Shoalhaven Hydro Expansion Project - Main Works

I DO NOT SUPPORT THIS PROJECT

REASONS

I am in favour of the need to create sustainable renewable energy. It is essential if we are to decarbonise our economy, but this push to create storage and renewable energy must be done carefully and projects cannot come at any cost. Of most concern to me as one of the founders of the Kangaroo Valley Wildlife Initiative is the unacceptable impact on wildlife, in particular rare and endangered species. These animals have suffered a devastating blow from prolonged drought, from the Black Summer fires, and from flood. Their recovery is precarious and even more uncertain because of continued habitat destruction and climate change. It is simply unacceptable to rush through a project with impacts on these species. Once these populations die, once extinctions occur, there really is no going back, we cannot afford to get this wrong.


An examination of the the Environmental Impact Statement shows it is very seriously flawed and is based on a desktop review, there are not the necessary field studies for the project and it has clearly been put together in a rush to meet the government's timetable to have things ready for the elections.

It provides no adequate protections for endangered species, and it is simply unacceptable to say that these extremely important protections can be left to the developer whose primary concerns are costs, profits and deadlines.

PLATYPUS

Of very significant concern are the platypus populations downstream which were the subject of Australia's only 40 year study of a platypus population. These platypus will probably perish because this project will create a lot of sediment and there is no plan to stop this sediment from entering the platypus habitat. The issue of sediment is vitally important because it impacts fresh water systems and platypus in particular, because their food is invertebrates on the floor of rivers.

GANG GANG COCKATOOS

The fauna management plan says the construction company's ecologist will identify if any Gang-gang cockatoos are nesting and if so they will delay the removal of that tree for three weeks until the fledglings fledge. To suggest that an energy company, working to cost, supply and time deadlines will hold up a project for three weeks every time they happen to notice a gang gang nest is unacceptable. This is inappropriately handing over the survival of a threatened species to private enterprise.

There are so many examples of profit overriding the needs of wildlife that it is essential that the government takes this responsibility. not Origin Energy.

OUT DATE DATA/NOT RELEVANT DATA USED

The EIS does not take into account the landslips, fire and floods we have had, and it depends in many instances on pre-fire data from 2019. The EIS also relies on data that is not directly applicable, for example it uses data from Oakdale which is in a different river system. Five years of vibrations, dust and noise from underground blasting and drilling, and all the truck and personnel movements have not been appropriately assessed in terms of the survival of endangered species and the preservation of important habitat.

IMPACT OF INCREASED ROAD TRAFFIC ON WILDLIFE DEATHS

The Kangaroo Valley Wildlife initiative in conjunction with the Kangaroo Valley Environment Group is currently lobbying authorities to reduce speed limits on Kangaroo Valley Roads because of the unacceptably high roadkill in the area. The addition of so many more trucks and vehicles on narrow, winding, fog-prone roads with inappropriately high speed limits will have a devastating impact on our surviving wildlife. On the INaturalist website our members have logged and documented well over 300 native animals killed in just the past year alone. Each animal that perishes in this way is destroying an ark of DNA so crucial to the survival of so many species. Each animal lost is another blow to the ecosystem which is under so much pressure already.

There is no effort to ameliorate this impact on wildlife. At the very minimum vehicle movements should be limited at night as so many of these species are nocturnal, and speed limits must be drastically lowered and enforced.

MORE TIME NEEDED FOR DETAILLED EXPERT EXAMINATION AND SUBMISSIONS

Because of the rushed and limited time to examine the proposal in detail and the problem of engaging experts to carefully analyse the detail so close to Christmas, I ask that the time to submit a more detailed submission is extended. Political expediency should not govern an issue so crucial to the environment at a time we are facing an extinction crisis. Given the Summer break submissions should be extended to 1 March to allow appropriate time to consider and draft a scientific analysis of the impact of this long and disruptive project.

The EIS is derelict of specific information. It is couched with far too many ‘may’s and ‘might’s to be taken seriously as a well planned document.

