdoors, by the water, not wondering what might be leaking into the soil or air. Once a project like this is approved, the character of the area changes — and it doesn’t change back.

The land here should be rehabilitated, not re-industrialised. Our community deserves decisions that reflect long-term care, not short-term cost-cutting or corporate convenience. This is not the right location for a facility of this nature — and no level of spin will change that.

I respectfully urge you to reject this proposal. Protect what makes Kurnell special, and give families like ours a future we can count on.

I am writing to strongly object to the proposed plan for a large-scale battery storage facility in our beachside suburb of Kurnell.

Im not sure why Kurnell is always the first go to place to dump all kinds of inconvenient stuff

Kurnell is not just a location on a map — it is a place of deep natural beauty, historical significance, and tight-knit community. It is where children ride their bikes to the beach, where families gather to watch sunsets over the bay, and where generations have come to find peace in nature. Proposals like this threaten to permanently alter not just the physical landscape, but the very character and soul of this special place.

The plan to install an industrial battery storage facility here is deeply troubling. It introduces serious risks — including fire hazards, toxic leakage, and long-term environmental degradation — in a fragile coastal ecosystem that should be protected, not exploited. Once you industrialise a coastline, you do not get it back. The scars will outlive us.

It is irresponsible to sacrifice a community’s natural heritage and future wellbeing for short-term infrastructure convenience. We should be investing in projects that restore and protect the area, not further burden it with industrial operations. This proposal prioritises corporate and commercial gain over the health, safety, and wishes of the people who actually live here.

Our children deserve to grow up in a clean, safe environment — one where they can play outdoors, breathe fresh air, and connect with nature. They should not have to live with the fear of battery fires, chemical runoff, or restrictions around public access to coastline areas. Once this project begins, there is no going back. The beauty we lose today is gone for them tomorrow.

Our suburb deserves better. Kurnell deserves better. We ask for transparency, independent environmental oversight, and a genuine commitment to protecting what little untouched coastline we have left. This is a place worth saving — not just for us, but for the generations who will come after us.

Please reject the current proposal. Let us build a future here that we can be proud of.

I feel this project will be devastating to the health and well being of people who live in Kurnell and surrounding suburbs. I feel it will also destroy the unique biodiversity of the area, the land, ocean and the fragile ecosystems existing here.

As a local resident and part of a young family, I strongly object to Mod-7.

The idea that a known contaminated site – with toxic waste, asbestos, and chemical pollution – could be “covered up” rather than properly cleaned is incredibly alarming. I am shocked that this is even being considered on such a prominent and sensitive part of the Kurnell Peninsula.

We were promised that this land would be made safe for the future — not left as a ticking time bomb under heavy industry. This isn’t cleanup. It’s a shortcut that benefits Ampol but puts families, children, and the environment at risk.

I’m also deeply concerned about how hard it is to understand these documents. They are filled with jargon and technical language that makes it difficult for everyday people – especially working parents juggling family life – to stay informed or even know what’s happening.

What we do understand is this:
• Dangerous toxins will remain buried on site.
• A massive industrial facility will dominate the area.
• The risk to surrounding homes, wetlands, and water remains.
• We lose the chance to ever reclaim this land as a safe space for future generations.

Please do not approve Mod-7. This is not how we build safe, healthy communities.

We ask that you hold Ampol accountable to fully remediate the site — not just bury the problem. Kurnell deserves better.

