Rothbury Battery Energy Storage System

This is a highly valued residential and tourist area.

Building a BESS in this area is an assault on the neighbours, visitors and environment.

In an evacuation scenario (due to fire or thermal runaway) there will be a severe bottlneck. A BESS fire will release dense plums of highly toxic gases like hydrogen fluroide and carbon monoxide over the community. There is no way to safely evacuate the thousands of nearby residents.

The emergency response capability has not been proven for this poisonous BESS.

We are extremely alarmed that local emergency services will be subjected to life-threatening, lethal hydrogen fluoride if responding to a major battery incident involving intense heat, hazardous gases and unpredictable failure mechanisms.

This developer must provide their own firefighters and emergency responders - who have appropriate training, equipment, resources and procedures for credible worst-case scenarios as no locals should ever be subjected to lethal BESS plumes.

Building this BESS in a bush fire zone is a looming environmental disaster. Roll out now and manage the harm later is NOT in the public interest. Do the neighbours know they are in the sacrifice zone?

Thermal Runaway, flooding and toxic chemical runoff are all unacceptable risks. A BESS fire will not be able to be extinguished, it will have to burn out while belching toxic smoke over the community. The noise of this BESS combined with the neighbouring BESS will have a cumulative impact on the neighbours. This project is NOT in the public interest.

To whom it may concern,
This submission is provided in response to the Rothbury Battery Energy Storage System (SSD 85939708). However, because the Rothbury BESS and the Sunshine Estate BESS (SSD 92914712) are located in immediate proximity, share infrastructure corridors and have overlapping environmental impacts, my comments necessarily relate to both developments. This submission is therefore intended to assist the consent authority in determining whether the projects satisfy the SEARs and whether their individual and cumulative impacts have been adequately assessed. In their current form, the documentation for both proposals does not provide sufficient certainty regarding key infrastructure elements or mitigation measures. As a result, the impacts of the developments have not been comprehensively or reliably assessed.
I am the owner (and future resident) of 35 Crown Line Drive, Rothbury, located to the north of both proposed developments. While I support renewable energy infrastructure in principle, I object to these projects in their current form for the reasons outlined below.

1. UNDEFINED TRANSMISSION INFRASTRUCTURE
The projects rely on connection to the existing substation, however:
• Transmission alignment is not defined
• Overhead vs underground delivery is unresolved
• There is no clarity on whether infrastructure extends beyond the site, including northward
This creates a fundamental gap in the assessment. Potential impacts (visual, landscape and amenity) associated with transmission infrastructure outside the site have not been properly evaluated.
This uncertainty alone prevents full assessment of the projects.

2. RELIANCE ON UNPROVEN LANDSCAPE SCREENING
The visual impact assessment relies heavily on proposed landscape screening. However:
• Screening consists of 10m planting buffers and windbreaks that fragment, not fully screen views
• The Landscape Plan is indicative only and not finalised
• Planting details remain subject to future design and consultation
• Screening effectiveness depends on long-term vegetation growth
Critically:
• Mature tree planting will take many years to establish
• In the short to medium term, the development will be far more visible than assessed
This means the “low visual impact” conclusion is dependent on mitigation that is:
• not fixed
• not immediate
• not guaranteed

3. TRANSMISSION + SCREENING GAP
These issues combine:
• Any additional overhead transmission lines would not benefit from equivalent screening
• Such infrastructure may extend beyond landscaped areas
Accordingly:
Visual impacts associated with transmission infrastructure are likely underestimated and not fully assessed.

4. CUMULATIVE IMPACTS NOT ADEQUATELY ASSESSED
The two BESS projects are co-located and may be constructed concurrently. However:
• There is limited integrated modelling of combined impacts
• Worst case cumulative scenarios (noise, traffic, visual change) are unclear
This does not meet the intent of cumulative impact assessment required under the SEARs.

5. RELIANCE ON MITIGATION RATHER THAN DESIGN
Across the assessments:
• Noise, visual and construction impacts are managed primarily through mitigation and staging assumptions
• Outcomes depend on future implementation rather than inherent design compliance
This introduces further uncertainty into the assessment.

CONCLUSION
The projects are not opposed in principle. However:
The combination of undefined transmission infrastructure and reliance on conceptual, long-term landscape mitigation means that the true impacts of the developments remain uncertain.

MY POSITION
I object to the projects in their current form and request that consent not be granted unless:
• Transmission infrastructure is fully defined and assessed
• Landscape mitigation is finalised and realistically modelled over time (including establishment periods)
• Cumulative impacts across both developments are comprehensively assessed
• All associated infrastructure impacts are clearly resolved

Regards,
Ann Fallon
35 Crown Line Drive, Rothbury

When the inevitable, irreversible environmental harm occurs, who will bear the responsibility and financial liability from this ecocidal monstrosity?

According to the POEO Act - the Local Council is ultimately responsible/liable for any toxic contamination/pollution of the land/water caused by Solar Electricity Generation Works as they are NOT A REGULATED ACTIVITY.
Is it the same for this BESS disaster?

Where’s the essential, upfront Decommissioning + Remediation Bond and the Public Liability Guarantee from the Government to protect all the neighbour victims?

Nobody wants this toxic, life-threatening Asbestos of the Future - Ticking-Time-Bomb BESS JUNK in Rural NSW!

The irresponsible, dictatorial NSW Government must be sacked as it’s completely failing to protect the public from the catastrophic FIRE Risks of Lithium-ion Battery Energy Storage Systems as they threaten our lives and poison our land, water and biodiversity.

It’s SO STUPID and SO BAD that it even appears to be DELIBERATE!

It’s well past time that the NSW Premier gets honest for once and admits these SWINDLE FACTORIES ARE ALL A DANGEROUS, DEADLY SCAM!

Border Force admit that imported BESS, Solar Panels and Wind Turbines are unregulated - with banned substances that they contain like PFAS/PFOS and Asbestos being ignored.

There is no supply chain transparency for unethically sourced components - where the origin, manufacturing standards and environmental practices require far greater scrutiny.

