State Significant Development
Response to Submissions
Richmond Valley Solar Farm
Richmond Valley
Current Status: Response to Submissions
Interact with the stages for their names
- SEARs
- Prepare EIS
- Exhibition
- Collate Submissions
- Response to Submissions
- Assessment
- Recommendation
- Determination
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Development of a 500 MW solar farm and associated infrastructure.
EPBC
This project is a controlled action under the Environment Protection and Biodiversity Conservation Act 1999 and will be assessed under the bilateral agreement between the NSW and Commonwealth Governments, or an accredited assessment process. For more information, refer to the Australian Government's website.
Attachments & Resources
Notice of Exhibition (1)
Request for SEARs (2)
SEARs (12)
EIS (23)
Response to Submissions (1)
Agency Advice (11)
Submissions
Showing 1 - 20 of 49 submissions
Name Withheld
Object
Name Withheld
Object
Hay
,
New South Wales
Message
Richmond Valley Solar & BESS is a dreadful plan - designed to create toxic fires, deprive Australian people of power, cost us a motzer & never be cleaned up.
Name Withheld
Object
Name Withheld
Object
Redbank Plains
,
Queensland
Message
I Object to Richmond Valley Electricity Generating Works & BESS as I am extremely concerned for the great loss of farming land and land for animal life!
When we lose endangered animals they are gone!
I also feel farmers are not protected from malpractice when they lease their land to big companies.
My information tells me that their contracts do not protect farmers from having to dispose later of any waste.
The Government must responsibly ensure that overseas investors do not contribute to the waste challenges we already have, but as it stands this has not been adequately put in place at all.
I am very unhappy that there is no opportunity for open debate on this venture that will change the life of all Australians.
The fact is that Solar & Wind ‘farms’ will not bring enough energy to supply ordinary Australians. They have not been proven to deliver continuous supply - 30% average efficiency for Wind & less for Solar is not good enough!
The fact is energy costs will rise for ordinary, already struggling householders.
The spin is: ‘ It looks good’.... NO!!!! NOT TRUE!!!
‘The panels are clean & safe’….. UNTRUE!!!
‘Farmers are in for a good deal’ ….. NOT AT ALL!!!
When we lose endangered animals they are gone!
I also feel farmers are not protected from malpractice when they lease their land to big companies.
My information tells me that their contracts do not protect farmers from having to dispose later of any waste.
The Government must responsibly ensure that overseas investors do not contribute to the waste challenges we already have, but as it stands this has not been adequately put in place at all.
I am very unhappy that there is no opportunity for open debate on this venture that will change the life of all Australians.
The fact is that Solar & Wind ‘farms’ will not bring enough energy to supply ordinary Australians. They have not been proven to deliver continuous supply - 30% average efficiency for Wind & less for Solar is not good enough!
The fact is energy costs will rise for ordinary, already struggling householders.
The spin is: ‘ It looks good’.... NO!!!! NOT TRUE!!!
‘The panels are clean & safe’….. UNTRUE!!!
‘Farmers are in for a good deal’ ….. NOT AT ALL!!!
Save Our Surroundings Riverina
Object
Save Our Surroundings Riverina
Object
Lake Albert
,
New South Wales
Message
Richmond Valley Solar Electricity Generating Works + BESS is a totally objectional, parasitic, Environmentally Destructive, life threatening Fire Risk that is useless, weather dependent & a toxic contamination disaster - against the best interests of Australia.
Name Withheld
Object
Name Withheld
Object
KOORINGAL
,
New South Wales
Message
Ugly Industrialised Solar Electricity Generating Works & Battery Energy Storage hazards will NEVER provide reliable, affordable Australian power which is an essential service for the people of NSW.
Depending on the weather means they are flaky, a very silly idea & DON’T WORK most of the time.
This toxic contaminating plan DOES NOT belong on essential, irreplaceable Food growing land at all as irreversible environmental harm will inevitably occur & our children’s Energy Security & Food Security future will be ruined forever
Depending on the weather means they are flaky, a very silly idea & DON’T WORK most of the time.
This toxic contaminating plan DOES NOT belong on essential, irreplaceable Food growing land at all as irreversible environmental harm will inevitably occur & our children’s Energy Security & Food Security future will be ruined forever
Tony Gill
Object
Tony Gill
Object
ELLANGOWAN
,
New South Wales
Message
I object to this Solor Farm project arc, energy say we are Little to no impact and low visual impact which is bullshit. I am a neighbouring property owner A solor Farm of this size will have a massive impact on Our community, the massive battery storage and amount of panels I believe would be harmful for us locals if damaged, or catch on fire. Solor Farms should never be built near properties where people live
Name Withheld
Object
Name Withheld
Object
MAROUBRA
,
New South Wales
Message
I object to this renewable energy project on environmental grounds. We have climate and biodiversity crises and this project ticks the boxes in terms of adding to these due to removal of native vegetation and trees. The site is also a known bush fire prone area yet we are proposing a substation and transmission lines?
How is clearing of 140 hectares of native vegetation acceptable? The proponent's solution is to plant a 30 metre biodiversity corridor? How does that replace the amount of cleared vegetation or replace hollow bearing trees that will be bulldozed?
The public are beginning to get a clear picture now that green energy industrialisation is environmentally destructive. This project impacts two threatened ecological communities and twelve threatened fauna species. It has clear serious and irreversible impacts on native species. At what point to we draw a line in the sand regarding impacts to other species from human impacts and realise the damage we are doing is irreversible? This is why Australia leads the world in extinctions.
Koalas are known to have habitat within the subject area but surveys failed to locate any. Convenient? Koalas are a landscape species. Why are any trees being used by koalas, even occasionally, being removed? This project is not environmentally suitable.
