Shoalhaven Pumped Hydro Expansion Project - Main Works

I am a resident of Jacks Corner Road, Kangaroo Valley and strongly object to this project.
My reasons for my objection are as follows:

1. Loss of quiet enjoyment for my property.
Kangaroo Valley is a quiet, rural town Jacks Corner Road particularly quiet. The proposed works that will be allowed to take place 24/7 for 5 years (in reality closer to 7) will not only mean that I can not enjoy my property outside during the day for fear of dust, noise of construction but also not afford me uninterrupted sleep at night. This is unacceptable.

2. Decimation of Wildlife.
Our wildlife has already had a hard few years with bushfires and then floods. It is already a daily occurrence to see dead wildlife on the side of Bendeela Road and Jacks Corner Road and with the increased traffic from workers/contractors will cause many more deaths. This is unacceptable.

3. Large Scale destruction of Native Vegetation.

4. Impact on Roads
At present, our roads are in a dreadful state. Whilst council endeavours to fix them in a timely manner, it is just not the case. The increase of traffic will cause huge pressure on residents and their vehicles as council will not be able to keep up with the destruction of roads. I refuse to have my rate money go to fixing pot holes that have been caused by the increased traffic from a project that will not provide any benefit to me AND for a private company (that it has been noted will be sold to an overseas investor).

There is no positive impact for this project. The amount of power the expansion will provide would be laughable if this wasn't such a serious matter. This expansion will essentially destroy the lives and livelihoods of the majority of "receivers" - close by residents and it is completely unacceptable.

Please find attached my objection to the planned project.

I am against the proposed Shoalhaven Hydro Expansion project.
Please see the attachment for details of the reasons.
I would like an appointment with the Planning Secretary to discuss this project and seek answers to it’s implementation.
Kind Regards.

Humane Society International opposes the Shoalhaven Hydro Expansion Project (Application no. SSI-10033) construction and operation due to the impacts it will likely have on remnant and regrowth vegetation, threatened species and other wildlife, which we believe have not been adequately addressed and mitigated in the Environmental Impact Statement. Please refer to our attached submission for more information.

I am a resident living very close to the project site, and have a number of concerns with the EIS. My property is used for some of the year as short-term rental accommodation, and hosts a wide variety of wildlife, including numerous families of diverse bird species, as well as livestock. I would like to see more detail provided on the areas outlined below, in order to make a properly informed decision about the suitability of this project for the area.

1. Noise

My primary concern is over the impact of noise on the surrounding residents and environment. The EPA notes this as one of the major impacts of the project, with "disruption to local amenity for users of properties near to construction works due to increased construction noise, dust, and traffic" (see Table 6-52) being of high significance without mitigation, and "possible sleep disturbance due to 24 hour works for tunnelling, resulting in health and wellbeing impacts for individuals" of medium significance.

The standards adopted in the EIS from the EPA to assess acceptable noise levels effectively downplay the actual impact. The lowest category (30-35dB) is louder than typical noise levels (e.g. 20dB); when changes are measured, it should be against actual noise levels, not what is deemed acceptable for other environments.

The estimated levels of noise from the project works will be not only noticeable, but intrusive. Night construction is estimated to be 65 LAFMax dB(A) and construction traffic on the local road to be 50-55 dB(A). The predicted levels of noise cited in Table 6-41 (noting that the level of change is underrepresented) are unacceptable, and will result in a significant decline in amenity for the residents and guests of our property, and cause significant impact on the area's wildlife.

The mitigation offered for these impacts is primarily one-way communication with those affected, which I do not believe is at all sufficient. The works are proposed to last for 2 to 3 years and continue 24 hours a day, 7 days per week. This represents a considerable change to living conditions in the area, which is typically very peaceful. As a minimum, I believe the works should not proceed 24/7, and that a schedule be drawn up in consultation with the community to ameliorate this impact. Further options for noise mitigation should also be assessed, in order to maintain conditions in the area in as close to its current state as possible.


2. Tunnel cross-section and vibration

Please supply more detailed information of the proposed tunnels and accessways, including a elevation cross-section view of the area showing distances to nearby properties. The EIS provides scant detail on the impacts of vibration, addressing only existing buildings but not wildlife or land use. More information is also required on these impacts.