Imported infrastructure should be subject to rigorous verification of safety, security, environmental and ethical standards.

Why does the dodgy NSW Government and NON-independent IPCN keep ignoring these essential facts?

This dodgy assessment is total rubbish as it only relies on fake green predictions and assumptions based on garbage in garbage out modelling and false propaganda - while leaving vital life-threatening risks, energy poverty and the national security crisis the CCP reliant RenewaBULL RORT has created deliberately unaddressed.

Sound environmental policy based on ecologically sustainable development requires a complete examination of foreseeable risks prior to planning, let alone approval.

DUMP THIS TOXIC SCAM and DUMP THE TOXIC NSW GOVERNMENT SCAMMERS!

Experience has shown that BESS works draw on the grid at times of no sun and little or no wind. On occasions, BESS works draw on the grid at the same time that other BESS works are supplying the grid. That is, BESS are effectively charging another BESS. This is ludicrous, and was highlighted by SOS some years ago that this would occur. This project will add to this insanity.
Attached are questions that must be addressed by this project in its EIS response.

HVWTA is not opposed to additional power infrastructure in the Hunter region. Power reliability has a direct and material impact on our members' businesses. Outages and point-in-time restoration delays contribute to significant annual income losses for tourism operators and require additional resourcing and equipment to manage. On that basis, we would welcome investment that improves power reliability for the region. We acknowledge that battery energy storage infrastructure can be appropriate where it is compatible with surrounding land uses. Our concern with this proposal is that it is located within one of Australia's most recognised wine tourism landscapes rather than within an established industrial area.

Hunter Valley Wine Country is not simply a rural landscape. It is an internationally recognised wine and tourism destination whose economy depends upon the preservation of its landscape character and visitor experience. Land-use compatibility should therefore be assessed not only against adjoining land uses, but also against the strategic role this precinct plays within the regional visitor economy. Unlike projects located within established industrial estates, this proposal introduces industrial-scale infrastructure into a tourism-defined landscape containing vineyards, cellar doors, accommodation, restaurants and visitor attractions.

The proposal should also be assessed against the long-term planning vision for the Cessnock Vineyard District, which seeks to protect the landscape values that underpin tourism, wine production and investment confidence.

Cumulative Impact
We note that two projects are being assessed separately and as isolated projects, these being the Rothbury BESS at 1309 Wine Country Drive (Ausgrid) and the Sunshine Estate BESS at 1337 Wine Country Drive (Avenis) but note that we are providing feedback in respect of both. With two BESS proposals in close proximity, sharing a connection point and overlapping impact areas, we are concerned the cumulative effect on visual amenity, noise, traffic and the broader character of this stretch of Wine Country Drive has not been adequately assessed from a tourism perspective.
While each project is assessed individually, visitors experience the landscape cumulatively. The relevant question is therefore not whether each individual project is acceptable in isolation, but whether the combined effect of multiple infrastructure projects materially alters the character of this section of Wine Country Drive.
We ask for consideration on how many similar developments this corridor could reasonably absorb before visitor experience and destination identity are materially affected, and what long-term vision exists for infrastructure development within this precinct, noting the project's expected 50-year operational life.

Visual Impact and Destination Character
Wine Country Drive is the primary arrival corridor into Hunter Valley Wine Country, and visitor first impressions are formed travelling this route. These sites currently have open acreage, horses, neighbouring vineyards and accommodation. The EIS itself acknowledges that visual impact was one of the most raised community concerns, with assessments undertaken from Wine Country Drive, Scarborough Cottage accommodation, the Black Creek Farm wine tasting deck, and nearby residences. We would add that the site sits opposite Greenacres, a large group accommodation property and private residence at the Old North Road corner, further underscoring the sensitivity of this location to visual and amenity impacts. We ask whether proposed landscaping and screening are genuinely sufficient to maintain the visual standard expected of Australia's oldest wine region, and whether this development sets an undesirable precedent for industrial-scale energy infrastructure within a tourism-defined precinct.

Construction Traffic and Visitor Access
Wine Country Drive access for tourism, accommodation and cellar door operators must be protected throughout construction. We request firm conditions restricting major construction activity and traffic disruption during peak visitation periods, including long weekends, school holidays and major regional events.

Noise, Fire Risk and Visitor Perception
While the EIS concludes noise and fire risk impacts are manageable, we note that perception matters significantly in a visitor economy, particularly given proximity to vineyards, accommodation providers and outdoor dining and tasting experiences. We ask that emergency response planning explicitly account for nearby tourism accommodation and visitor activity, and that this be communicated clearly to operators in the area, including those at Black Creek, where tourism operators and managers reside on site. We note that noise was raised as a concern, including from the cumulative effects from two BESS. We seek confirmation that any proposed noise wall does not create any additional visual impacts.

Economic Assessment
We ask that the economic assessment more fully accounts for the value of tourism expenditure, wine industry output, destination brand value, and accommodation and property investment in this precinct, alongside the stated benefits of construction employment and energy reliability.

Community Benefit
Should either project proceed, HVWTA requests that a meaningful share of the proposed Community Benefit Fund be directed toward visitor-economy and landscape improvements, in recognition of the precinct most directly affected.

Should consent ultimately be granted, HVWTA requests that conditions of consent include:
• coordinated cumulative monitoring with the neighbouring Sunshine Estate BESS;
• strengthened landscape screening requirements, including establishment targets across both sites;
• restrictions on construction during major tourism periods;
• ongoing consultation with nearby tourism operators;
• periodic review of visual screening effectiveness throughout the operational life of the project; and
• clear decommissioning obligations to ensure the site can be restored at the end of its operational life.

We would welcome the opportunity to discuss these matters further and to be consulted on any conditions of consent.

