Snowy 2.0 - Main Works

The National Parks Association has provided considered comments on this proposal. These include many of the following points that are clearly objectionable:
The ‘project area’ described in the EIS is 250,000 ha, one third of Kosciuszko National Park and three times the size of metropolitan Sydney. How can a Federal Government have so little concern for one of our iconic national parks?
The EIS seriously understates the full environmental impact on the Park, which, when vegetation clearance, earthworks, dumping and damage to streams and water-dependant ecosystems are included will exceed 10,000 ha.
Even the EIS admits that the Main Works will ‘disturb’ 1,680 ha, clear 1,053 ha of native vegetation and destroy 992 ha of threatened species habitat.
14 million cubic metres of excavated spoil, some of which contains asbestos and/or is acidic, will be dumped in Kosciuszko National Park. Most of the spoil will go into Talbingo and Tantangara Reservoirs, decreasing their storage capacities, with the remainder to go into roads or to ‘landscape’ the park.
Major infrastructure, including the widening and construction of 100 km of roads and tracks are proposed throughout the project area. Some of which will destroy sensitive environmental and geological significant areas. Under normal circumstances these would not be allowed within a National Park, so why under Snowy 2.0?
Two side-by-side high voltage transmission lines for 10 km through the Park, with a 120m wide easement swathe.
Snowy 2.0 requires tunnelling through 27 kms of rock. This will depress the water table in some sections by more than 50 m and have an impact for up to 2 kms either side of the tunnel. This will lead to montane streams and water dependant alpine bogs drying up, further impacting upon vulnerable habitats and native species. It will also lead to a reduction of inflows to Snowy reservoirs and downstream rivers. These river systems are already under threat from feral animals and global heating. Any works that threaten water quality and quantity must be avoided.
Noxious pests and weeds will be spread throughout the Snowy Scheme and downstream, including Redfin Perch (a Class One Noxious Pest) and aquatic weeds. These pests and weeds will be transported from Talbingo Reservoir up to pest-free Tantangara, the Upper Murrumbidgee catchment, and then to Eucumbene and throughout the Snowy Scheme and downstream rivers.
Kosciuszko National Park is one of the most loved and frequently visited Parks in Australia. Snowy 2.0 will put off future visitors by its visual blight on the pristine montane landscape from vantage points over thousands of square kilometres. Who wants to see transmission lines and major civil engineering structures in a natural landscape? And who will want to fish in Tantangara anymore, with introduced pest species?
The EIS contains a totally incomplete and inadequate assessment of alternatives to Snowy 2.0. How can such an environmentally destructive development be proposed without an exhaustive exploration of viable alternatives? Kosciuszko is a National Park, not an industrial park!
Snowy Hydro claims that Snowy 2.0 will benefit the renewable energy sector. Yet, for the next decade or so, most of the pumping electricity for Snowy 2.0 will come from coal-fired power stations, not renewables. Worse still, Snowy 2.0 will be a net consumer of electricity, not a generator, with ‘round-trip’ losses of 30%, plus another 10% for transmission.
Not only is Snowy 2.0 environmental vandalism, it isn’t economic. The original $2 billion cost estimate is now approaching $10 billion, including transmission.
Many other pumped storage opportunities have been identified in NSW with a combined capacity considerably greater than Snowy 2.0. Why were these alternatives, together with batteries and other forms of storage, not explored before proposing construction of such a huge project within a National Park?
Never before has a project of such immense size and environmental destruction been proposed within a National Park.