To the Independent Planning Commission, NSW
Re: Objection to SSD-5544-MOD 7 – Infrastructure Consolidation and Remediation, Kurnell Terminal
My name is Ronald Bussing and have been a land owner in Kurnell since 1998 ,prior to this I grew up in Kurnell with my parents and siblings arriving here in 1960 when we immigrated from Holland . During this period I have seen huge changes to the land use and environment.
Now I wish to formally object to the mod 7 proposal of Caltex .
I am deeply saddened by the change of plans on the Caltex site ,as a former employee for 18 years and also being involved in the demolition of the refinery plant . The original plan was to eliminate all hazardous material from the site over time . Just a few of these were
# 1 During the transition to a terminal a temporary storage area of asbestos waste on site was prepared and fulfilled during and after my redundancy . But knowing the amount of waste contained in metre square bulker bags then stacked and wrapped in rubber sheeting would have been in the thousands tons ,my estimation. I don’t believe that this storage facility will last as a permanent facility . The asbestos waste should be removed from this site as first proposed.
# 2 Waste sludge and hydrocarbon waste was dried in bags from the cleanup of the redundant tanks there were 50 bags containing 50 cubic meters of waste each when I was made redundant and all this was going to be burned offsite at a high temp combuster in Victoria . It seems this plan has been thrown out the door . I worry that this is an environmental disaster waiting to happen if another flood event occurs as seen in 2022 .
# 3 The proposal to remove the oily water sewer would be preposterous as there are still tanks that drain into this system and get processed in the separators and the through the bio-treater to remove phenols and other contaminants from the whole site. This could also have a significant negative impact on the mangroves if another flood event happened. An environmental disaster could spell the end to Botany Bay as we know it and this may affect the whole Georges river network.
#4 The value of properties in the community have the potential to be impacted severely if this proposal goes ahead. The cost to remediate the site in the future will only blowout further than estimated and possibly be forwarded on to the council as the industrial energy hub is set up and the potential to give the land back would be taken away from any stakeholders.
I wish to formally object to the proposed MOD 7 changes to the Kurnell Terminal development. While the proposal claims to support environmental rehabilitation, the substance of the modification falls far short of true remediation and presents ongoing risks to the local environment and community.

The public consultation process has been wholly inadequate. A complex, highly technical proposal like MOD 7 should not be rushed through with only 15 days on public exhibition. This timeframe does not allow residents, councillors or independent experts to properly review and respond to the impacts. Transparency and genuine community consultation should be fundamental in any project of this nature—especially in a sensitive area like Kurnell.
The decision to cap existing contamination rather than remove it is deeply concerning. This approach leaves hydrocarbons, asbestos, and PFAS chemicals in the ground permanently. Worse still, the proposal involves redirecting stormwater flows through new open drains that discharge into nearby wetlands. This dramatically increases the risk of polluted runoff entering Quibray Bay—a protected ecosystem already damaged by previous industrial activity.
Kurnell has a recent history of environmental incidents, including a significant diesel spill from the same operator that killed large areas of mangrove forest. There is no evidence that adequate safeguards have since been implemented. Approving MOD 7 as it stands would entrench these risks instead of correcting them.
Furthermore, there is a lack of independent oversight built into the proposed remediation strategy. The proponent should not be left to self-manage long-term environmental hazards without third-party verification and regular public reporting.
In summary, MOD 7 should be rejected until proper public consultation occurs, all contaminated material is safely removed, and independent environmental reviews are completed. Kurnell deserves better than a short-term, cost-cutting solution disguised as remediation.

There is a lack of a full clean up effort, this close to a family community and national park it is unacceptable . We expect that a company with the profits and reputation of Ampol should do right by the lands they occupy

My name is Yvonne Banks and I have lived in Kurnell for 58 years. Even before moving here, I visited regularly to see my grandmother, who also called this special place home. Kurnell has always held a deep place in my heart. I have watched it change over many decades, and I had hoped that when the refinery closed, the village and local environment would begin to recover. I believed that the pollution, noise and industrial dominance would finally come to an end.

Instead, MOD 7 feels like another betrayal. I strongly oppose this modification. Ampol has used and leased this land for more than 70 years. They have profited from it, and they now have a responsibility to clean it up properly. Covering the contamination is not good enough. It leaves the problem behind for our children and grandchildren to deal with. That is not a legacy I want to leave.

I am also disappointed in how the community has been treated. There has been no proper engagement or clear information from Ampol. Many of us believed a full cleanup was planned. We were not told the truth. The State Government should be holding Ampol accountable for this deception.

I have watched my children grow up enjoying this neighbourhood. I want the same for my grandchildren. I do not want to leave them a toxic, dangerous piece of land. I want to leave them a clean, safe, and healthy environment to enjoy for generations.

To:  NSW Department of Planning, Housing & Infrastructure – Independent Planning Commission

Re: SSD‑5544‑Mod 7 – Infrastructure Consolidation & Remediation at Kurnell Terminal

I write to object to the proposed MOD 7 changes for the Kurnell Terminal (SSD‑5544‑Mod 7), currently on public exhibition until 25 July 2025. Please see my points noted below:

1. Insufficient Public Exhibition & Community Consultation

The 15-day exhibition period (10–25 July) is grossly inadequate for such a technical and environmentally significant proposal. Local residents report limited access to detailed technical materials (e.g., Technical Report - Soils, Groundwater & Contamination). There has been no clear summary or briefing to the broader Sutherland community or their elected councillors, undermining democratic participation.