Cease and Desist all further processing of  SSD-85939708 Rothbury BESS.
This region coal mine region. Coal mine region, not RE transition region, for God's Sake!!
I need an Immediate Moratorium on BESS in NSW thank you Minister Sharpe.
And this will be Immediate thankyou Minister Sharpe for you are to under Full investigation for Harm and Loss to Rural regions Agricultural regions. Agricultural. Agricultural.
I wonder who the Mayor is. Haven't done their homework have they re Risk of BESS.
https://theconversation.com/when-the-worlds-largest-battery-power-plant-caught-fire-toxic-metals-rained-down-wetlands-captured-the-fallout-268848
1 Dec 2025 — The Moss Landing battery fire became an unintended experiment – showing how burning lithium-ion cells scattered nickel, cobalt and manganese ...
https://www.epa.gov/ca/moss-landing-vistra-battery-fire
On January 16, 2025, the Moss Landing 300 battery energy storage system at the Moss Landing Vistra power plant (Monterey County, Calif.) caught fire
https://reneweconomy.com.au/massive-moss-landing-battery-still-smoking-as-authorities-probe-cause-of-devastating-fire/
20 Jan 2025 — About 80 per cent of the Moss Landing battery facility in California has been destroyed in a fire which started on Thursday afternoon.
https://en.wikipedia.org/wiki/Moss_Landing_Power_Plant
At 3 pm on Thursday, January 16, 2025, a fire broke out in the Phase 1 building (300 MW / 1,200 MWh), the portion of the site managed by Vistra Corp.
https://www.montereycountynow.com/news/local_news/one-year-later-the-moss-landing-battery-fire-leaves-more-questions-than-answers/article_996d6185-1fce-4131-90b1-292dbe96a291.html
15 Jan 2026 — One year after the Moss Landing battery fire, health impacts remain unclear. Residents seek answers, oversight, and regulations.
https://community.purpleair.com/t/moss-landing-battery-fire/11233
17 Jan 2025 — The burnt batteries are sending chlorine and/or florine gases into the atmosphere. We are trying to assess the risk to us here in Santa Cruz.Read more
https://heatmap.news/energy/moss-landing-battery-safety
28 Mar 2025 — Nearly all of the batteries at the 300 megawatt facility, one of the world's largest, burned up in the fire, sending a colossal plume of black smoke soaring up ...Read more
https://www.utilitydive.com/news/moss-landing-battery-fire-vistra/737837/
21 Jan 2025 — The site's fourth blaze in five years destroyed most of a 300-MW battery array owned by Vistra Energy and should serve as a “wake-up call” ...
https://sfstandard.com/2025/02/06/erin-brockovich-lawsuit-moss-landing-power-plant-fire/
6 Feb 2025 — Erin Brockovich and Monterey County residents sued Vistra Energy and PG&E Thursday over a January fire at a battery storage site.
https://kioncentralcoast.com/news/monterey-county/moss-landing/moss-landing-storage-fire/2025/03/11/another-town-hall-addresses-the-moss-landing-battery-storage-fire-lawsuit-tuesday-evening/
11 Mar 2025 — There will be another town hall meeting held by Singleton Schreiber and consumer advocate Erin Brockovich at 6 p.m. on Tuesday.
https://www.singletonschreiber.com/newsroom/events/moss-landing-battery-fire-virtual-town-hall-3-4-26
3 Apr 2026 — Join Singleton Schreiber and consumer advocate Erin Brockovich at a Virtual Town Hall on Wednesday, March 4th, 2026, at 5:00 PM, PT. WHAT: Moss ...Read more
https://www.facebook.com/groups/962330675331079/posts/971282871102526/
Never Again Moss Landing Battery Environmental Disaster Community Group. Kathy Sinnott󰞋Feb 1, 2025󰞋󱟠. 󳄫. Erin Brockovich called me last evening.Read more......."Erin Brockovich called me last evening. She is reaching out to those of us who reported the BESS fire on her Community Health Book webpage. Enough of us put pins in the map to get attention. It’s not too late to stick your pin in the map"...

Polkolbin is a area under view because wine grows there.
Compensation plans for Damages from incidences eg. Ignition in BESS facilities, are not included in this plan - Rothbury BESS, 1309 Wine Country Drive, Rothbury.
Rothbury is a small town in the COAL MINING AND COAL FIRED POWER STATIONS region Hunter Region, NSW. Rothbury is 10 km from Cessnock. At the 2011 census, Rothbury had a population of 452 people. North Rothbury is another small settlement about 5km to the northeast. The town is 8 km from Pokolbin's vineyards. Rothbury BESS project site lies between these small villages. Have ALL Community been Notified of this project and the risks associated with BESS.
Newcastle residents and businesses can host their own battery storage can't they, Minister Sharpe. Batteries on every home and business for Newcastle and umm.... How Dare you Threaten Agricultural Industry regions eg Polkolbin wines, plus Rural residents regions out of city areas, and with No awareness of Risks of BESS, 10km from a potential site nb, Minister Sharpe. No Social Licence, Minister Sharpe.
Is an evacuation plan included in the proposal ? No. Then who pays for Damages caused to Local communities, Agricultural enterprises, and small businesses by Unnecessary Toxic Risk to Air, Land, Water, Water Supply  - dams and rainwater tank supply. Where will You be in 8 years time, 3 years time, 4 months time, 6 months time, Minister ? Noted, you will be, Minister Sharpe, for Unnecessary Threat to Communities Australian for No reason but a Scam named Net Zero. Shame on you Minister Sharpe. How Dare you continue this Farce of Renewables toxic Junk Future Inappropriate Infrastructure, aka RE transition including BESS for energy storage at the same time Australian Government and NSW Government still sell NSW- mined Coal gping offshore from Newcastle, en masse, you Bunch of Hypocrits - Shame on you, Shame on you, Shame on you. 
Is that a Glencore Coal mine nearby, west of Rothbury, Cessnock, with Liddell Power Station site NEARBY ??? ? 

Austar coal mine is located near Paxton, NSW. "The mine has coal reserves amounting to 221 million tonnes of coking coal, one of the largest coal reserves in Asia and the world. In 2012, the mine had an annual production capacity of 3 million tonnes of coal.."
https://www.glencore.com.au/operations-and-projects/coal/current-operations 
"Glencore is one of Australia's largest producers of coal, for export, with 13 operational mines across New South Wales and Queensland."
https://www.facebook.com/Ausgrid/
"We supply power to Sydney, Central Coast, and the Hunter.."