The successful tenderer for the works should not be the one to appoint an ecologist to survey the area under consideration, any ecological studies should be done by independent, and suitably qualified people with no attachment to the commissioning company. Oversight of this could be given to the NSWPW, Shoalhaven City Council, or a Body representative of the Kangaroo Valley Community.

Objections to SSI-10033 attached

I am a member of the Kangaroo Valley community and have been a resident for approximately 20 years, up until recently I ran 2 tourism businesses in the valley- now closed as a result of the bush fires of 2 years ago

I am against the Shoalhaven Hydro Upgrade scheme for the following reasons
Please refer to attached document -submission, there is insufficient space in the Your Comments box to accommodate my submission

Please see attachment for comments

To whom it may concern

Re Proposed project to expand Bendeela Hydro by Origin

I write to ask for extended time for submissions about this project.

The reason for this is because there needs to be much more detailed consideration and consultation with experts by our community. We have not had sufficient time for this.

Also, my computer is about to be replaced because it is frequently freezing, making this submission difficult to prepare.

I give a brief summary of some of my concerns which are raised by the Environmental Impact Statement (EIS) relating to this project.

There is no reason to fast track this project. A project of this size and potential impact, in an area where a number of endangered species are surviving, requires somber and serious preparation Extinction is forever.

Christmas time is not a good time to find experts who are available for this sort of assessment.

While there may have been plans in place in the 1970’s to expand this project, at that time the local species were not endangered as they are now.

I am a person who is in strongly in favour of green energy initiatives, but the green credentials of a project must outweigh its negative environmental impacts. In this case that is not clear because the EIS is flawed.

Expert consultants should assist with the preparation of a revised EIS, taking into account the fragile circumstances of the many endangered species that the Atlas of Living Australia and Bionet show are surviving in the project site.

Concerns about the EIS include:
• Consideration of irrelevant data in the recommendations
• Failure to consider relevant matters in the recommendations
• The presentation of glossy “management plans” which are not plans but are simply statement of intent that a plan be made at a later stage eg at construction stage for the Spoils Management Plan, and at the Detailed Planning Stage for the Surface Water Management Plan.

Irrelevant considerations
There are many but I have time to only include a couple.

Irrelevant data includes water samples taken at Oakdale, which is in a different river system, and no evaluation of why that data is being considered nor any indication of the weight it is given in the recommendation.

Soil samples taken in Nowra on the other side of the mountains does not appear to be relevant.
Relevant considerations which have not been included.
Local information and details about our recent major structural events in the valley have not been sought nor considered. There is a clear unfamiliarity with the events or circumstances of the project site.
For instance,
The 40 year Shoalhaven River platypus study was conducted all along the Kangaroo River and Shoalhaven River. https://www.ecosystem.unsw.edu.au/content/rivers-and-wetlands/platypus-conservation-initiative/life-history-and-dynamics-of-a-platypus-population-four-decades-of-mark-recapture-surveys

Nowhere else in Australia has a platypus population been studied in such detail over such a long period. I see no consultation has been made with the University of NSW whose academics conducted that study, to ask advice about management of sediment arising from the project in relation to the very populations they have studied downstream from this project site.

The “Surface Water Management Plan” document refers vaguely to drainage to be put into place at the spoils dumping site, but there is no indication of where or how that drained water will be prevented from eventually entering the river, along with its sediment.

Platypus fed on invertebrates in the floor of rivers. (Diet and dietary selectivity of the platypus in relation to season, sex and macroinvertebrate assemblagesT. A. McLachlan-Troup1, C. R. Dickman1 & T. R. Grant2) Sediment covers the floor of rivers and invertebrates die, and so do platypus when they can’t eat. Sediment also changes the river flow, also impacting platypus survival.

In addition there has been no assessment of the impact this year of the landslip on the mountain and the collapse of a very large portion of the riverflat land into Kangaroo River at the property belonging to the Sydney Bushwalkers. That land is directly opposite the Bendeela Recreation Area, at a narrow part of the river, so it is very close.