How is clearing of 140 hectares of native vegetation acceptable? The proponent's solution is to plant a 30 metre biodiversity corridor? How does that replace the amount of cleared vegetation or replace hollow bearing trees that will be bulldozed?
The public are beginning to get a clear picture now that green energy industrialisation is environmentally destructive. This project impacts two threatened ecological communities and twelve threatened fauna species. It has clear serious and irreversible impacts on native species. At what point to we draw a line in the sand regarding impacts to other species from human impacts and realise the damage we are doing is irreversible? This is why Australia leads the world in extinctions.
Koalas are known to have habitat within the subject area but surveys failed to locate any. Convenient? Koalas are a landscape species. Why are any trees being used by koalas, even occasionally, being removed? This project is not environmentally suitable.
Name Withheld
Object
Name Withheld
Object
Kepnock
,
Queensland
Message
Richmond Valley Solar + BESS has no social licence as it is a horribly dangerous, extremely toxic & totally useless plan that is a complete waste of public money as it will never provide secure, reliable, affordable power.
Name Withheld
Object
Name Withheld
Object
Harefield
,
New South Wales
Message
Richmond Valley Solar & BESS is a despicable, diabolical plan designed to rip-off the Australian public with CONtrolling Energy Poverty & a massive Land Grab designed to reduce our limited, irreplaceable FOOD growing land - entombing it in Toxic PV forever - contaminating our healthy soil & water - wrecking our children’s future & making Australia weak - beholden to the CCP - our most hostile enemy!
Name Withheld
Object
Name Withheld
Object
Springfield
,
Queensland
Message
I OBJECT to this horrible plan for Richmond Solar Electricity Generating Works + BESS as it is extremely environmentally destructive, will only work part-time & will soon create a massive pile of toxic waste that is already ruining Australia.
Name Withheld
Object
Name Withheld
Object
Springfield
,
New South Wales
Message
Richmond Valley Solar + BESS is part of the most obscene, non-sensical, ruinable plans for Australia, destroying our precious biodiversity & ecology, contaminating our essential Agricultural land & water supplies & seriously harming Australian people & our children’s future forever with toxic junk & energy deprivation.
Save Our Surroundings Murrumbidgee
Object
Save Our Surroundings Murrumbidgee
Object
Griffith
,
New South Wales
Message
Richmond Valley Industrialised Solar Electricity Generating Works + incapable Battery Energy Storage System is an extremely destructive, disingenuous plan with a contaminating lifecycle that is not one bit clean, green or sustainable.
Being weather dependent is useless, only ensuring it will never provide reliable, cheap power on demand.
Australians need far superior 24/7 Australian power with a minimal environmental footprint.
Being weather dependent is useless, only ensuring it will never provide reliable, cheap power on demand.
Australians need far superior 24/7 Australian power with a minimal environmental footprint.
Name Withheld
Object
Name Withheld
Object
GRIFFITH
,
New South Wales
Message
My main objections to this massive development are as follows.
1. The Paris Agreement states that Agricultural Land is to be protected from the type of developments proposed. That is utilising grazing but more importantly arable land to establish Industrial Complexes.
Only 4 per cent to 6 per cent of Australia's land mass is arable.
2. Much of the development money is from a Chinese Company connected to The Chinese Communist Party and therefore The Chinese Governnment. Australia has already witnessed how China treats other nations who question their policies. To have The P. R. C. Construct power systems for Australia seems ludicrous. Particularly as these systems do not provide reliable power and at the same time make China stronger and weaken Australia.
3. The hoped for introduction of AUKUS must surely point out the need for a Nuclear Power Industry particularly for South Australia.
4. When both the Federal and State Governments wake up to the fact that we are living in The Nuclear Age one would hope that the unbridled spread of these unreliable tax payer subsidised operations providing unreliable power would be limited.
5. What agency when common sense prevails is going to remove these installations that are a blight on our wonderful Australian landscape and are making a few wealthy and the majority of Australians poorer in a number of ways.
1. The Paris Agreement states that Agricultural Land is to be protected from the type of developments proposed. That is utilising grazing but more importantly arable land to establish Industrial Complexes.
Only 4 per cent to 6 per cent of Australia's land mass is arable.
2. Much of the development money is from a Chinese Company connected to The Chinese Communist Party and therefore The Chinese Governnment. Australia has already witnessed how China treats other nations who question their policies. To have The P. R. C. Construct power systems for Australia seems ludicrous. Particularly as these systems do not provide reliable power and at the same time make China stronger and weaken Australia.
3. The hoped for introduction of AUKUS must surely point out the need for a Nuclear Power Industry particularly for South Australia.
4. When both the Federal and State Governments wake up to the fact that we are living in The Nuclear Age one would hope that the unbridled spread of these unreliable tax payer subsidised operations providing unreliable power would be limited.
5. What agency when common sense prevails is going to remove these installations that are a blight on our wonderful Australian landscape and are making a few wealthy and the majority of Australians poorer in a number of ways.
Name Withheld
Object
Name Withheld
Object
SPRING GROVE
,
New South Wales
Message
Placing solar panels on farming land that can be used to grow food is not the answer to the so-called energy crisis.
The location is in a bushfire zone which further threatens my family.
Not enough is known about the long term health effects of large scale solar farms. Or environmental effects.
I object to this solar farm being located in the Richmond Valley, and propose it be built further west, even as far as the desert.
The location is in a bushfire zone which further threatens my family.
Not enough is known about the long term health effects of large scale solar farms. Or environmental effects.
I object to this solar farm being located in the Richmond Valley, and propose it be built further west, even as far as the desert.