Thanks a lot, Minister Sharpe! How Dare You increase Cost of Living and Harm and cause loss to Our Precious Rural Agricultural regions you are Unaware grow Food for the Nation.
How do you Get away with it, Minister Sharpe, is a question.
Moratorium BESS in NSW thank you. There is No need for these across NSW Agricultural Rural regions growing Food for the Nation.
Hope you have a Compensation plan on hand, Minister Sharpe. Where is it ?

I object to the proposed Rothbury Battery Energy Storage System and request that the Department carefully consider the following matters before determining the application.

While I recognise the need to improve the reliability of the electricity network and support the transition of the energy system, I am concerned that this proposal has the potential to create unacceptable impacts on the surrounding community and rural landscape.

My primary concerns include:

Visual and Landscape Impacts
The project introduces significant industrial infrastructure into a predominantly rural setting. I am concerned about the cumulative industrialisation of the Rothbury area, particularly when considered alongside existing and proposed energy and infrastructure developments. The cumulative visual impact should be assessed rather than considering this project in isolation.
Traffic and Road Safety
Construction traffic, including heavy vehicle movements, has the potential to adversely affect local roads, residents and other road users. I request that detailed traffic management measures be required, together with any necessary road upgrades funded by the proponent.
Bushfire and Battery Fire Risk
Although battery technology continues to improve, large-scale battery energy storage systems carry inherent fire risks. I request that the Department ensure independent review of the proposed fire safety strategy, emergency response arrangements, water supply, and consultation with Fire and Rescue NSW before any approval is granted.
Noise
Construction and operational noise should not adversely affect nearby residents. Appropriate noise limits, ongoing monitoring and enforceable compliance requirements should be imposed if the project proceeds.
Environmental Impacts
The Department should be satisfied that impacts on native vegetation, biodiversity and threatened species have been appropriately avoided, minimised and offset where necessary. Particular attention should be given to cumulative environmental impacts associated with increasing energy infrastructure within the region.
Decommissioning and Rehabilitation
The proponent should be required to provide a legally enforceable decommissioning and rehabilitation plan, including adequate financial security to ensure the site can be restored at the end of the project's operational life without cost to the community or taxpayers.
Community Benefit
Should the project be approved, I encourage the Department to require meaningful community benefit initiatives, ongoing consultation with local residents and transparent reporting of environmental performance throughout the life of the project.

For these reasons, I respectfully object to the proposal in its current form and request that the Department either refuse the application or require additional conditions and mitigation measures to adequately address the issues identified above.

Thank you for considering my submission.

Declaration of Objection:
I am writing to register my strong objection to the proposed Rothbury Battery Energy
Storage System (SSD-85939708). As a local community stakeholder, I request that the Department of Planning, Housing
and Infrastructure refuse consent for this development based on the critical deficiencies in the proponent's Environmental
Impact Statement (EIS)
Technical Grounds for Objection:
• Inadequate Bushfire and Thermal Runaway Risk Management: The proposed installation of 140 lithium-ion battery
containers represents a catastrophic hazard profile for the immediate Rothbury area.
Thermal Runaway and Toxic Gas Outgassing: Lithium-ion BESS facilities carry an inherent risk of thermal runaway, which
releases highly toxic gases including Hydrogen Fluoride (HF), Carbon Monoxide (CO), and volatile organic compounds. The
EIS fails to demonstrate an adequate air-quality dispersion model detailing how these toxic plumes would impact nearby
residential properties and vineyards under dominant local wind conditions.
Overburdening of Local Emergency Services: The Rothbury and broader Cessnock area relies heavily on the Volunteer
Rural Fire Service (RFS). The EIS does not present a comprehensive Fire and Emergency Response Plan developed in
direct concurrence with Fire and Rescue NSW and the RFS. A major BESS fire requires millions of liters of water to cool
over several days; the EIS has not identified a sustainable, onsite water supply that does not compromise the local
domestic water network or sensitive rural water tables.
• Substantial Impacts on the Existing Local Road Network: The construction phase is slated to introduce heavy vehicle
traffic, ranging up to 26-meter B-Double transport trucks, onto Wine Country Drive and surrounding local feeder roads over
an 18-month period.
Cumulative Damage to Road Infrastructure: The current pavement design of local access roads is completely unsuited to
sustain the heavy axle loads associated with moving massive high-voltage transformers and utility-scale battery
enclosures. The EIS significantly downplays the physical wear and tear on the road network.
Traffic Disruption on Wine Country Drive: Wine Country Drive is a critical tourism and commuter artery for the Hunter
Region. Introducing heavy vehicle movements at the proposed upgrade access points will create severe congestion,
decrease road safety, and disrupt local businesses that rely on seamless tourist access. The mitigation measures proposed
in the traffic assessment are entirely inadequate.
• Destruction of Critical Local Biodiversity & Threatened Species Habitat: The project area spans approximately 50
hectares, with a massive direct disturbance footprint.
Impact on Matters of National Environmental Significance (MNES): The clearing of native vegetation directly threatens
known habitats for critical local species, including foraging structures for threatened Black Cockatoos and core habitat for
vulnerable local fauna.
Flawed Avoidance and Offset Logic: The proponent's claim that a "worst-case scenario" footprint will be reduced post
approval is unacceptable. The Department must assess the actual, definitive footprint now. The proposed biodiversity
offsets do not compensate for the immediate, localized loss of ecosystem connectivity and mature canopy clearing within
the Rothbury area.
• Severe Visual Amenity and Noise Impacts on a Rural-Tourism Zone: The scale of the industrial infrastructure
proposed—including 140 containers, 42 inverters, high-voltage substations, 132kV sub-transmission lines, and 7-meter
wide access roads—is fundamentally incompatible with the rural, landscape-tourism character of Rothbury.
Inadequate Visual Screening: The current tree-line shielding is insufficient to hide 3-meter-high industrial containers and
high-voltage grid infrastructure from neighboring properties and key transport corridors. The proposed landscape
buffering will take years to mature, leaving an industrial scar in a prominent rural area.
Operational Inverter Noise: The continuous low-frequency hum generated by 42 Power Conversion Systems (inverters)
and cooling fans operating 24/7 will severely degrade the acoustic amenity of the surrounding rural environment. This
continuous background noise has been poorly modeled and will heavily impact the quality of life for nearby residents.
Anthony Poole

Submission Objecting to SSD-85939708 – Rothbury Battery Energy Storage System

To the Department of Planning, Housing and Infrastructure,
I write to object to State Significant Development Application SSD-85939708 for the proposed Rothbury Battery Energy Storage System.