2. Environmental & Human Health Risks from Capping Rather Than Removing Contamination

MOD 7 proposes to leave existing petroleum hydrocarbons, PFAS, and asbestos in situ—capping contaminated land instead of removing it. This permanent retention poses ongoing risks to groundwater and adjacent sensitive ecosystems. The proposal also involves re-routing ~22% of the site’s stormwater via open channels into Quibray Bay, a RAMSAR-listed wetland - clearly increasing contamination potential.

3. Recent Spill History Illustrates Risk

In 2022, an Ampol diesel spill entered Marton Park Wetlands and Quibray Bay, causing significant mangrove dieback. Rather than addressing this through full remediation, MOD 7 embeds unchanged pollutant pathways and increased stormwater discharge - heightening the risk of repeated ecological damage.

4. Lack of Independent Risk Assessment

Despite disturbing technical content (e.g., the soil and groundwater report), the proposal lacks independent verification. MOD 7 relies on Ampol’s own remediation strategies, without guarantees of oversight by third-party auditors or public release of validation reports.

I respectfully urge the IPC to:

Reject MOD 7, and require a minimum 60‑day exhibition with simplified public summaries;

Commission independent environmental and hydrological risk assessments before any decision;

Demand full remediation - not just capping - of contaminated soils and groundwater;

Require stormwater modelling and independent approvals prior to altering discharge patterns near sensitive wetlands.

Kurnell’s fragile environment, community safety, and the integrity of its wetlands must not be compromised for partial or cost-cutting remediation. Approval of MOD 7 in its current form would lock in contamination pathways and weaken protections for generations to come.

Thank you for your serious consideration of these arguments.

I am submitting this objection to express my strong opposition to Modification 7 at the Kurnell site. The plan to cap, rather than fully remediate, the contaminated land is unacceptable and presents a serious threat to public health, the environment, and the future of our local community.

Hazardous substances such as PFAS, hydrocarbons, and asbestos remain present on-site. Encasing these contaminants instead of removing them is a dangerous shortcut—particularly in a low-lying area prone to flooding. Any significant rainfall could result in these toxic materials being flushed into nearby waterways, including Botany Bay and the surrounding wetlands. This is not a hypothetical risk. In April 2022, a major spill of hydrocarbons occurred during a rain event due to Ampol’s failure to contain pollutants adequately.

The community was originally assured that the land would be remediated and returned as parkland or public open space. Now, that promise is being disregarded in favour of rezoning the land for permanent industrial use—prioritising cost-saving for a major corporation over the wellbeing of residents and the natural environment. This is an unacceptable breach of trust and environmental accountability.

Kurnell is home to some of NSW’s most ecologically significant areas, such as Towra Point Nature Reserve and Quibray Bay—both vital for migratory birds and mangrove habitats. Increasing industrial activity near these areas risks irreversible ecological damage.

Increased noise, pollution, and reduced green space will diminish the quality of life for locals, reduce biodiversity, and damage local tourism and future sustainable development potential. The health and safety of residents must come before corporate profit.

I strongly urge the NSW Government to reject Modification 7. The land must be properly remediated as originally intended—not left contaminated and repurposed for industrial expansion. Our community, environment, and future deserve better.

As a concerned resident of Kurnell, I strongly oppose the approval of Modification 7. This proposal poses significant risks to both public health and the surrounding environment.

The site contains hazardous contaminants such as PFAS, hydrocarbons, and asbestos. Leaving these substances in place, capped rather than removed, is both irresponsible and dangerous. During periods of heavy rainfall and flooding, these toxins could spread into Botany Bay, local wetlands, and the areas we use for swimming, fishing, and walking. This has already happened before—on April 7, 2022, a large amount of hydrocarbons spilled into the community due to inadequate containment by Ampol during a rain event. Of an evening we still have an over powering toxic smell coming from the mangroves due to the damage caused to the form the oil spill.

Originally, Ampol committed to properly remediating the land and transforming it into open parkland or green space for community use. Instead, they now propose to permanently zone it for industrial use while simply capping the contamination. This is a clear case of corporate greed taking priority over public safety and environmental responsibility.