Name Withheld
Object
Name Withheld
Object
LAKE ALBERT
,
New South Wales
Message
I DO NOT CONSENT to our Public Funds being unconscionably wasted so irresponsibly by stupid bureaucrats, socialist zealots & greedy Vested Interests on such Filthy, Toxic, Pathetic, Fake Green, Incapable, Weather Dependent, Intermittent RenewaBULL JUNK like this illogical, FIRE HAZARDOUS, Toxic Contaminating & useless, CCP reliant, slave labour based Richmond Solar + BESS.
AUSTRALIA’S ENERGY SECURITY - FOOD SECURITY - ECONOMIC PROSPERITY - NATIONAL SECURITY NECESSITATES INDEPENDENT, RELIABLE, AFFORDABLE, EFFICIENT, PLENTIFUL, SECURE, 24/7 AUSTRALIAN COAL, GAS & A CLEAN, SAFE NUCLEAR POWER FUTURE WITH MINIMAL ENVIRONMENTAL FOOTPRINT - NO INTERCONNECTOR NIGHTMARE NEEDED!!
AUSTRALIA’S ENERGY SECURITY - FOOD SECURITY - ECONOMIC PROSPERITY - NATIONAL SECURITY NECESSITATES INDEPENDENT, RELIABLE, AFFORDABLE, EFFICIENT, PLENTIFUL, SECURE, 24/7 AUSTRALIAN COAL, GAS & A CLEAN, SAFE NUCLEAR POWER FUTURE WITH MINIMAL ENVIRONMENTAL FOOTPRINT - NO INTERCONNECTOR NIGHTMARE NEEDED!!
David MacDonald
Object
David MacDonald
Object
Queenscliff
,
New South Wales
Message
Richmond Solar - 880ha of forests totally cleared. Including a threatened ecological community. Ecological consultancy Biosis incorrectly claimed no koalas & greater gliders & yellow-bellied gliders on site. Reality: there are over 60 threatened species potentially on site.
This is completely and utterly unacceptable.
This is completely and utterly unacceptable.
Maria Bradley
Object
Maria Bradley
Object
COOGEE
,
New South Wales
Message
e - Richmond Solar - 880ha of forests totally cleared. Including a threatened ecological community. Ecological consultancy Biosis claimed no koalas & greater gliders & yellow-bellied gliders on site. Over 60 threatened species potentially on site
Name Withheld
Object
Name Withheld
Object
Mareeba
,
Queensland
Message
Richmond Valley Solar Farm needs to be a CONTROLLED ACTION under the EPBC Act, as the impacts listed below are extremely significant and completely unacceptable. Surveys are incomplete, as admitted by the consultancy company, going by their document from 2023: "Richmond Valley Solar Farm MNES Assessment Project no. 38804".
Direct impacts will include very significant areas removal of native vegetation - ecosystems (possibly 880 hectares of deforestation), removal of threatened species and their habitat and fauna mortality. Indirect impacts will include reduced viability of adjacent habitat due to edge effects, reduced viability of adjacent habitat due to noise, dust, or light spill, and microclimate warming and drying effects, transport of weeds and pathogens from the site to adjacent vegetation and changed fire regimes.
A constraints and opportunities assessment prepared for the project by Biosis identified 17 MNES
entities that have a moderate – high likelihood of occurrence within the project area and may therefore be
impacted by the project. This includes 15 threatened flora and fauna species, and two
threatened ecological communities.
SIC assessments concluded significant impacts have the potential to occur to three
threatened entities. This is predominantly based on the uncertainty of impacts resulting from potential
impacts to habitat present, previous bushfire impacts in the last 5 years, a worse case preliminary design and
incomplete seasonal surveys undertaken to date. The three threatened entities found on the site by incomplete and brief surveys are;
• Slaty Red Gum Eucalyptus glaucina (Vulnerable).
• Rupp’s Watte Acacia ruppii (Endangered)
• Koala Phascolarctos cinereus (Endangered)
In total there are 8 plant species which are vulnerable or endangered which are thought to have a high likelihood of being present on the site, and 12 vulnerable/endangered plant species which are thought to have a medium likelihood of being present.
The project will result in the destruction of 18 hectares of subtropical eucalypt floodplain forest and woodland, which is an endangered ecological community.
It will also impact over 100 hectares of coastal swamp eucalypt forest. Whilst apparently none of this habitat will be cleared, the fact that this development which demands wholesale clearing of all vegetation will directly impact upon the integrity of this ecosystem via local changes to hydrology, drainage, microclimate changes with warming and drying of surrounded areas, and presence of pollutant & toxic chemicals from the solar farm.
There are 27 vulnerable/endangered fauna species which are thought to have a high likelihood of being found on the site and 36 vulnerable/endangered fauna species which are thought to have a medium likelihood of being found on the site.
The southern greater glider and yellow-bellied glider was found in very close proximity to the project/deforestation area and it is likely that greater gliders and yellow-bellied gliders utilise the habitat to be destroyed - this will definitely impact the local population, causing fragmentation and reduced viability of the populations and contribute to local extinctions, culminating in full extinction.
The ecologists admit that 63 hectares of foraging habitat for grey-headed flying foxes will be destroyed, but allege that this is insignificant, as does every proponent of every development which destroys habitat . The cumulative impacts of such developments which whittle away and fragment all remaining habitats are of course never mentioned. This is yet another shortcoming of the report and reveal yet again that the ecological survey company writing the report is not objective.
We find it rather strange that "targeted surveys" have not found individuals of any threatened species in the project area, and we can only conclude that the surveys were too brief, not comprehensive enough, and not repeated during other seasons. Maybe it is possible that the surveys are not fully independent, as the ecological survey company is employed by and answers to the proponent, Ark Energy. The ecological surveyors should be fully independent and citizen scientists should be allowed on the site.