3. Maintenance of roads

I note that Appendix L, section 8 states that a Condition of Approval for the project (TT15) is that the roads remain in the same condition as at project commencement. I do not believe this is sufficient for such a long-running project, as the condition during construction works and not just afterwards is also important. This should be addressed in a detailed plan before the project begins, as the recent degradation of surrounding roads attest, and with multiple owners bearing responsibility for the roads used during construction.


4. Groundwater and subsidence

The EIS notes that further investigation is required for planning of the tunnelling and required tunnel treatments (section 6.4.4.4), and that Kings Creek (beginning nearby and running just to the west of the Bendeela Pondage) forms a part of high and medium potential Groundwater Dependent Ecosystems (GDE - see Figure 6-9). Once subsidence occurs it cannot be reversed, and represents a very high impact risk. Kings Creek is vital to this area: it is our primary source of drinking and irrigation water, and fundamental for wildlife. Given the importance of Kings Creek to the area, the potential impact of the project should be better understood before it commences with zero subsidence and damage to the creek guaranteed.


5. Commercial impact

It is clear from the EIS that usage of surrounding properties will be significantly affected by the project in a number of ways. I was surprised to see that the EIS did not include any consideration of the commercial or financial impact of the construction phase of the project on landholders, particularly given its expected duration. The lessened amenity is noted, e.g. with the project "discouraging people from using local accommodation and wedding businesses" (p.xii), yet there are no options provided for those affected to address this at all. This should be explicitly addressed and options detailed.


6. Alternatives considered

The level of detail about alternatives considered summarised in the EIS (section 2.5) is very low and only accounts for commercial considerations. Other options appear to offer comparable benefits (e.g. power output) but reduced impact on the environment and amenity of the area. For instance, option 4 (expanding the capacity Bendeela Power Station) lists only one 'exclusion driver' as "impact to existing operation" (Table 2-2). Similarly, the 'exclusion driver' to option 6 (new underground shaft from Fitzroy Canal) is simply "Cost of tunnelling vs pipeline construction". These summaries do not provide an adequate analysis of the alternatives, and fail to take into account considerations other than commercial ones. Indeed, the 'alternative configuration 2' to option 5 is not even summarised, although it appears to offer comparable benefits with much reduced impacts on the environment and amenity.

Please provide more detailed analysis for consideration of the alternatives.


Thank you for the opportunity to respond to the EIS, and thanks in advance for your ongoing engagement with the Kangaroo Valley community.

Please find attached objection from with regard to negative impact on Pest Problems Pest Control Pty Ltd.
Bendeela Road based pest control business.

The significant negative impacts on the enjoyment of the natural amenity of Kangaroo Valley and surrounding areas on thousands of people by the 24 hours a day, 7 days a week construction for a period of no less than 5 years for this project is not acceptable. Nor is the environmental degradation of the local environment by the dumping of debris from the construction. Surely the economics themselves do not add up for the additional power that is to be generated. The "green credentials" of this project are extremely doubtful. The consultative period and process leaves a lot to be desired.

I am not a close neighbour of The Kangaroo Valley as I live about six kilometers past the location on Jacks Corner Road.

I am against the Shoalhaven Hydro Upgrade scheme for a number of reasons.

It is clear the completion of the EIS itself was rushed, and driven by a political timescale to fit in with the NSW State Government election. This has led to the mistakes and omissions in the EIS.

The whole project is also being rushed and driven by the need of the NSW government to be seen to be replacing coal fired power stations by 2030.

This project was originally examined by Origin in 2018, but it was shelved due to the excessive construction costs needed to generate only 235 MW of power. The construction costs are now even higher.

It would make much more sense if the NSW government and Origin Energy invested this money into other green energy options such as wind or solar, and leave the Snowy Hydro scheme (6100 MW from 2024) as the state’s “hydro battery.”

The noise, vibration and dust from the construction is going to cause sleep disturbance at night and make it untenable for paying guests staying at adjacent properties and wedding venues.

Construction:
The basic philosophy of using a 24/7 construction phase to reduce the maximum noise levels is fallacious. There is no logic supporting the idea that 24 hour noise is going to make life more pleasant for the locals. It is also logical to assume it would be much more disruptive to the local wildlife. There are vulnerable plant and animal species in the area and there is no planning for mitigation of the effects of this development on this biota.