While I recognise the importance of improving electricity reliability and supporting the transition to lower-emission energy sources, I do not believe this proposal has demonstrated that the chosen location is appropriate or that all environmental and community impacts have been adequately addressed.

My reasons for objection are outlined below.

Public safety
The project involves a large-scale lithium-ion battery installation that introduces fire and hazardous materials risks uncommon in rural communities.

The Environmental Impact Statement does not adequately demonstrate:
how a thermal runaway incident would be contained;
how toxic smoke and gases would be managed;
the capacity of local emergency services to respond to a prolonged battery fire; or
whether emergency planning has been fully coordinated with relevant emergency service agencies.

Greater independent assessment is warranted before approval is granted.

Road infrastructure and traffic
Construction activities will generate significant heavy vehicle traffic over many months.

Wine Country Drive and surrounding local roads are already heavily used by residents, agricultural operators and visitors.

Additional construction traffic may:

reduce road safety;
increase travel delays;
damage local road infrastructure; and
adversely affect the tourism industry that is central to the local economy.

The long-term cost of maintaining damaged road infrastructure should also be fully considered.

Environmental impacts
The proposal would remove native vegetation and affect habitat used by threatened species.

The assessment should demonstrate that:

impacts have been avoided wherever possible;
biodiversity losses have been minimised;
cumulative regional habitat loss has been properly assessed; and
offset arrangements genuinely provide equivalent environmental outcomes.

These matters require careful scrutiny before approval.

Rural landscape and amenity
The Rothbury area is valued for its scenic rural landscape and internationally recognised wine industry.

The proposed industrial infrastructure is inconsistent with the existing rural character and may diminish visual amenity for nearby residents, visitors and tourism operators.

The proposed landscaping measures are unlikely to provide effective screening for many years.

Operational noise
Battery cooling systems, transformers and associated electrical equipment may create continuous operational noise.

Additional assessment should confirm that nearby homes and rural properties will not experience unacceptable noise levels, particularly during evening and overnight periods.

Cumulative assessment
Given the proximity of another proposed battery energy storage system, it is essential that the Department assess the combined effects of both developments rather than considering each application separately.

The cumulative impacts on emergency response capability, transport, biodiversity, landscape character and local communities should be fully evaluated before any decision is made.

For these reasons, I respectfully request that the Department refuse SSD-85939708 unless the outstanding planning, environmental and safety concerns are comprehensively addressed.

Thank you for considering my submission.

I fully support this location for a BESS as it seems to be the best use of vacant land ajacent to an existing Substation. The intended Battery Chemistry is very unlikely to be a hazzard to the environment and the visual impacts of the proposed installation will be minor taking into consderation the tree screening of the existing Substation. If these sorts of installations can reduce the need for the smelly and poluting Gas and Diesel fired peaker plants we have been saddled with, it will be a good thing for the health of all of us.