Even if hypothetically there are no threatened species existing on the site, this project will still be environmentally catastrophic as it removes carbon-sequestering and climate-regulating ecosystems, and destroys and future possibility of regeneration and restoration of the ecosystems in both the directly cleared area and surrounding areas. If this project goes ahead, it will be transformed into an ecologically catastrophic desert, which retains heat and contributes to direct warming and drying of the earth's surface. In addition, the presence of the solar farm will demand that all vegetation including grasses be destroyed with herbicides, and the soil will likely wash away with high rainfall events. This also will negate any chance of regeneration of ecosystems for many hundreds if not thousands of years, and cause added siltation and damage to surrounding areas and ecosystems. This project is catastrophic for both biodiversity and the biosphere - and therefore the climate.
In addition, proposed transmission line impacts are yet to be determined and ongoing fauna mortalities throughout the operation of the Solar Farm do not appear to have been taken into consideration.
We conclude that this project should be a controlled action under the EPBC Act and needs to be rejected due to adverse effects on biodiversity, the biosphere, and climate.
Direct impacts will include very significant areas removal of native vegetation - ecosystems (possibly 880 hectares of deforestation), removal of threatened species and their habitat and fauna mortality. Indirect impacts will include reduced viability of adjacent habitat due to edge effects, reduced viability of adjacent habitat due to noise, dust, or light spill, and microclimate warming and drying effects, transport of weeds and pathogens from the site to adjacent vegetation and changed fire regimes.
A constraints and opportunities assessment prepared for the project by Biosis identified 17 MNES
entities that have a moderate – high likelihood of occurrence within the project area and may therefore be
impacted by the project. This includes 15 threatened flora and fauna species, and two
threatened ecological communities.
SIC assessments concluded significant impacts have the potential to occur to three
threatened entities. This is predominantly based on the uncertainty of impacts resulting from potential
impacts to habitat present, previous bushfire impacts in the last 5 years, a worse case preliminary design and
incomplete seasonal surveys undertaken to date. The three threatened entities found on the site by incomplete and brief surveys are;
• Slaty Red Gum Eucalyptus glaucina (Vulnerable).
• Rupp’s Watte Acacia ruppii (Endangered)
• Koala Phascolarctos cinereus (Endangered)
In total there are 8 plant species which are vulnerable or endangered which are thought to have a high likelihood of being present on the site, and 12 vulnerable/endangered plant species which are thought to have a medium likelihood of being present.
The project will result in the destruction of 18 hectares of subtropical eucalypt floodplain forest and woodland, which is an endangered ecological community.
It will also impact over 100 hectares of coastal swamp eucalypt forest. Whilst apparently none of this habitat will be cleared, the fact that this development which demands wholesale clearing of all vegetation will directly impact upon the integrity of this ecosystem via local changes to hydrology, drainage, microclimate changes with warming and drying of surrounded areas, and presence of pollutant & toxic chemicals from the solar farm.
There are 27 vulnerable/endangered fauna species which are thought to have a high likelihood of being found on the site and 36 vulnerable/endangered fauna species which are thought to have a medium likelihood of being found on the site.
The southern greater glider and yellow-bellied glider was found in very close proximity to the project/deforestation area and it is likely that greater gliders and yellow-bellied gliders utilise the habitat to be destroyed - this will definitely impact the local population, causing fragmentation and reduced viability of the populations and contribute to local extinctions, culminating in full extinction.
The ecologists admit that 63 hectares of foraging habitat for grey-headed flying foxes will be destroyed, but allege that this is insignificant, as does every proponent of every development which destroys habitat . The cumulative impacts of such developments which whittle away and fragment all remaining habitats are of course never mentioned. This is yet another shortcoming of the report and reveal yet again that the ecological survey company writing the report is not objective.
We find it rather strange that "targeted surveys" have not found individuals of any threatened species in the project area, and we can only conclude that the surveys were too brief, not comprehensive enough, and not repeated during other seasons. Maybe it is possible that the surveys are not fully independent, as the ecological survey company is employed by and answers to the proponent, Ark Energy. The ecological surveyors should be fully independent and citizen scientists should be allowed on the site.
Even if hypothetically there are no threatened species existing on the site, this project will still be environmentally catastrophic as it removes carbon-sequestering and climate-regulating ecosystems, and destroys and future possibility of regeneration and restoration of the ecosystems in both the directly cleared area and surrounding areas. If this project goes ahead, it will be transformed into an ecologically catastrophic desert, which retains heat and contributes to direct warming and drying of the earth's surface. In addition, the presence of the solar farm will demand that all vegetation including grasses be destroyed with herbicides, and the soil will likely wash away with high rainfall events. This also will negate any chance of regeneration of ecosystems for many hundreds if not thousands of years, and cause added siltation and damage to surrounding areas and ecosystems. This project is catastrophic for both biodiversity and the biosphere - and therefore the climate.
In addition, proposed transmission line impacts are yet to be determined and ongoing fauna mortalities throughout the operation of the Solar Farm do not appear to have been taken into consideration.
We conclude that this project should be a controlled action under the EPBC Act and needs to be rejected due to adverse effects on biodiversity, the biosphere, and climate.
Fleur van Eenennaam
Object
Fleur van Eenennaam
Object
Mareeba
,
Queensland
Message
Richmond Valley Solar Farm needs to be a CONTROLLED ACTION under the EPBC Act, as the impacts listed below are extremely significant and completely unacceptable. Surveys are incomplete, as admitted by the consultancy company, going by their document from 2023: "Richmond Valley Solar Farm MNES Assessment Project no. 38804".
Direct impacts will include very significant areas removal of native vegetation - ecosystems (possibly 880 hectares of deforestation), removal of threatened species and their habitat and fauna mortality. Indirect impacts will include reduced viability of adjacent habitat due to edge effects, reduced viability of adjacent habitat due to noise, dust, or light spill, and microclimate warming and drying effects, transport of weeds and pathogens from the site to adjacent vegetation and changed fire regimes.