No assessment has been made of possible similar river front collapses caused by drilling and blasting vibrations and the extreme climate events we are continuing to experience. There is no assessment of whether the Bendeela Recreation Area is equally unstable and will collapse if there are underground vibrations for years.

No assessment has been made of the effect of underground vibrations on the stability of the land of other riverside properties in the project area.

It would be ironic if the “green“ project was to cause the demise of the platypus which were studied. Given world interest in these 40 million year old monotremes this could cause international outrage.

The Mitigation Strategy document of the EIS says:

A Biodiversity Management Plan (BMP) will be prepared and implemented. The BMP will be prepared by a qualified ecologist and include a plan for implementing, evaluating and reporting on the effectiveness of all mitigation measures outlined in this BDAR, but not be limited to these measures.

That is not sufficient detail for an EIS to be the basis of an evaluation of the viability of the project.

Detailed plans of management and mitigation strategies must be prepared before the project is put to tender and must be included with this EIS at this stage of the assessment of the viability of this project. These detailed plans are relevant considerations and are not included. The delays and considerations required to protect the endangered species will add to the costs and time of this project, and the tenderers need to know these costs ahead of the tender process.

If the detailed planning is left to the successful tenderer, it is highly doubtful that many of the motherhood statements of possible strategies in the EIS “Mitigation Strategies” document will be observed.
Eg at page 5 of
https://majorprojects.planningportal.nsw.gov.au/prweb/PRRestService/mp/01/getContent?AttachRef=SSI-10033%2120221101T021401.362%20GMT
Specific measures to mitigate the impact to individual breeding pairs of Gang-gang cockatoo (Callocephalon fimbriatum) and Glossy Black-cockatoo (Calyptorhynchus lathami) (adults, chicks and eggs) will be confirmed.

The pre-clearing protocol of breeding habitat for cockatoos needs to comprise:
▪ Hollow-bearing potential nest tree(s) is to be clearly identified on construction planning maps
▪ Hollow bearing tree(s) are to be removed outside the breeding season where practicable (April to August and Oct to Jan). …
▪ A pre-clearing protocol will include inspection of the tree to determine if live cockatoos are present and potentially nesting. If nesting cockatoos are present, additional mitigation is to be implemented and could include clearing of identified potential habitat trees outside the breeding season and installation of nest boxes by a suitably qualified and experienced ecologist.

Where nesting is identified as occurring at the proposed time of clearing, the subject trees are to be clearly marked as no-go zones and removal delayed until the chicks have fledged. There is to be no disturbance within 100 m of the tree, and disturbance between 100 -200 m is to be minimised. The removal of the tree must allow time for fauna to vacate the habitat.

Nice sentiments but if a nesting Gang-gang pair is found by the company’s ecologist, work is unlikely to be stopped at that 100 metre site for the three or four weeks that it takes for the fledglings to fledge. Maybe they would do it once, with a lot of publicity. But when the next pair is found would another three weeks be allowed? And the next? I suspect that any ecologist employed by the construction company will be under pressure by the company for them to “not find” the nesting pairs so that costs, time and supply lines will not be delayed.

I saw it happen in the clearing of the 200 year old trees, including huge, native fig trees with masses of crevices and hollows in Centennial Park in Sydney, after the route of the light rail was suddenly changed to go through that part of the park. That was just before Christmas some years ago, and the construction company’s ecologist found only one animal in the 80 trees, so the tree removal went ahead 24 hours a day over the Christmas week.

WIRES rescuers had seen masses of creatures in those trees for years, but had never thought to document them, and it was too late to do so after the fences were put up after the announcement, which excluded access to those trees, and the trees were very quickly removed. Centennial Park staff were also banned from accessing the trees after the announcement of the changed route.