I object to this proposal and I ask the Department to refuse it.
I live in the Cessnock area and I know this landscape. A 135 MW / 540
MWh lithium battery plant on Wine Country Drive does not belong in a
rural, agricultural and tourism valley like Rothbury, and the material on
exhibition does not come close to proving it is safe here. My objection is
unconditional. The points below are all planning matters the Department
has to weigh under section 4.15 of the EP&A Act, in particular whether
this is in the public interest.
The fire risk is real and it cannot be put out. A battery fire of this kind is
not fought and extinguished. The accepted approach is to cool
everything around it and let the batteries burn themselves out over
hours or days. The Victorian Big Battery at Moorabool burned for about
three days in 2021 and was left to burn out. Moss Landing in California
burned over several days in January 2025 and then reignited 33 days
later from energy still trapped in the cells. Both of Australia's grid-scale
battery fires so far, Moorabool in 2021 and Bouldercombe in 2023,
happened during commissioning. Industry incident data shows most
failures happen during construction, commissioning or the first couple of
years of operation, and that around one in four operating systems
inspected had fire-suppression faults. This is a hazard that arrives early
and lingers.
A battery fire poisons the air, and our valley traps it. When these cells
burn they release hydrogen fluoride, hydrogen cyanide, carbon
monoxide and a load of volatile organic compounds. Measured studies
put hydrogen fluoride output at a level that, for a plant this size, runs
into tens of tonnes under a full burn. Hydrogen fluoride is both a
corrosive acid and a systemic poison, and its cruelty is the delay: a
person can feel fine and then develop life-threatening fluid on the lungs
12 to 48 hours later. The exhibited material contains no proper
dispersion model showing where that plume goes over our homes and
vineyards. That matters here more than most places. The Hunter is
channelled by strong north-westerly winds that on hot days push southeast, straight toward Cessnock and the housing. The summer sea breeze
pushes the other way, into the Pokolbin vineyards. The Brokenback
Range traps smoke and drains it back down into the valley, which is
exactly why up to 90% of the 2020 Hunter vintage was lost to smoke
taint. On a still night a toxic plume would just sit here. None of that is
modelled.
The people sent to it get hurt, even when they only contain it.
"Containment" does not mean the crew is safe. At McMicken in Arizona
in 2019, accumulated gas from a battery unit deflagrated when
firefighters opened it to assess it. They were not even fighting the fire.
Nine responders were caught, four career firefighters were seriously
injured, two with traumatic brain injury, and one was thrown more than
70 feet by the blast. Out here the response is our volunteer Rural Fire
Service, and longer response times mean more gas builds up before
anyone arrives, which makes that exact failure more likely, not less. The
material on exhibition does not include a fire and emergency response
plan agreed with Fire and Rescue NSW and the RFS, and it does not
identify a real, independent water supply for a fire that needs enormous
volumes of water over many hours without draining the town supply or
the local water table. Firefighting is already classed by the World Health
Organisation's cancer agency as a Group 1 carcinogen for the people
who do it, and a battery fire piles a concentrated load of toxic metals on
top of that.
This is bushfire country, and summer is when it burns. The site sits on
mapped bush-fire-prone land, and the danger runs both ways. A bushfire
front reaching this plant can drive the cells into thermal runaway, and it
does not even take a flame touching the plant to do it. These cells go into
thermal runaway at around 150 to 190 degrees, and a fire front radiates
heat at levels that rate a building as flame zone from tens of metres
away. A steel battery enclosure with its cooling knocked out, which is
exactly what happens when a bushfire takes the site power, behaves like
a closed oven and can be driven to that runaway temperature by radiant
heat alone, with no flame ever touching it. Going the other way, a battery
fire that burns for hours or days and throws intense radiant heat can
start a grassfire around it. Summer is the sharp end of this, and summer
is also harvest and peak tourist season, so the window of worst fire
weather is the same window when the vineyards are hanging fruit and
the region is full of visitors. This exact area has a hard fire record. In the
2019-20 Black Summer a major blaze ran near Laguna and Cessnock
and our local brigades fought fires across Cessnock, Wollombi and
Laguna; the 154,000 hectare Little L Complex to the west forced
backburning around Broke-Fordwich that threatened the Hunter
vintage, and up to 90% of the 2020 Hunter crop was lost to smoke taint.
In December 2023 three fast-moving fires broke out in a single afternoon
and put Abermain, Kurri Kurri, South Weston and Pelaw Main under
emergency leave-now warnings, with flames reaching fences. Pokolbin
itself has had a major bushfire on Halls Road that forced residents to
evacuate. Dropping a fire source that cannot be extinguished into that
landscape, and then relying on a volunteer brigade to hold it under those
summer conditions, is exactly the scenario the exhibited assessment fails
to deal with in either direction. It does not model a bushfire heating the
cells into runaway by radiation alone, it does not show the separation
distance needed to keep the cells below their runaway temperature
during a flame-zone front with the site power lost, and it identifies no
passive fire barrier that still works once the cooling is dead.
The site is close to species that exist nowhere else, and the report that
measures the damage has to be tested, not taken on trust. This site sits
in and around the range of the North Rothbury Persoonia, a critically
endangered plant whose entire world population is in this one small
locality, of the Central Hunter Valley eucalypt woodland which is a
critically endangered ecological community, of the Hunter Valley Delma
which is an endangered legless lizard, and in Regent Honeyeater and
Swift Parrot habitat. The biodiversity report is the document that is
supposed to measure the damage to these and test it for serious and
irreversible impact. I ask the Department not to accept an indicative
footprint or an assurance, but to check that the exhibited biodiversity
report actually tests the on-site presence of these species and the impact
on them, and to confirm whether this has been referred to the
Commonwealth as a controlled action. For a plant that lives nowhere
else on earth, that is not a detail to sort out after approval.
A battery fire is worse for vineyards than a bushfire. Its smoke carries
hydrogen fluoride and metal particles, and a fire in the pre-harvest or
harvest window could wipe out entire crops across the surrounding
vineyards. The water used to fight it runs off carrying nickel, cobalt,
manganese and fluoride into a catchment that drains to the Hunter River
and the groundwater the vineyards irrigate from. The surrounding wine
and tourism economy is worth around $557 million a year, and the
2019-20 smoke-taint season alone cost roughly $160 million. The
exhibited material does not properly assess either the smoke or the
runoff pathway.
The roads, the two-plant load, and the clean-up bill. Construction runs
heavy vehicles, transformers and battery units over Wine Country Drive,
a tourism and commuter road not built for that load, and the traffic
study ignores that a second battery plant next door (SSD-92914712)
would be doing the same thing at the same time. Together these two
proposals put roughly 255 MW and 1,020 MWh of storage into one small
locality, and neither assessment looks at the combined fire, water, traffic
and noise burden. On top of that, the material secures no real money for
the clean-up. Retired batteries of the chemistry now used cost money to
recycle rather than being worth anything, and if the operator folds, the
community is left with a hazardous, contaminated site and no funds to
clear it.
What I ask. These are not things a few conditions can fix after approval.
They go to whether this is a proper use of this land in the public interest,
and on what has been put on exhibition, it is not. I ask the Department
to refuse SSD-85939708. If it will not refuse, I ask that it defer the
decision and re-exhibit only after a full hazard and toxic-plume
assessment tied to our actual weather, a fire and emergency response
plan agreed with Fire and Rescue NSW and the RFS with a secured
independent water supply, a human-health risk assessment, a genuine
combined assessment of both battery plants together, a final biodiversity
footprint that tests the on-site species and is tested for serious and
irreversible impact, an assessment of the smoke-taint and firewater
pathways to the vineyards and catchment, and secured funding for
decommissioning.

We need developments like this to help with power supply certainty as well as create employment opportunities .

Much Greater Independent Scrutiny is required for this Battery Energy Storage System (BESS) at Wine Country Drive, Rothbury as it represents one of the most significant public health and safety risks associated with this State Significant Development.

The proposal involves an industrial-scale lithium-ion battery installation that introduces hazards fundamentally different from and far more dangerous than those associated with conventional electrical infrastructure. These include:
* thermal runaway;
* prolonged battery fires;
* release of highly toxic combustion products, including hydrogen fluoride;
* lethal smoke and airborne contaminants;
* complex emergency response requirements;
* contaminated firefighting water;
* hazardous battery transport and disposal at end of life.