A constraints and opportunities assessment prepared for the project by Biosis identified 17 MNES
entities that have a moderate – high likelihood of occurrence within the project area and may therefore be
impacted by the project. This includes 15 threatened flora and fauna species, and two
threatened ecological communities.
SIC assessments concluded significant impacts have the potential to occur to three
threatened entities. This is predominantly based on the uncertainty of impacts resulting from potential
impacts to habitat present, previous bushfire impacts in the last 5 years, a worse case preliminary design and
incomplete seasonal surveys undertaken to date. The three threatened entities found on the site by incomplete and brief surveys are;
• Slaty Red Gum Eucalyptus glaucina (Vulnerable).
• Rupp’s Watte Acacia ruppii (Endangered)
• Koala Phascolarctos cinereus (Endangered)
In total there are 8 plant species which are vulnerable or endangered which are thought to have a high likelihood of being present on the site, and 12 vulnerable/endangered plant species which are thought to have a medium likelihood of being present.
The project will result in the destruction of 18 hectares of subtropical eucalypt floodplain forest and woodland, which is an endangered ecological community.
It will also impact over 100 hectares of coastal swamp eucalypt forest. Whilst apparently none of this habitat will be cleared, the fact that this development which demands wholesale clearing of all vegetation will directly impact upon the integrity of this ecosystem via local changes to hydrology, drainage, microclimate changes with warming and drying of surrounded areas, and presence of pollutant & toxic chemicals from the solar farm.
There are 27 vulnerable/endangered fauna species which are thought to have a high likelihood of being found on the site and 36 vulnerable/endangered fauna species which are thought to have a medium likelihood of being found on the site.
The southern greater glider and yellow-bellied glider was found in very close proximity to the project/deforestation area and it is likely that greater gliders and yellow-bellied gliders utilise the habitat to be destroyed - this will definitely impact the local population, causing fragmentation and reduced viability of the populations and contribute to local extinctions, culminating in full extinction.
The ecologists admit that 63 hectares of foraging habitat for grey-headed flying foxes will be destroyed, but allege that this is insignificant, as does every proponent of every development which destroys habitat . The cumulative impacts of such developments which whittle away and fragment all remaining habitats are of course never mentioned. This is yet another shortcoming of the report and reveal yet again that the ecological survey company writing the report is not objective.
We find it rather strange that "targeted surveys" have not found individuals of any threatened species in the project area, and we can only conclude that the surveys were too brief, not comprehensive enough, and not repeated during other seasons. Maybe it is possible that the surveys are not fully independent, as the ecological survey company is employed by and answers to the proponent, Ark Energy. The ecological surveyors should be fully independent and citizen scientists should be allowed on the site.
Even if hypothetically there are no threatened species existing on the site, this project will still be environmentally catastrophic as it removes carbon-sequestering and climate-regulating ecosystems, and destroys and future possibility of regeneration and restoration of the ecosystems in both the directly cleared area and surrounding areas. If this project goes ahead, it will be transformed into an ecologically catastrophic desert, which retains heat and contributes to direct warming and drying of the earth's surface. In addition, the presence of the solar farm will demand that all vegetation including grasses be destroyed with herbicides, and the soil will likely wash away with high rainfall events. This also will negate any chance of regeneration of ecosystems for many hundreds if not thousands of years. This project is catastrophic for both biodiversity and the biosphere - and therefore the climate.
In addition, proposed transmission line impacts are yet to be determined and ongoing fauna mortalities throughout the operation of the Solar Farm do not appear to have been taken into consideration.
We conclude that this project should be a controlled action under the EPBC Act and needs to be rejected due to adverse effects on biodiversity, the biosphere, and climate.
Direct impacts will include very significant areas removal of native vegetation - ecosystems (possibly 880 hectares of deforestation), removal of threatened species and their habitat and fauna mortality. Indirect impacts will include reduced viability of adjacent habitat due to edge effects, reduced viability of adjacent habitat due to noise, dust, or light spill, and microclimate warming and drying effects, transport of weeds and pathogens from the site to adjacent vegetation and changed fire regimes.
A constraints and opportunities assessment prepared for the project by Biosis identified 17 MNES
entities that have a moderate – high likelihood of occurrence within the project area and may therefore be
impacted by the project. This includes 15 threatened flora and fauna species, and two
threatened ecological communities.
SIC assessments concluded significant impacts have the potential to occur to three
threatened entities. This is predominantly based on the uncertainty of impacts resulting from potential
impacts to habitat present, previous bushfire impacts in the last 5 years, a worse case preliminary design and
incomplete seasonal surveys undertaken to date. The three threatened entities found on the site by incomplete and brief surveys are;
• Slaty Red Gum Eucalyptus glaucina (Vulnerable).
• Rupp’s Watte Acacia ruppii (Endangered)
• Koala Phascolarctos cinereus (Endangered)
In total there are 8 plant species which are vulnerable or endangered which are thought to have a high likelihood of being present on the site, and 12 vulnerable/endangered plant species which are thought to have a medium likelihood of being present.
The project will result in the destruction of 18 hectares of subtropical eucalypt floodplain forest and woodland, which is an endangered ecological community.
It will also impact over 100 hectares of coastal swamp eucalypt forest. Whilst apparently none of this habitat will be cleared, the fact that this development which demands wholesale clearing of all vegetation will directly impact upon the integrity of this ecosystem via local changes to hydrology, drainage, microclimate changes with warming and drying of surrounded areas, and presence of pollutant & toxic chemicals from the solar farm.