The only way to be sure that such mitigation measures are observed is to prepare the details at this stage of the project, in consultation with experts, and to thus allow the companies to be aware of the possible cost and time blowouts, so that genuine mitigation might be implemented.

This detailed plan information is also necessary to be able to weigh up the viability of the project and its costs, both economic and environmental.

We need actual field studies now, by independent experts, to locate and document hollow bearing trees and their occupants, and to include those findings as considerations to weigh in the EIS evaluation. These should also be included in the tender process to allow the costs and alternatives to be clear for the tenderers. Again, if this is left to the construction companies, there would be strong incentive for construction company’s employees not to find the hollows.

This submission is continued in the attachment

Issue:
The Shoalhaven Hydro expansion project EIS has been rushed through, without proper consideration of the cost/ MW hour, or any consideration of other green alternatives.

This EIS process has been rushed after political pressure was placed on Origin energy, so that the project will be decided upon this month, and announced in January, before the state election in March 2023.

The NSW Planning Secretary’s Environmental Assessment Requirements (SEARS) require that:
‘The EIS must be accompanied by a signed report from a suitably qualified expert that includes an accurate estimate of the capital investment value”

This report is completely missing/absent.

For at least 5 years, the construction process is going to have a detrimental effect on all the neighbours, and many local businesses in Kangaroo Valley.

Background:
The Shoalhaven Hydro expansion project was previously examined by Origin Energy in 2019. It included drilling from several sites to obtain rock samples as part of the assessment.
The project was then shelved, because the cost of the project ($100’s Millions) exceeded the benefit gained from 235 MW of Hydro power.

Comment;

This is an obvious election vote grab due to its WOKE "Green" Agenda label.

The enormous cost, approx $100's millions and the projected workload to achieve the outcomes at a rate of 24 hours a day, 7days a week for 5 years! Versus the slight impact of only benefiting 2.2% of the population of NSW make this project laughable, destructible, intrusive, ridiculous and unfeasible.

We need people with vision not politicians with no foresight, we need to look into FREE ENERGY for humanity eg Nikola Tesla who obtained two patents for his radiant energy devices in 1901 that were able to harness free energy from the sun without wires and was shut down by industrialists who wished to preserve the status quo so they could continue charging everyone for energy, let's do more research into these types of projects instead of destroying the countryside as the only answer, release the patents and lets give people the free energy they deserve!

Recommendation:
1. Make the public aware that the NSW government is pushing through a ‘Green’ Hydro expansion project- because of the upcoming State election.

2. Make the public aware that the Shoalhaven Hydro expansion might increase their electricity charges- rather than reduce them.

3. Call on the Premier and the Planning Minister to delay their assessment, until a more thorough EIS has been completed, which includes;

(i) Objective analysis of the cost/ MW hour compared to other alternatives.

(ii) A complete assessment of the total noise impact on nearby residences and businesses, using “site specific (adverse) meteorological conditions”.

OBJECTION based on attached document

As a landowner, resident and business operator on the site of the proposed Shoalhaven Hydro Expansion project, I am one of the ‘sensitive receivers’ identified in the EIS. I am deeply concerned about the immediate environmental, economic, health and social impacts of this project, of which insufficient research and detail is provided in the EIS.

On behalf of the Kangaroo Valley Environment Group, there is a strong desire to examine this project in more detail, particularly in relation to the impact on sensitive ecosystems along the Kangaroo River. We request an extension to allow further time to make a submission.

I am writing to request elongating the consultation process for proposed upgrades to the Kangaroo Valley Hydro Plant.

The 9th Nov to 6th Dec is not a credible window for the community to digest what is being proposed nor to contribute in an informed response.

Wildwood brings approx 5000 annual overnight guests to the valley who we educate and encourage to engage with other local businesses during their stay. Simply put, we are terrified of what this project could mean for both our forward bookings and potential to attract new customers while purporting to be an eco retreat in Australia’s most beautiful valley.