Kangaroo Valley is a quiet rural area that people from Sydney ‘escape to’ on their weekends. The predicted noise levels from the 24/7 construction are going to severely impact all the immediate neighbours, and are also going to have a detrimental effect on many of the local businesses such as weddings, yoga retreats, canoeing etc.

After the bushfires, then COVID, then 38 individual landslides/ landslips (Ref Shoalhaven City Council) that closed our roads, the 5year construction phase will be the final nail causing the closure of many of these businesses. Also there is no geotechnical support to the notion that identified areas of land slip risk will not be impacted by the vibration and blasting.

The construction noise impacts will also make it impossible to sell these properties.

Construction Techniques.
The chosen technique of drilling and blasting the tunnel entrances is not appropriate for a rural recreational area. As stated previously, the risk of land slips would be greatly magnified by the drilling and blasting.

Mitigation:
Many of the mitigation measures mentioned in the EIS are not real mitigation measures. They are merely ‘paper based’ solutions to seek planning department approval.

If Origin’s contractor cannot comply with the blasting schedule, then Origin will send us an email 5 days prior. The outcome of this arrangement is no reduction in noise levels and gives Origin the opportunity to completely ignore the blasting schedule.

Many of the other ‘concrete’ mitigation measures are either unachievable suggestions, or else not agreed upon and unenforceable. For example, it will not be possible to create a turning circle for the trucks at the KV “underground access portals” / tunnel entrance because there isn’t enough space to build it. Therefore, the suggested ‘turning circle’ as a mitigation measure against truck reversing horns is unachievable.

The suggested mitigation to use vehicles with reversing ‘squawker' or ‘broadband' alarms instead of horns, and machinery with quiet mufflers is only ‘to the extent reasonable and feasible’ - i.e., it is not enforceable.

Noise Levels.
The conclusion in Appendix M, refers to the “establishment of local background noise levels”.

These levels are extremely low and are the lowest of any site that Origin has studied. In one case, (Receiver 14) ambient noise levels were as low as 23 decibels.

“A small number of receivers were predicted to experience noise levels above applicable NMLs (Noise Management Levels). These exceedances are generally expected to be noticeable or clearly audible.”

The alleged mitigation compares these exceedances to standard NMLs, not the actual low “background noise levels” recorded for the EIS.

Even on the figures in the EIS, these exceedances will occur at 62% of the identified receivers.

The actual noise levels predicted (from the lower scheme) during construction increase to at least 46 decibels. The decibel scale is non-linear and it is estimated that local properties would have ambient noise levels 4 times louder than is currently the case.

The EIS also does not correctly account for adverse meteorological conditions, such as a light katabatic wind down flow associated with an inversion. It has merely used a standard formula for the consideration, without making any actual measurements during actual adverse meteorological conditions, to determine what the true value of the noise transfer is. Trucks and motorcycles from 8 km away can be heard under these conditions.

These conditions exist in Kangaroo Valley on many days of the year in any season and are frequently experienced during Spring and Autumn.

During these conditions the noise levels from the upper scheme, will increase the noise levels from the lower scheme, resulting in a noise level, which is at least 8-10 x louder than our local background noise level.
This puts all nearby residences into the Highly Affected band. It is completely unacceptable.

Contradictions & Inaccuracies:
There are many of these littered through the EIS. Some of them are:

1. The noise impact tables relate to the noise levels expected from tunnelling and haulage. The actual construction method to be used to start the tunnel for the “underground access portals” is surface level drill and blasting.
The noise level from this blasting is unaccounted for in the EIS.

2. Origin might have a preference for daytime operations at the upper scheme? The EIS states:

“It is noted that some Upper Scheme works may be required outside standard construction hours including shaft excavation, support and lining activities and concrete pours for anchor blocks and surge tank foundation.”

3. The mitigation control suggested for spoil haulage is
“Consider the use of quieter spoil transport technologies (e.g., conveyors) rather than trucks”
The only plan under consideration at this stage is the use of Trucks.

4. “Consider the installation of temporary construction noise barriers”
The consideration of and then subsequent rejection of a noise barrier suggests a lack of planning and appropriate strategies with regard to noise mitigation. There is also great doubt whether there is enough room to install temporary noise barriers at the underground access portals.