• The ‘project area’ described in the EIS is 250,000 ha, one third of Kosciuszko National Park and three times the size of metropolitan Sydney.
• The EIS seriously understates the full environmental impact on the Park, which, when vegetation clearance, earthworks, dumping and damage to streams and water-dependant ecosystems are included will exceed 10,000 ha. 
• Even the EIS admits that the Main Works will ‘disturb’ 1,680 ha, clear 1,053 ha of native vegetation and destroy 992 ha of threatened species habitat.
• 14 million cubic metres of excavated spoil, some of which contains asbestos and/or is acidic, will be dumped in Kosciuszko National Park. Most of the spoil will go into Talbingo and Tantangara Reservoirs, decreasing their storage capacities, with the remainder to go into roads or to ‘landscape’ the park.
• Major infrastructure, including the widening and construction of 100 km of roads and tracks are proposed throughout the project area. Some of which will destroy sensitive environmental and geological significant areas. Under normal circumstances these would not be allowed within a National Park, so why under Snowy 2.0?
• Two side-by-side high voltage transmission lines for 10 km through the Park, with a 120m wide easement swathe.
• Snowy 2.0 requires tunnelling through 27 kms of rock. This will depress the water table in some sections by more than 50 m and have an impact for up to 2 kms either side of the tunnel. This will lead to montane streams and water dependant alpine bogs drying up, further impacting upon vulnerable habitats and native species. It will also lead to a reduction of inflows to Snowy reservoirs and downstream rivers. These river systems are already under threat from feral animals and global heating. Any works that threaten water quality and quantity must be avoided. 
• Noxious pests and weeds will be spread throughout the Snowy Scheme and downstream, including Redfin Perch (a Class One Noxious Pest) and aquatic weeds.  These pests and weeds will be transported from Talbingo Reservoir up to pest-free Tantangara, the Upper Murrumbidgee catchment, and then to Eucumbene and throughout the Snowy Scheme and downstream rivers.
• Kosciuszko National Park is one of the most loved and frequently visited Parks in Australia. Snowy 2.0 will put off future visitors by its visual blight on the pristine montane landscape from vantage points over thousands of square kilometres.  Who wants to see transmission lines and major civil engineering structures in a natural landscape? And who will want to fish in Tantangara anymore, with introduced pest species?
• The EIS contains a totally incomplete and inadequate assessment of alternatives to Snowy 2.0.  How can such an environmentally destructive development be proposed without an exhaustive exploration of viable alternatives? Kosciuszko is a National Park, not an industrial park!
• Snowy Hydro claims that Snowy 2.0 will benefit the renewable energy sector.  Yet, for the next decade or so, most of the pumping electricity for Snowy 2.0 will come from coal-fired power stations, not renewables. Worse still, Snowy 2.0 will be a net consumer of electricity, not a generator, with ‘round-trip’ losses of 30%, plus another 10% for transmission.
• Not only is Snowy 2.0 environmental vandalism, it isn’t economic.  The original $2 billion cost estimate is now approaching $10 billion, including transmission.
• Many other pumped storage opportunities have been identified in NSW with a combined capacity considerably greater than Snowy 2.0. Why were these alternatives, together with batteries and other forms of storage, not explored before proposing construction of such a huge project within a National Park?
• Never before has a project of such immense size and environmental destruction been proposed within a National Park.