As a business we are very pro clean energy and by no means trying to stop progress, but I feel let down by Origin and no longer trust them as a custodian of state government money who will act in the interests of NSW citizens. It also seems that the amount of energy the project can supply does not justify the cost (economic, environmental, societal) and that the state's money could be used in more meaningful ways if the NSW government is serious about hyrdo and green energy.

I have spent over 2 hrs in meetings with Origin preparing for the project.
At no point was it disclosed that the planned dump was directly opposite our front gate
Similarly, the fact that up to 340 workers will be using the block, which is surrounded by our land and bush walks we send out guests on 24 hrs a day, 7 days a week
I am extremely nervous for both my current forward bookings which will contest we are not what they signed up for & for decimating any chance of our business bringing in new bookings
My last email asking them directly if these items were the planned case and what their plans for a commercial relationship or plan could be sent 22/11 has gone unanswered.

Origin’s EIS report is dense and vague and certainly no moves have been made to actually help us and other small businesses mitigate circumstances that will more than likely send us bankrupt.

It seems strange to me the government would be willing to subsidize a company like Origin in the States to push to go green but then not help us support, the community in the initiative to do so too.

If slowing the process is not in our current government's interest, who would quite rightly want an environmental win to announce prior to the electoral cycle. I really would ask your help to lobby for appropriate compensation that acknowledges 5-10yr projects of this size will ruin us without help.

By help I mean:
- compensation that recognizes an eco wedding retreat will have to pause the majority of activities until this project, in its current proposed form, is completed.
- seeking assistance in building new roads on the property that would allow us access without having to go past the new proposed industrial sites (office and tip entrance) Origin plan opposite and next to our entrance.
- some coordination with our events and guests - 24 hour 365 day a year carte blanche to operate loudly in the valley, a natural amphitheater feels like it needs review as to why.

We would also like to better understand the overall environmental impact on the area better and

Regards,

Alex Herlihy
Wildwood Kangaroo Valley

Please see attached document.

Hello. I commenced this review being as neutral as I could given I did not know the high level concept or scale of the project prior to reading the Scoping Report and EIS documentation as well as attending the community and public information session held on the Sat 26th November.

However, following the subsequent reading of the Scoping Report and EIS documentation, I have to object to the project and my main concerns I would like to highlight are:

Scoping Report 3.4.7 Timing – hours and years Construction is anticipated to take 36 to 42 months: Comment: This is a highly unlikely timeframe put forward by the consultants given the large scale nature of this project. Yes. I understand this goes into detail in the EIS however to think this could be a 3 year project is naive to say the least

Scoping Report Table 4.1: Options consideration summary: I find it odd that whilst 7 Options were considered, only Option 5 is tabled as having a Value Driver of the Lowest risk / benefit and being min disruption. I would like further information to be detailed in relation to the other 6 Options that were considered. This also had been highlighted in the The Planning Secretary’s Environmental Assessment Requirements (SEARS) require that the EIS include “the alternatives that were considered to the project”

EIS Appendix L. Traffic and transport impact assessment: I have major concerns in relation to the proposed traffic volume given the base data was undertaken in Feb 2019 (almost four years ago). The Kangaroo Valley community have encountered a series of major landslips, landslides and road closures as a result of the weather conditions encountered from Feb/March 2022 = however no reference. I also find it concerning that the paragraph detailed in 9 Conclusion states.........The results of the traffic and transport impact assessment indicate that the construction and operation of the Project is expected to have a "negligible impact" on the performance of key intersections in the study area.
"Approximately 3,700 truck movements including 550 oversize / over mass vehicles; approximately 36,000 truck movements associated with spoil haulage; Approximately 13,700 bus movements associated with workforce transport; Approximately 41,000 light vehicle movements associated with workforce transport…." would be a significant impact and should be detailed so.