The implications of this proposal go beyond health and safety. It threatens local wildlife, tourism, the economy, and the potential for sustainable development. More industry means more noise, pollution, and a further loss of green space that supports local ecosystems.

Kurnell is home to fragile natural environments, including Towra Point Nature Reserve and Quibray Bay—both of which are vital habitats for migratory birds and mangroves. These areas must be protected from further industrial intrusion and environmental harm.

Given Ampol’s past failures and the risks involved, the NSW Government must reject this proposal. It is vital to prioritise the health of our community and the preservation of our unique natural environment.

I don’t believe this mess needs to be just covered up. Where is it going to go? Deep into the soil and create toxic waste forever. This needs to be done properly and removed before being sealed up and covered. I have children in the area and plan to grow old here. Kurnell is full of young families and many children. Toxic waste is not something you keep all snug and covered up fermenting and potentially leaching through lands and waterways in a suburban area with lots of young families.

Dear Secretary,
I write to objection to MOD 7 for infrastructure consolidation, removal of redundant assets, and remediation at the Ampol Kurnell Terminal (exhibited 10–25 July 2025).
1. Environmental & Water Quality Threat
The April 2022 spill of over 9,000 L of oily water demonstrated how disturbing contaminated land can re mobilise pollutants, threatening waterways, ecosystems, and the community.
2. Monitoring & Transparency Deficit
The MOD 7 proposal lacks detailed commitments to continuous environmental monitoring, independent audits, trigger level reporting, and accessible public disclosure—undermining accountability.
3. Insufficient Community Engagement
No specific consultation is evident for MOD 7—no community briefings or interactive Q&A occur prior to decisions, leaving local voices unheard.
4. High Risk of Industrial Repurposing (e.g., BESS)
Ampol is currently investigating an 800 MW Battery Energy Storage System (BESS) for the Kurnell site
While BESS offers renewable energy benefits, large-scale lithium-ion installations carry serious hazards:
• Thermal runaway, fire & explosion: lithium-ion BESS may undergo uncontrolled thermal events. Industrial fires in Moss Landing (CA), Victorian Big Battery, Otay Mesa, Bouldercombe, and Ulster demonstrate the real-world risks, including toxic plume release and prolonged blazes
• Air and water contamination: fires release hazardous gases (e.g. hydrogen fluoride), and post-fire soils can show heavy metals hundreds to thousands of times above background
• Community safety: installing BESS near residential, ecological, or fuel infrastructure heightens the potential for catastrophic incidents in an already sensitive zone
Unless MOD 7 explicitly prohibits industrial re purposing—including BESS—this remediation phase may simply enable higher risk developments without proper environmental or safety scrutiny.

Dear Secretary,
I write to objection to MOD 7 for infrastructure consolidation, removal of redundant assets, and remediation at the Ampol Kurnell Terminal (exhibited 10–25 July 2025).
1. Environmental & Water Quality Threat
The April 2022 spill of over 9,000 L of oily water demonstrated how disturbing contaminated land can re mobilise pollutants, threatening waterways, ecosystems, and the community.
2. Monitoring & Transparency Deficit
The MOD 7 proposal lacks detailed commitments to continuous environmental monitoring, independent audits, trigger level reporting, and accessible public disclosure—undermining accountability.
3. Insufficient Community Engagement
No specific consultation is evident for MOD 7—no community briefings or interactive Q&A occur prior to decisions, leaving local voices unheard.
4. High Risk of Industrial Repurposing (e.g., BESS)
Ampol is currently investigating an 800 MW Battery Energy Storage System (BESS) for the Kurnell site
While BESS offers renewable energy benefits, large-scale lithium-ion installations carry serious hazards:
• Thermal runaway, fire & explosion: lithium-ion BESS may undergo uncontrolled thermal events. Industrial fires in Moss Landing (CA), Victorian Big Battery, Otay Mesa, Bouldercombe, and Ulster demonstrate the real-world risks, including toxic plume release and prolonged blazes
• Air and water contamination: fires release hazardous gases (e.g. hydrogen fluoride), and post-fire soils can show heavy metals hundreds to thousands of times above background
• Community safety: installing BESS near residential, ecological, or fuel infrastructure heightens the potential for catastrophic incidents in an already sensitive zone
Unless MOD 7 explicitly prohibits industrial re purposing—including BESS—this remediation phase may simply enable higher risk developments without proper environmental or safety scrutiny.