There are 27 vulnerable/endangered fauna species which are thought to have a high likelihood of being found on the site and 36 vulnerable/endangered fauna species which are thought to have a medium likelihood of being found on the site.
The southern greater glider and yellow-bellied glider was found in very close proximity to the project/deforestation area and it is likely that greater gliders and yellow-bellied gliders utilise the habitat to be destroyed - this will definitely impact the local population, causing fragmentation and reduced viability of the populations and contribute to local extinctions, culminating in full extinction.
The ecologists admit that 63 hectares of foraging habitat for grey-headed flying foxes will be destroyed, but allege that this is insignificant, as does every proponent of every development which destroys habitat . The cumulative impacts of such developments which whittle away and fragment all remaining habitats are of course never mentioned. This is yet another shortcoming of the report and reveal yet again that the ecological survey company writing the report is not objective.
We find it rather strange that "targeted surveys" have not found individuals of any threatened species in the project area, and we can only conclude that the surveys were too brief, not comprehensive enough, and not repeated during other seasons. Maybe it is possible that the surveys are not fully independent, as the ecological survey company is employed by and answers to the proponent, Ark Energy. The ecological surveyors should be fully independent and citizen scientists should be allowed on the site.
Even if hypothetically there are no threatened species existing on the site, this project will still be environmentally catastrophic as it removes carbon-sequestering and climate-regulating ecosystems, and destroys and future possibility of regeneration and restoration of the ecosystems in both the directly cleared area and surrounding areas. If this project goes ahead, it will be transformed into an ecologically catastrophic desert, which retains heat and contributes to direct warming and drying of the earth's surface. In addition, the presence of the solar farm will demand that all vegetation including grasses be destroyed with herbicides, and the soil will likely wash away with high rainfall events. This also will negate any chance of regeneration of ecosystems for many hundreds if not thousands of years. This project is catastrophic for both biodiversity and the biosphere - and therefore the climate.
In addition, proposed transmission line impacts are yet to be determined and ongoing fauna mortalities throughout the operation of the Solar Farm do not appear to have been taken into consideration.
We conclude that this project should be a controlled action under the EPBC Act and needs to be rejected due to adverse effects on biodiversity, the biosphere, and climate.
Georgia Green
Comment
Georgia Green
Comment
KIPPENDUFF
,
New South Wales
Message
Please see the attached submission.
Attachments
Name Withheld
Object
Name Withheld
Object
ELLANGOWAN
,
New South Wales
Message
It cannot be demonstrated that this project will not affect public health and safety, nor the harmony of surrounding land uses.
Flood -
Increased flooding risk is a serious impact to our property considering the proposed development site is a designated flood prone area and a significant section of our property along the boundary line sits on the same elevation. Neighbours have also witnessed increased flooding levels since the host landowner cleared bushland on the proposed development site, whereby Avenue Road began flooding during heavy rain periods, restricting southerly access for residents during potential hazardous events.
The addition of non-permeable solar farm panelling and associated infrastructure to the proposed development site would increase rainfall run-off on flood prone land that has already demonstrated an increased propensity to flood after vegetation clearing. Moreover, any associated earthworks that modify the topography, permeability and absorption rate on the proposed development site risks exacerbating the frequency and severity of any future flooding.
The consequences for our property would be severe. Aside from fencing and infrastructure damage, our capacity for primary production activities during and after flooding on the property would be heavily impacted. The property’s soil and water quality would be at high risk of degradation through contamination and erosion.
Landscape and Visual -
As witnessed in person by Ark Energy employees, the visual impact including glint and glare on our property is severe and unviable for any visual impact mitigation screening. This is due to our property’s intrinsic northern position, immediate proximity, elevation and significant vista over the proposed solar farm site. The sheer length, depth, height and density of screening vegetation required to provide any degree of visual mitigation is unrealistic when considering the amount of time it would take trees to reach an effective growth height for us or any of our neighbours. From a bushfire risk perspective, increasing the fuel load on bushfire prone land along our boundary line will also drastically increase the chances of fire propagation on to neighbouring land from the proposed development site, no matter the species selected for planting.
Affect on the livelihood of the community with eco-tourism, agri-tourism, and health and wellness businesses which rely on the intrinsic rural amenity and clean land for operation. The industrialised landscape of a large-scale solar farm does not support these businesses therefore will impact these people’s livelihoods.
Noise -
Both airborne and ground borne noise pollution during construction, operation and decommissioning of the proposed solar farm would contribute to a considerably heavier intrusive and amenity noise load than is typically experienced on our property. At present, noise levels in the area are in alignment with the amenity of the locality, with the loudest noises produced by occasional trucks along Avenue Road. Any heavy vehicle haulage, earth works and operational infrastructure required for the proposed solar farm will elevate local noise loads above levels typically experienced, despite the route taken by trucks. This is a serious concern for us that would adversely impact all residents including young families who live and work from their properties. The concerns for noise include cumulative noise and vibration, and the health effects of infrasound. The residents living here can attest to how the far the sound travels to the enclave of residents to the north of the proposed site, particularly with the prevailing winds coming from the direction of the site.
Hazards -
As the proposed development site is classed Category 1 bushfire prone land, there would be an increased capacity for bushfires to propagate onto our property by way of:
- increased local ambient and ground temperatures (photovoltaic heat island effect)
- increased fuel loads through combustible infrastructure and site materials at such a large-scale (panels, cabling, building structures, vehicles, lithium batteries)
- increased combustible fuel loads through visual mitigation planting along shared boundaries
- increased lightening strikes by way of conductive infrastructure antennae
- decreased capacity of local emergency services to protect surrounding properties
through resource drain towards the proposed large scale solar farm
Moreover, the ability of local Rural Fire Service (RFS) to deal with a potential lithium battery-bank fire is a critical concern when assessing the typical theory, experience and equipment provided to RFS crews. The proximity of the proposed solar farm’s Battery Energy Storage System facility to the adjacent bushfire prone land poses a considerable risk for increased combustible fuel loads and fire propagation to adjacent properties. The buffer zones suggested would be completely inadequate, especially when considering wind.