Appendix P. Preliminary risk assessment. Reference:
A risk workshop took place on 5 December 2018. A review of the risk register developed through the workshop was carried out in 2022 to reflect concept design changes given the progression of the Project design concept.
However no additional information relating to the significant landslips and landslides that occurred in 2022 has been highlighted. Using the examples of 3.2.25 Seismic events; 3.2.26 Transport; 3.2.27 Vibration; I would have thought that these risks would need updating at the very least.

Overall, I feel that the construction risks and medium term impacts to local residents and the KV Community far outweigh the long term viabilty of this project.

Thankyou for giving me an opportunity to voice my concerns.

SSI-10033
I am totally opposed to this ill conceived, destructive and intrusive project. It is conceptual only and completely lacks detail, particularly during the construction phase, which will go on for 5-7 years! The EIS is flawed. It is based on land use diagrams which are at least 25 years out of date, show NO PRESENT BUILDINGS and completely ignores the fact that in the 50 years since the existing pumped hydro scheme was constructed the rainforest has regenerated and assumes that areas cleared then for construction have no signiicant tree cover.
There will also be another 29.5 ha of native forest cleared, adding further to the loss of biodiversity. This will impact on species such as lyre birds, black cockatoos, wonga pigeons, echidnas, goannas, water monitors, various species of lizard, wombats, terrapins, kangaroos and wallabies which all inhabit this area.
There will be significant and unacceptable impacts on properties in the area – particularly our property (40 Jim Edwardes Place). Though the EIS lacks specific detail, it appears that both the Ventilation tunnel and Multi Access tunnel pass directly through our property and directly under our rental cottage. Given the elevations of the cottage, the exit portal on Jacks Corner and the maximun gradient for mining dump trucks the depth of the tunnel below the cottage will be less than 50 m. The noise generated by these truck movements 24/7 will be completely intolerable and render the cottage uninhabitable during the entire excavation and tunneling process. Our house will also be subject to unacceptable noise and vibration effects 24/7 during construction.
Vague references to mitigation are meaningless without detail of these measures. The establishment of temporary stockpiles will add further to noise and dust pollution.
Tourism will be significantly impacted. Kangaroo Valley was voted as the 6th best holiday destination in Australia in 2019, because of the “beautiful field and mountain surrounds, relaxed slower pace: historic and quaint architecture; exceedingly friendly locals; delicious local produce; great hiking and views.” The Valley has also featured on the TV show “Escape from the City”.
All this beauty and tranquility will be destroyed for a mere 200mW of additional generating capacity, one tenth that of the Snowy 2 scheme!
The proposed project completely ignores technological developments in energy storage which are rapidly changing the economics of alternative storage methods. For example, the South Australian big battery provides the same maximum output (250mW) – stores enough energy to power 30,000 homes for 8 hours and they are now installing a second. Such a system has minimal impact on the environment and can be located anywhere near a high voltage transmission switch yard. Such a system could be operating in less than half the estimated construction time of the hydro scheme, would require minimal disturbance of the environment (could be located near the existing switchyard if it still needs to be in the Valley). Pumped hydro has been around since the 1800’s and has served well but has been overtaken by technology and changing economics.
The project is poorly planned, ill-conceived and woefully lacking in detail.
I wish to repeat my strong opposition to the project
Logan Apperley
40 Jim Edwardes Place
Kangaroo Valley

I am a resident at 439 Jacks corner road, just down the road from the power station. I am very sad to hear this news as it will destroy the beautiful calmness of Kangaroo valley. I am just 13 now but I will be 18 when it's finished and everyday I will have to drive past on the bus being slowed down by road works. I don't understand why someone would do this which in fact is destroying our ecosystem. I am proud to live in Kangaroo valley but if this happens I will be ashamed.

I am a resident at 439 Jacks corner road, about 2 minutes drive from where the new hydro expansion will start. I would hate for this expansion to occur due to the impact it would have on the natural beauty of Kangaroo Valley. I also object due to the high number of heavy machinery it will take to get this project done, and how long it will take to get the project finished.

Please refer to attached submission of concern regarding the project.

Please refer to attached submission of concern regarding the project.