My name is Ross Anthony Jeffree, PhD, and I appreciate the opportunity to make a personal submission on the EIS for the Snowy 2.0. It is a most confronting project which challenges Australia’s citizens in the preservation of our National Natural Heritage.
I have been a professional environmental scientist for more than 40 years, working in Government, United Nations and the Private Sectors. I was previously Head of the UN Marine Radioecology Laboratory, Monaco, and a Principal Research Scientist within the Environment Division, ANSTO. I was the Manager, Draft Environmental Impact Statement for the Replacement Research Reactor at ANSTO (Australian Nuclear Science & Technology Organisation). I have recently acted as a private Environmental Consultant to the New Zealand Environmental Protection Agency, the Northern Territory Government Department of Mines and Energy, the Independent Surface Water Working Group, Alligator Rivers Region, Northern Territory, Lagoon Creek Resources Pty Ltd and the United Nations in nuclear applications for coastal zone management and research in Asia-Pacific and Central Asia.
I have held diplomatic science positions at the Australian High Commission, London and within the United Nations, Monaco. I was a recipient of the Nobel Peace Prize Certificate which was awarded to the IAEA Secretariat, 2005 and Eureka Sherman Prize for Environmental Research Finalist, 2002. Based on my environmental research publications I was elected as a Fellow of the Australian Institute of Biology, EcoEthics International Union, Royal Geographical Society and Zoological Society of London. Recently, I have been Adjunct Professor & Visiting Fellow, Science Faculty, University of Technology, Sydney. I am currently a Member of the IUCN’s Commission on Ecosystem Management.
My concerns with the Snowy 2.0 Project Proposal
Firstly, the geographical scale of this proposal within a much cherished and frequently visited National Park is enormous. The ‘project area’ as described in the EIS amounts to 250,000 ha, which is all of one third of the Kosciuszko National Park and three times the size of metropolitan Sydney. The EIS actually admits that the Main Works will ‘disturb’ 1,680 ha, clear 1,053 ha of native vegetation and destroy 992 ha of threatened species habitat. Fourteen million cubic metres of excavated spoil, some containing asbestos and/or acidic in nature, will be dumped in Kosciuszko National Park. Most of the spoil will go into Talbingo and Tantangara Reservoirs, decreasing their storage capacities, with the remainder to go into roads or to ‘landscape’ the park. Major infrastructure will include the widening and construction of some 100 km of roads and various tracks are proposed throughout the project area. Some of these will destroy sensitive environmental and geologically significant areas. Under normal circumstances these would not be allowed within a National Park; so why will this National Treasure be so abused?
Two parallel high voltage transmission lines are planned to extend for 10 km through the Park, with a 120m wide easement swathe. The Project will also requires tunnelling through 27 kms of rock. This could depress the water table in some sections by more than 50 m and also have an impact for up to 2 kms either side of the tunnel. This is likely to lead to montane streams and water dependant alpine bogs drying up, further impacting upon vulnerable habitats and already endangered native species. It will also lead to a reduction of inflows to Snowy reservoirs and downstream rivers. These river systems are already under threat from expanding populations of feral animals and global warming. Any works that threaten water quality and quantity will be seriously detrimental to Park values.
The EIS thus appears to seriously understate the full geographical scale of Snowy 2.0 environmental impact on the Park, which will likely exceed 10,000 ha, based on vegetation clearance, earthworks, dumping and damage to streams and water-dependant ecosystems are included.
Secondly, Park qualities are very likely to be further degraded by Snowy 2.0 through the introduction of noxious weeds and pests which will be spread throughout the Snowy Scheme and downstream, including Redfin Perch (a Class One Noxious Pest) and aquatic weeds. These pests and weeds will find their way from Talbingo Reservoir up to the pest-free Tantangara, the Upper Murrumbidgee catchment, and then to Eucumbene and throughout the Snowy Scheme and downstream rivers.
Thirdly, the publicised ‘benefits’ of Snowy 2.0 are highly suspect. Snowy Hydro claims that Snowy 2.0 will benefit the renewable energy sector. Yet, for the next decade or so, most of the pumping electricity for Snowy 2.0 will come from coal-fired power stations, not renewables. Even more damning, Snowy 2.0 will be a net consumer of electricity, not a generator, with ‘round-trip’ losses of 30%, plus another 10% for transmission. This coming decade is a critical period in terms of the IPCC’s (Intergovernmental Panel on Climate Change) recommendations for rapid reductions in carbon emissions, in order to avoid the worst effects of climate warming and disruption. We do not need an enormous project which will further enhance Australia’s carbon emissions over the coming decade. Moreover, Snowy 2.0’s costing is continuing to blow out; the original $2 billion cost estimate is now approaching $10 billion, including transmission.
Fourthly, alternative pumped storage opportunities have been identified in NSW with a combined capacity considerably greater than Snowy 2.0. These alternatives, together with batteries and other forms of storage, should have been explored in the EIS before proposing construction of such a project of immense size and environmental degradation within a highly cherished National Park.