The serious health risks associated with any harmful chemicals and contamination released into the air, soil and water sources from burnt plastics, metals and lithium batteries during fire events. Of particular concern are known carcinogens produced by burning solar panels. Once in the soil, studies have also demonstrated high leaching characteristics for these chemicals. The impacts to our community’s health, livestock, food and water sources would be devastating due to our proximity to the proposed development site. There is a serious potential risk of silicosis of the lungs from airborne carcinogens and long term health effects related to consumption of foods grown on or near soil and water sources affected by hazardous leaching of toxic solar panel chemicals. As well as the chemicals used for maintenance of all infrastructure and groundcover management. All of which will end up being consumed by local families and farmers as our food, livestock and water is produced on the land. This will also impact the food coming out of our region from the neighbouring commercial agriculture businesses.
The proposed solar farm’s photovoltaic heat island effect is a serious health and well being concern. This thoroughly documented and peer reviewed effect associated with large scale solar farms raises local temperatures, adversely impacting:
- fire suppression due to higher ambient and fuel source temperatures
- health issues related to human thermal comfort levels
- livestock thermal comfort
- soil biodiversity and productive thermal range for crops and orchards
- the value of adjacent properties
This impact cannot be mitigated in any way due to our immediate proximity, the scale of the proposed farm and the inherent nature of this adverse effect.
The unstudied, long-term EMF radiation at such a large scale and in such close proximity to residents, particularly children. Especially the cumulative effect of all three of the proposed large-scale solar farms and BESS of this magnitude situated in such close proximity to homes and workplaces.
Environment -
The grassland and dense native forest habitat on the proposed site along and directly adjacent, would be severely impacted. Damage would be extensive and severe on the native protected flora and fauna, in an area well-known for its extremely high biodiversity, delicate ecosystems, wetlands and river systems, including the nations largest tidal waterpool. Koalas are frequently heard and sighted, and the many many water birds who reside here would be subjected to the known Lake Effect, glint and glare and thermal discomfort. Of particular concern is the endangered Coastal Emu (of which it is estimated there are less than 50), with all surrounding residents having spotted evidence of the emus including tracks, scat, nests and the birds themselves. With such a localised area of habitation, this destruction of key habitat and installation of exclusion fencing will severely effect the number of Coastal Emus, the effect of which is unmitigable.
Of great concern is also the downstream effect to the nations largest tidal waterpool when toxic chemicals leach from the panels or during construction during a flood or extreme weather event.
Ark Energy conduct -
Drop-in sessions avoided the opportunity for a public forum whereby the community can hear each other’s questions and concerns. Greenwashed presentations, and persistent downplaying or omission of inherent impacts and risks, and unable to answer simple questions or concerns. An obvious box-ticking exercise, rather than genuine engagement.
Failure to engage with us as key stakeholders for over 18 months to notify us of the proposal, whilst significant residential and commercial investment was occurring on the property on the basis of the current rural amenity and health and safety of the surroundings. This personal and financial investment would not have occurred had we been notified, resulting in significant loss. The proposal has had an immediate effect on property devaluation for us and our neighbours.
It should be noted that the broader community still remains unaware and uninformed about the project, Richmond Valley Council have not listed this in relevant public communications.
Details missing from EIS - including, but not limited to:
- night-lighting locations and frequency/hue of lighting used, the consequent effect on landscape and environment, including insects.
- A list of the chemical components of the panels Ark Energy propose to use, and their known impact on human health and the environment
Why does the government rely on the friendly reports from the company standing to gain from the information they contain in order to make their decision? Why do impacted neighbours with little understanding of the realities of such projects and their intrinsic impacts not have advocacy? Who is liable when there is damage or fatality on neighbouring properties from a fire
Flood -
Increased flooding risk is a serious impact to our property considering the proposed development site is a designated flood prone area and a significant section of our property along the boundary line sits on the same elevation. Neighbours have also witnessed increased flooding levels since the host landowner cleared bushland on the proposed development site, whereby Avenue Road began flooding during heavy rain periods, restricting southerly access for residents during potential hazardous events.
The addition of non-permeable solar farm panelling and associated infrastructure to the proposed development site would increase rainfall run-off on flood prone land that has already demonstrated an increased propensity to flood after vegetation clearing. Moreover, any associated earthworks that modify the topography, permeability and absorption rate on the proposed development site risks exacerbating the frequency and severity of any future flooding.
The consequences for our property would be severe. Aside from fencing and infrastructure damage, our capacity for primary production activities during and after flooding on the property would be heavily impacted. The property’s soil and water quality would be at high risk of degradation through contamination and erosion.
Landscape and Visual -
As witnessed in person by Ark Energy employees, the visual impact including glint and glare on our property is severe and unviable for any visual impact mitigation screening. This is due to our property’s intrinsic northern position, immediate proximity, elevation and significant vista over the proposed solar farm site. The sheer length, depth, height and density of screening vegetation required to provide any degree of visual mitigation is unrealistic when considering the amount of time it would take trees to reach an effective growth height for us or any of our neighbours. From a bushfire risk perspective, increasing the fuel load on bushfire prone land along our boundary line will also drastically increase the chances of fire propagation on to neighbouring land from the proposed development site, no matter the species selected for planting.
Affect on the livelihood of the community with eco-tourism, agri-tourism, and health and wellness businesses which rely on the intrinsic rural amenity and clean land for operation. The industrialised landscape of a large-scale solar farm does not support these businesses therefore will impact these people’s livelihoods.