The Applicant claims to have various management measures to address these hazards. However, reliance upon unproven, experimental technology and proposed controls is not equivalent to demonstrating that worst-case events have been comprehensively assessed or that their consequences are acceptable.
For a development of this scale and hazard profile, independent expert assessment of catastrophic failure scenarios is essential.

Compliance With Standards Is Not Sufficient
Throughout the Environmental Impact Statement, the Applicant relies heavily upon compliance with engineering standards, manufacturer specifications and future management plans.
Compliance with standards is necessary but it is not sufficient.
The Department must be satisfied that reasonably foreseeable catastrophic failure scenarios have been independently evaluated and that the resulting consequences are not harmful in any way to the public or hazardous to our soil heritage, vital water sources and precious biodiversity.
That evidentiary threshold has not been met.

Large-scale lithium-ion battery systems remain an evolving technology. International experience continues to identify new failure mechanisms, operational challenges and emergency response issues despite claimed compliance with engineering standards.

Numerous international incidents have demonstrated that utility-scale battery failures can involve prolonged fires, thermal runaway, toxic gas releases, explosions during emergency response and lengthy site closures.
These events demonstrate that catastrophic failure is a credible planning consideration requiring rigorous independent expert assessment rather than reassurance through management plans alone.

Thermal Runaway Cannot Be Eliminated
No lithium-ion Battery Energy Storage System can eliminate the possibility of thermal runaway.
International investigations have identified numerous initiating mechanisms, including:
* manufacturing defects;
* internal cell failures;
* electrical faults;
* mechanical damage;
* overheating;
* water ingress;
* installation defects;
* maintenance failures;
* software or control system malfunction;
* external fire exposure.

Once initiated, thermal runaway may rapidly propagate between cells, modules or containers despite sophisticated battery management systems.

The relevant planning question is therefore not whether thermal runaway is unlikely.
It is whether the Applicant has demonstrated, through independent evidence, that the consequences of a worst-case thermal runaway event will not pose dangerous public health and safety risks to nearby residents and emergency responders or poisonous impacts for agricultural land, groundwater, biodiversity or surrounding communities.
The Environmental Impact Statement does not adequately demonstrate this.

Fire Behaviour Has Been Underestimated
Lithium-ion battery fires differ fundamentally from conventional fires.
International experience demonstrates that such fires are extremely hazardous and usually:
* burn for many hours or days;
* repeatedly reignite after apparent extinguishment;
* require prolonged cooling operations;
* generate contaminated firefighting water;
* release hazardous combustion products;
* require extensive exclusion zones.

Emergency services have, in numerous overseas incidents, adopted defensive strategies because extinguishment was considered impractical or unsafe.
The Applicant states that emergency procedures will be developed. They themselves need to be present on site to fight these fires themselves instead of poisoning the RFS.
The existence of procedures does not establish that sufficient emergency capability exists to safely manage a prolonged utility-scale battery fire within a rural setting.

Rural Emergency Response Has Not Been Demonstrated
The proposal is located within a rural district where specialist emergency response resources are inherently more limited than those available within metropolitan areas.
The Environmental Impact Statement provides insufficient analysis of:
* hazardous materials response times;
* availability of specialist firefighting resources;
* prolonged deployment capability;
* firefighter fatigue;
* respiratory protection requirements;
* contaminated runoff management;
* inter-agency coordination;
* water availability during drought.

These are practical operational issues rather than theoretical considerations.
The Applicant has not demonstrated that regional emergency services possess the personnel, equipment and specialist training necessary to safely manage a multi-day utility-scale, highly toxic battery incident.
Without that evidence, assertions regarding acceptable residual risk remain unsubstantiated.

Toxic Emissions Require Much Greater Assessment
Thermal decomposition of lithium-ion batteries generates complex mixtures of hazardous gases, including:
* hydrogen fluoride;
* hydrogen chloride;
* carbon monoxide;
* volatile organic compounds;
* particulate matter;
* metal-containing aerosols.

Some of these substances present acute and lethal risks to emergency responders and nearby communities.
The Environmental Impact Statement provides limited assessment of atmospheric dispersion modelling for catastrophic battery failure and gives insufficient consideration to:
* livestock exposure;
* contamination of pasture;
* impacts on agricultural production;
* contamination of water storages;
* deposition of hazardous substances onto soils and vegetation;
* long-term environmental monitoring following major fires.

These omissions represent significant failures in the environmental assessment.

Bushfire Interaction Has Not Been Adequately Addressed
New South Wales regularly experiences severe bushfire conditions.
The proposal therefore requires assessment of interactions between external bushfires and the Battery Energy Storage System itself.
Important questions remain unanswered, including:
* whether radiant heat could initiate battery failure;
* emergency access during simultaneous bushfire events;
* impacts of heavy smoke on electrical systems;
* contingency arrangements if evacuation prevents active management of the facility.

Given Australia's bushfire risk, these matters warrant detailed independent expert assessment.

Water Requirements Have Not Been Properly Evaluated
Utility-scale battery fires may require substantial quantities of water depending upon emergency response strategy.
The Environmental Impact Statement does not adequately address:
* availability of sufficient water during drought;
* onsite emergency water storage capacity;
* capture of contaminated runoff;
* disposal of contaminated firefighting water;
* protection of creeks, farm dams and groundwater.

Routine construction water assessments cannot substitute for comprehensive evaluation of emergency water requirements associated with a prolonged battery fire.

Decommissioning and Financial Liability Remain Uncertain
The proposal assumes battery systems will be safely removed and recycled at the conclusion of operations.
However, significant uncertainties remain regarding:
* ultimate responsibility for removal;
* long-term financial security;
* potential insolvency of future operators;
* availability of domestic recycling capacity;
* hazardous waste transport and disposal.

The absence of a guaranteed rehabilitation/decommissioning bond is totally unacceptable with no
certainty regarding future environmental liabilities.