In summary, I am extremely surprised and disappointed that the Government would have the gall to even propose such a Project which would jeopardise the environmental and national heritage of one third of one of our National Natural Treasures. May I remind Government that a National Park is not an undeveloped site waiting for a business opportunity! Is the Government seeking with this cynical Project proposal a sullied environmental reputation comparable to Brazil and its ‘economic development’ of the Amazon?
Snowy 2.0 attempts to solve the National environmental crime of carbon emissions in exceedance of our commitment to the Paris Accord, by committing another environmental crime to this and future generations in the gross degradation of the Kosciusko National Park.

Surely as Australians we are better than this and future generations deserve much better than this!

Dear people
I am concerned about the adverse environmental consequences of this project, but expect these will be acceptable in the long term given the claimed benefits for the country's energy system. One has to wonder whether Snowy 1.0 would ever have happened if it had to satisfy existing environmental regulations! My concern is about the economic viability of this project compared to the numerous other options available for smoothing of the rapidly increasing supply of intermittent renewable energy.

I have just read an article by Dr Bruce Mountain in "The Conversation" that comprehensively debunks the economic claims made for this project. No doubt you have also read it, but for completeness it can be found at...
http://theconversation.com/snowy-2-0-will-not-produce-nearly-as-much-electricity-as-claimed-we-must-hit-the-pause-button-125017
In summary, Dr Mountain's conclusions are...
* at most the scheme could only produce about 170GWh of energy, compared to the claimed 350GWh, due to the relative sizes of the storage dams at the top and bottom
* Due to the imperative to retain water in the dams for other purposes, the amount of storage available will be further reduced, possibly to as little as 40GWh in the long term - less than 1/9th of the originally claimed capacity
Add to this...
* the cost estimate for construction has more than doubled, and given the nature of such projects, is likely to keep on increasing
* the expected time until completion is many years later than originally estimated
* the huge cost of extra transmission networks required to supply and dispatch power to and from the project
* the high level of energy lost to friction in the pipes and inefficiencies in the pump/turbines and transmission. Losses are estimated to be at least 40%

...must make this project vastly more expensive per GWh than all the alternative energy storage options, such as...

* any number of smaller pumped hydro systems that could be constructed on sites identified by an ANU study
(https://energy.anu.edu.au/research/highlights/anu-finds-22000-potential-pumped-hydro-sites-australia)
* battery storage, that can be built in a fraction of the time and at convenient locations within the existing transmission grid, at much lower and ever decreasing cost per GWh, as well as being far more efficient.

I have searched but been unable to find any refutation of Dr Mountain's calculations. If such a document exists, could you please provide me with details.

I await your response with interest.

Peter Youll

The NPA has provided a good summary of publicly available information on Snowy 2.0.
It looks very much like the NBN in how it is being set up.
While I support action on stored energy, there are a multitude of smaller pumped hydro opportunities distributed across Australia which allow development improvements with experience.
I am also intrigued by the underutilisation of Tumut 3 and this should be explained.

I make my submission in the attachment

See attached letter

To whom it may concern,

I support this project and encourage the development of many more hydro electricity projects throughout Australia. Effective and efficient transition to a renewable energy future requires energy storage created by projects like Snowy Hydro 2.0. I look forward to it's timely completion and the vital role that Snowy Hydro 2.0 will play in helping to manage variable energy supply from renewable.

I also encourage the development of hydro electric dams in Tasmania and the installation a new electrical cable linking Tasmania with the main land. Combined, the snowy mountains and Tasmania will provide significant and effective energy storage for a renewable Australia.

Regards,

Ashley

There was an error in our previous submission. The attached letter replaces the first submission.