5. “The surface blasting proposed for construction of the Tailrace Inlet/Outlet … is likely to be required and has the potential to result in ground vibration and/or air blast overpressure to be received”. (6.6.1)
The noise from this blasting is not accounted for in the EIS. Nor is the possible effect of ground vibration on local areas at risk of land slip.


In Summary:
The EIS is flawed and needs to be withdrawn. The main reasons are:

The Planning Secretary’s Environmental Assessment Requirements (SEARS) require that the EIS include “the alternatives that were considered to the project”

There is no such analysis in this EIS of other alternatives, such as solar or wind generation. If there had been such an analysis, it is highly likely that it would have concluded that the cost of the Kangaroo Valley upgrade exceeds the benefit of the 235 MW produced.
This is especially the case when Snowy Hydro will have the capacity of 6100 MW and is already our main “Hydro battery.”

SEARS also requires:
“The EIS must be accompanied by a signed report from a suitably qualified expert that includes an accurate estimate of the capital investment value (as defined in Clause 3 of the Environmental Planning and Assessment Regulation 2000)”

Where is it? What is the cost of this expansion? What is the cost/ MW hour and how does it compare to the cost/ MW hour of solar, wind, or the Snowy Hydro?

Noise assessment:

There is no Noise impact table of the total Noise anywhere in the EIS. For example, the oversized heavy vehicle movements (450 of them) are not included in the tunnelling and soil haulage movements.

Even under good meteorological conditions, this could place us in the ‘Highly noise-affected level' of 65 dB(A). Under the adverse meteorological conditions that Kangaroo Valley often experiences, we will often be in this noise level band.

SEARS requires:
“The level of assessment of likely impacts should be commensurate with the significance or degree or extent of impact within the context of the proposed location and surrounding environment.”

The context is a very quiet rural/ recreational area. The EIS has made its assessment against standard Noise Management Levels, instead of the actual very low noise levels recorded.

This is misleading and doesn’t give a true reflection of the impact.

Under Public safety, SEARS requires:
“an assessment of the risks to public safety, paying particular attention to ….the handling and use of any dangerous goods”.

There is no reference to the storage precautions for the explosives. Where are they going to be stored?

1. The basic philosophy of using a 24/7 construction phase to reduce the maximum noise levels is fallacious. It doesn’t take adequate account of the human body’s need for regular undisturbed sleep, at least three nights a week!

2. The EIS has failed to identify all the affected properties (receivers) in their noise impact analysis. At least 1 p

Objection

I object to this project

The objections are contained in the attached.

This is submitted as an objection in total to this project by Linda Obern a resident that lives opposite this proposal

This submission is under the Wisdom Wombat Refuge a wildlife sanctuary opposite the intended project and I oppose this project as its Owner and Occupier.

I am very concerned about the environmental impact of this project. The proposed works will cause substantial damage to the unique fauna and flora of the area. We have already been impacted by bushfires, floods and landslides. This project will increase the already existing pressure on our native wildlife and its habitat.

I previously submitted my objections to the project - SE-51626218.

The objections are in the attached document.

My objections to the project are set out in the attachment.

Please find the attached, I object to the project as the attached submission indicates.
Regards
Paul Obern

We live less than 2000 metres from the existing scheme and the proposed extension. Five plus years of 24/7 drilling, blasting, excavation and heavy vehicle movement will trash the peaceful enjoyment of our home in Kangaroo Valley. The wider impact on resident and businesses will likely be significant and include financial harm as well as mental and physical health decline. The EIS is wholly inadequate and full of subjective conclusions and lacking in current evidentiary data. Mitigation is not seriously explored and in most cases will be impossible. This is a small generation venture that would not be financially viable without taxpayer funding support. There are alternative renewable energy projects that would provide larger capacity, faster transition and more value to NSW and Australian taxpayers. The proponent fails to provide sufficient fact-based answers to serious risks and damaging impacts that this project would cause. The minister should reject this proposal. I have attached my formal submission. Thank you for the opportunity.

I fully support the Shoalhaven Hydro Expansion Development. The expansion project is critical in supporting renewable energy production and securing our electricity supply.