Independent Verification Is Essential
Throughout the Environmental Impact Statement, confidence is sought through engineering standards, management plans and future operational procedures.
These measures are important.
However, they cannot substitute for independent verification of worst-case public safety and environmental consequences.
Complex industrial systems can and do fail despite compliance with recognised standards.
Responsible planning requires rigorous assessment of credible failure scenarios rather than reliance upon assumptions that all engineering controls will perform as intended throughout the project's operational life.

Residual Risk Has Not Been Adequately Quantified
The Applicant asks the Department to conclude that the residual risks associated with the Battery Energy Storage System are acceptable.
That conclusion has not been justified.
Significant uncertainty remains regarding:
* catastrophic fire behaviour;
* thermal runaway propagation;
* toxic emissions;
* emergency response capability;
* contamination pathways;
* long-term environmental impacts;
* financial liability;
* end-of-life management.

Where substantial uncertainty exists regarding severe, life-threatening consequences, the precautionary principle requires a higher standard of proof via diligent risk research prior to any further plans or approvals being granted.

Conclusion
As the Applicant has not demonstrated, through independent, peer-reviewed evidence, that the proposed BESS can operate throughout its life without exposing nearby communities, emergency responders, agricultural land and the environment to unacceptable risks under reasonably foreseeable worst-case conditions - it must be rejected.

I strongly object to the proposed Battery Energy Storage System (BESS) at Wine Country Drive, Rothbury.
This proposal seeks to introduce a high-risk industrial facility into productive cropping and grazing land and close to a rural community that should not be expected to bear the consequences of a catastrophic battery failure.

The Applicant repeatedly asks the Department to trust engineering standards, management plans and future operational procedures.
Trust is not evidence.

When the potential consequences include thermal runaway, prolonged fires, toxic gas releases, contaminated firefighting water and long-term environmental contamination, the burden of proof must be exceptionally high.
It has not been met.

Around the world, large-scale lithium-ion battery fires continue to expose serious weaknesses in emergency response, environmental protection and long-term contamination management.

Recent events at Moss Landing demonstrate that battery failures can have consequences extending well beyond the facility itself, prompting ongoing scientific investigation into the spread of hazardous battery-related contaminants.
Fire authorities and independent researchers continue to acknowledge significant knowledge gaps surrounding utility-scale battery systems.

If experts are still identifying failure mechanisms and refining emergency response strategies, it is premature to approve another massive BESS on valuable agricultural land in the Hunter Valley.

This proposal places productive farmland, livestock, water resources, biodiversity and nearby residents at unnecessary risk for the life of the project and beyond.
Once contamination occurs, it cannot simply be undone by a management plan.

The Environmental Impact Statement relies heavily on optimistic assumptions about how systems are expected to perform rather than demonstrating how worst-case failures will be safely managed under real-world conditions.

The precautionary principle exists for developments exactly like this—where the potential consequences are severe and the scientific uncertainties remain significant.

The Department should not approve a project that asks the community to accept risks that have not been independently proven to be acceptable.
For these reasons, the Department must refuse consent for the proposed Battery Energy Storage System at Wine Country Drive, Rothbury.

**’Forever Chemicals’ used in Lithium Ion Batteries Threaten Environment, Research Finds | Lithium-ion batteries | The Guardian 14/7/24
https://www.theguardian.com/technology/article/ 2024/jul/14/forever-chemicals-lithium-ion- batteries-environment

**Coastal Wetland Deposition of Cathode Metals from the World’s Largest Lithium-ion Battery Fire" (Moss Landing BESS FIRE)
According to independent Experts this is actually worse than a radioactivity spill.
A lot of this very toxic stuff is not easily located. Whereas, with radioactivity, one needs just a hand-held Geiger counter to locate the pollutant.
https://www.nature.com/articles/ s41598-025-25972-8#Tab1

**Safety of Grid Scale Lithium-ion Battery Energy Storage Systems
“The scale of Li-ion BESS energy storage envisioned at “mega scale” energy farms is unprecedented and requires urgent review. The explosion potential and the lack of engineering standards to prevent thermal runaway may put control of “battery fires” beyond the knowledge, experience and capabilities of local Fire and Rescue Services.
BESS present special hazards to fire-fighters....”
https://www.researchgate.net/publication/352158070_Safety_of_Grid_Scale_Lithium-ion_Battery_Energy_Storage_Systems

**Grid Scale Batteries & Fire Risk
https://static1.squarespace.com/static/656f411497ae14084ad8d03a/t/
66fd2383b56dbc6906390297/1727865736681/Fannon-Batteries.pdf

**Disaster at Moss Landing: The Risk of Battery Storage - YouTube - 16/1/25
https://www.youtube.com/watch?v=xuTaZFQA18E **https://wattsupwiththat.com/2025/02/20/massive-green-battery-plant-catches-on-fire-again-weeks-after-major-toxic-blaze/

**https://localnewsmatters.org/2025/02/13/environmental-tests-reveal-elevated-levels-of-toxic- metals-since-moss-landing-battery-fire/

**https://www.sfgate.com/news/bayarea/article/environmental-tests-reveal-battery-metals- around-20163514.php

**https://www.cbsnews.com/sanfrancisco/news/elevated-levels-heavy-metals-elkhorn-slough- lithium-battery-facility-fire/

**Lithium-Ion Battery Fire Risks & Extinguisher Limitations
1.CSIRO ActivFire® Advisory Note AN-004
CSIRO explicitly states it "has not and will not certify ... that any fire extinguisher can effectively extinguish a Li-Ion battery fire."
Verification Services

**”There is a General Lack of Guidance and Provisions in Building Codes, Standards, and Legislation in Relation to Safety to Address the Potential Risks From These Technologies.
Part of the problem is that we do not yet know enough about their probability of failure, their mechanisms of failure and potential consequences of failure.”
https://www.fire.nsw.gov.au/page.php?id=940

I object to this environmentally destructive plan with its multitude of failures regarding public health and safety, security, affordability and capability, as well as the lack of protection of precious biodiversity.

Conservation of biological diversity is a fundamental element of Ecologically Sustainable Development - which is totally ignored by this horrible, totally disingenuous and unwanted BESS scam that has NO SOCIAL LICENCE whatsoever!!