Noise -
Both airborne and ground borne noise pollution during construction, operation and decommissioning of the proposed solar farm would contribute to a considerably heavier intrusive and amenity noise load than is typically experienced on our property. At present, noise levels in the area are in alignment with the amenity of the locality, with the loudest noises produced by occasional trucks along Avenue Road. Any heavy vehicle haulage, earth works and operational infrastructure required for the proposed solar farm will elevate local noise loads above levels typically experienced, despite the route taken by trucks. This is a serious concern for us that would adversely impact all residents including young families who live and work from their properties. The concerns for noise include cumulative noise and vibration, and the health effects of infrasound. The residents living here can attest to how the far the sound travels to the enclave of residents to the north of the proposed site, particularly with the prevailing winds coming from the direction of the site.
Hazards -
As the proposed development site is classed Category 1 bushfire prone land, there would be an increased capacity for bushfires to propagate onto our property by way of:
- increased local ambient and ground temperatures (photovoltaic heat island effect)
- increased fuel loads through combustible infrastructure and site materials at such a large-scale (panels, cabling, building structures, vehicles, lithium batteries)
- increased combustible fuel loads through visual mitigation planting along shared boundaries
- increased lightening strikes by way of conductive infrastructure antennae
- decreased capacity of local emergency services to protect surrounding properties
through resource drain towards the proposed large scale solar farm
Moreover, the ability of local Rural Fire Service (RFS) to deal with a potential lithium battery-bank fire is a critical concern when assessing the typical theory, experience and equipment provided to RFS crews. The proximity of the proposed solar farm’s Battery Energy Storage System facility to the adjacent bushfire prone land poses a considerable risk for increased combustible fuel loads and fire propagation to adjacent properties. The buffer zones suggested would be completely inadequate, especially when considering wind.
The serious health risks associated with any harmful chemicals and contamination released into the air, soil and water sources from burnt plastics, metals and lithium batteries during fire events. Of particular concern are known carcinogens produced by burning solar panels. Once in the soil, studies have also demonstrated high leaching characteristics for these chemicals. The impacts to our community’s health, livestock, food and water sources would be devastating due to our proximity to the proposed development site. There is a serious potential risk of silicosis of the lungs from airborne carcinogens and long term health effects related to consumption of foods grown on or near soil and water sources affected by hazardous leaching of toxic solar panel chemicals. As well as the chemicals used for maintenance of all infrastructure and groundcover management. All of which will end up being consumed by local families and farmers as our food, livestock and water is produced on the land. This will also impact the food coming out of our region from the neighbouring commercial agriculture businesses.
The proposed solar farm’s photovoltaic heat island effect is a serious health and well being concern. This thoroughly documented and peer reviewed effect associated with large scale solar farms raises local temperatures, adversely impacting:
- fire suppression due to higher ambient and fuel source temperatures
- health issues related to human thermal comfort levels
- livestock thermal comfort
- soil biodiversity and productive thermal range for crops and orchards
- the value of adjacent properties
This impact cannot be mitigated in any way due to our immediate proximity, the scale of the proposed farm and the inherent nature of this adverse effect.
The unstudied, long-term EMF radiation at such a large scale and in such close proximity to residents, particularly children. Especially the cumulative effect of all three of the proposed large-scale solar farms and BESS of this magnitude situated in such close proximity to homes and workplaces.
Environment -
The grassland and dense native forest habitat on the proposed site along and directly adjacent, would be severely impacted. Damage would be extensive and severe on the native protected flora and fauna, in an area well-known for its extremely high biodiversity, delicate ecosystems, wetlands and river systems, including the nations largest tidal waterpool. Koalas are frequently heard and sighted, and the many many water birds who reside here would be subjected to the known Lake Effect, glint and glare and thermal discomfort. Of particular concern is the endangered Coastal Emu (of which it is estimated there are less than 50), with all surrounding residents having spotted evidence of the emus including tracks, scat, nests and the birds themselves. With such a localised area of habitation, this destruction of key habitat and installation of exclusion fencing will severely effect the number of Coastal Emus, the effect of which is unmitigable.
Of great concern is also the downstream effect to the nations largest tidal waterpool when toxic chemicals leach from the panels or during construction during a flood or extreme weather event.
Ark Energy conduct -
Drop-in sessions avoided the opportunity for a public forum whereby the community can hear each other’s questions and concerns. Greenwashed presentations, and persistent downplaying or omission of inherent impacts and risks, and unable to answer simple questions or concerns. An obvious box-ticking exercise, rather than genuine engagement.
Failure to engage with us as key stakeholders for over 18 months to notify us of the proposal, whilst significant residential and commercial investment was occurring on the property on the basis of the current rural amenity and health and safety of the surroundings. This personal and financial investment would not have occurred had we been notified, resulting in significant loss. The proposal has had an immediate effect on property devaluation for us and our neighbours.
It should be noted that the broader community still remains unaware and uninformed about the project, Richmond Valley Council have not listed this in relevant public communications.
Details missing from EIS - including, but not limited to:
- night-lighting locations and frequency/hue of lighting used, the consequent effect on landscape and environment, including insects.
- A list of the chemical components of the panels Ark Energy propose to use, and their known impact on human health and the environment
Why does the government rely on the friendly reports from the company standing to gain from the information they contain in order to make their decision? Why do impacted neighbours with little understanding of the realities of such projects and their intrinsic impacts not have advocacy? Who is liable when there is damage or fatality on neighbouring properties from a fire
Pagination
Project Details
Application Number
SSD-41020244
EPBC ID Number
2023/09641
Assessment Type
State Significant Development
Development Type
Electricity Generation - Solar
Local Government Areas
Richmond Valley