Molong Battery Energy Storage System

This development relies on probabilistic risk modelling rather than consequence based assessment. Battery fires are described as unlikely, yet the consequences of even a single failure include toxic smoke, contaminated runoff and long term chemical residues. Planning decisions should not hinge on frequency alone when the magnitude of harm is irreversible.
Battery fire events in Victoria and the United States demonstrate that design compliance does not eliminate catastrophic outcomes. Fire retardants containing PFAS are routinely deployed, creating secondary contamination that persists long after the incident. End of life dismantling presents similar high consequence risks that are not mitigated by likelihood modelling. How can a planning authority justify approval when worst case outcomes guarantee irreversible environmental harm?

This obnoxious battery hazard planned for the unaware Molong people - who have never been properly informed about it - represents a reckless gamble with public safety, knowingly introducing an industrial hazard capable of releasing lethal gases into a rural community that has no capacity to evacuate, shelter, or medically respond to a toxic plume event.
Who will be culpable and held accountable when Molong people die from the lethal hydrofluorine gas fumes - that are poisonous to our lungs - when there’s an inevitable, life-threatening fire burning for days that can’t be extinguished.
Where’s the Exclusion Zone, the Evacuation Plan, the HAZMAT Team?

I am just wondering, how much of this productive farming area and rural communities will be vandalised by the the overseas companies and with permission from the Australian government. Molong 150MW/730MWh (264 batteries and 50 inverters ) Plus new overhead transmission lines approximately 900m and new access road. This garbage has not been fully tested anywhere in the world, however agriculture is a tried and tested reliable food source. Australian farmers are renowned for being some of the best food produces in the world as well as the best land managers on the planet. TRIED AND TRUE METHODS OF BEST FARMING PRACTICE. And our government is on a viscous course to destroy them by stripping farmers of their land, destroying the natural environment with the portential of major land contamination for possibly centuries. Who will clean up the contaminated soils? With Australia's ridiculous rate of immigration, farming land being under threat,( we won't have the productive land to feed the population, let alone export our products overseas.) communities being put at risk from BESS battery fires and pollution.
I could give you a run down of all the polluting chemicals in these BESS batteries, solar panels and wind turbine and the destruction caused and will cause but you should have done your research by now, and be fully aware of the risks.
I suppose when food gets tight , you will turn around and say " I DIDN'T KNOW THAT WOULD HAPPEN" WHEN YOU HAVE BEEN TOLD FOR YEARS THAT IT WOULD. IGNORANCE IS NO LONGER AN acceptable EXCUSE.
Regards Annette Wheaton

The proposal relies heavily on future regulation and technological advancement to resolve present risks. This defers responsibility rather than addressing it. PFAS contamination and battery fire behaviour are current and well documented issues. Planning approval should not be contingent on hypothetical future solutions to known problems. Who guarantees that regulations and technology will be adequate decades from now?

This development creates a long term monitoring burden without a clear custodian. Contamination monitoring may be required for decades after closure. If the proponent ceases to exist, responsibility for monitoring and response becomes unclear. Approval should not create open ended public liability. Who ensures monitoring is maintained for decades when the responsible entity disappears?

The proposal treats community impact as secondary to grid benefit. Local land, water and safety risks are borne by the host community while benefits are distributed elsewhere.
Such imbalance requires a higher threshold of environmental certainty than is demonstrated.
How is justice served when the risk falls locally but benefits are dispersed?

Fire risk is assessed as an operational matter rather than a development impact. This distinction is artificial. The foreseeable need to deploy chemical suppressants is an inherent consequence of the development itself. Environmental contamination resulting from fire response is therefore a direct planning impact that cannot be deferred to operational management plans. How can a development avoid assessment for risks it is guaranteed to produce?

The assessment fails to apply the precautionary principle appropriately. Where scientific uncertainty exists around irreversible harm, caution should prevail. PFAS contamination and battery fire behaviour present precisely such uncertainty. Approval proceeds despite the absence of proven containment or remediation methods. How is caution reconciled with approval when outcomes cannot be reversed?

The proposal inadequately considers heat stress as a compounding risk factor. High ambient temperatures increase battery degradation, fire likelihood and emergency response difficulty.
Regional heat events have already exposed weaknesses in energy infrastructure. Planning must account for escalating climate conditions rather than historical averages.
How can approval be justified when climate extremes may worsen predictable risks?

How can regulators approve irreversible harm without a mechanism to reverse it?
The absence of a consent reversal pathway is concerning. Once contamination occurs, approval conditions cannot undo harm. Planning systems are poorly equipped to manage irreversible outcomes, yet this proposal proceeds without addressing that limitation.

This development relies on insurance and warranties as risk controls. These instruments do not remediate land or remove contamination. Financial mechanisms expire or are contested, leaving physical harm unresolved. Who compensates for permanent contamination if insurance or warranties fail?

How can human safety be guaranteed when emergency response itself produces toxic exposure?
The assessment underestimates firefighter exposure risks. Battery fires generate toxic smoke and chemical residues that affect responders directly. PFAS exposure during fire fighting is a documented occupational hazard that has not been adequately considered.

he proposal assumes that contaminated land can be restored to baseline condition. PFAS science indicates this is unrealistic. Approval therefore implies acceptance of permanent environmental degradation.
How can approval proceed when the intended remediation is scientifically impossible?

The project creates long term land use conflict. Industrial contamination risk is incompatible with surrounding rural and residential uses. Once established, this conflict cannot be resolved through mitigation alone.
Who resolves land use conflicts that persist indefinitely after the development ends?

The assessment relies on modelling that excludes human error, maintenance lapses and organisational change. International battery incidents show these factors are often decisive in failure events. How can risk be properly assessed when human and organisational factors are inherently unpredictable?

How can regulators assess cumulative risks that only manifest decades later?
The proposal does not adequately consider cumulative exposure. Even low level releases over time can result in significant PFAS accumulation. Gradual contamination is harder to detect and regulate yet equally damaging.

The assessment assumes compliance equates to safety. International evidence contradicts this assumption. Battery facilities have failed while fully compliant with approvals and standards.
Who ensures that compliance actually prevents catastrophic outcomes?

How can a local planning decision resolve hazards that remain unresolved worldwide?
Approval is sought despite unresolved global challenges in battery waste, fire control and PFAS remediation. These are not local anomalies but systemic issues. Proceeding in the absence of solutions effectively transfers unresolved problems to the host community.

Who takes responsibility for impacts that cannot be confined to the approved site?
This proposal externalises environmental risk beyond the operational site. Smoke, runoff and groundwater migration affect areas not subject to consent conditions. Planning controls therefore fail to match impact pathways.

End of life dismantling is treated as a technical exercise rather than a development impact. Handling degraded batteries presents significant fire and contamination risk. This phase should be assessed with the same rigour as construction and operations.
How can approval ignore the dangers inherent in dismantling the batteries decades later?