Snowy 2.0 does not stack up either environmentally or economically.
The EIS states that the Main Works will ‘disturb’ 1,680 hectares, clear 1,053 hectares of native vegetation and destroy 992 hectares of threatened species habitat.
Major infrastructure, including the widening and construction of 100 km of roads and tracks are proposed throughout the project area. Some of which will destroy sensitive environmental and geological significant areas. Under normal circumstances these would not be allowed within a National Park.
Alternative options need to be fully examined and assessed.
Snowy 2.0 will be a net consumer of electricity, not a generator, with ‘round-trip’ losses of 30%, plus another 10% for transmission.
The original $2 billion cost estimate is now approaching $10 billion, including transmission. What will the final cost be and what is the true cost / benefit of this project?

I support the project.
The efficiency of using two existing dams to create a pumped storage system without the cost of new dams is to be commended.
The corporate knowledge that Snowy Hydro has garnered through the operation of Tumut 3 power station, Talbingo and Jounama storage's as pumped storage since 1973 would inform the decision making process to invest.
There is an urgency to build a large scale electricity storage system.
Solar generation is obviously restricted to daylight hours and wind generation is variable.
From the Aneroid Energy site the variability of wind generation is plain to see.
Wind generation through September 2019 was below 10% of maximum five times during the month.
This is a problem that will increase as a positive Southern Annular Mode appears to have pulled the southern hemisphere high pressure band further south reducing the wind resource.
There are a number of hypotheses why this has occurred but it appears to be set in for an extended period of time.
What inconvenience is caused by construction of the tunnels, powerhouse , power lines and ancillary structures is more than out weighed by the benefits of smoothing the output of renewable electricity generators and provide reliable power to consumers.
As the requirement for electricity is set to increase (Electric vehicles, population growth in high density housing vs reduction in manufacturing) and the unlikelihood of either nuclear power stations or new coal fueled power stations being built there is an urgency for electricity storage to be created.
I commend the project.

As a long term resident and landholder in the Adaminaby area, I am greatly concerned about the magnitude of the proposed Snowy 2.0 project.
We are a farming family whose property is bordered by the national park to the west and the Murrumbidgee to the east. The potential for both of these natural resources to be greatly affected by this massive development has practically gone unanswered. We have had no direct contact from Snowy Hydro and there is no information about any potential impacts on the flow, fish stocks, pest invasion to the Murrumbidgee, below Tantangara dam.
As neighbouring landholders and tourism operators our livelihood could be greatly reduced if there are any negative impacts to the river.

Also as a long term resident and community member of Adaminaby I am very concerned about the potential negative economical and social impacts on our town.
Already house and property prices have increased, with no discernible reason, beside speculation about the project. Its almost impossible to find long term rental accommodation and return tourist are finding short term rental rate increases. Tourism is the mainstay of the Adaminaby economy and if Selwyn Snowfields along with the fishing streams, rivers and lakes are restricted and fundamentally changed, then people will not visit our town, they will go to others areas of the state that are not being developed and restricted.
Below is a list of all my concerns with the proposed project.
- The 400 odd heavy vehicles travelling on the Snowy Mountains Hway and through Adaminaby everyday. (The noise, increased risk of accidents, the wear and tear on the road.)
- The negative social and economic impacts on Adaminaby and the surrounding villages. (increased land prices, no new jobs, less tourism)
- The destruction of the Tantangara Dam foreshore and plateau. This is an area of great significance to visitors to the park.
- Development in a National Park ( The fact that 100% of this project is being undertaken in a environmentally significant area (eg National Park)
- Waste dump of material along the Tantangara foreshore and water quality of Tantangara .
-The spoil being pushed into the side of the dam on the western side (below maximum lake level) potentially reducing the size of the reservoir.
- Impacts on fish stocks in Tantangara, Murrumbidgee and Eucumbene
- Invasive fish species in the waterways therefore severely affecting our fishing economy and polluting our waterways
- The monumental amount of tax payers money being spent on a project that has a very real possibility of being redundant in 10 years due to the increased take up of renewable energy generation projects and advances in battery and renewable technology
- The fact that coal fired power stations will be used to pump the water back up the hill
- The likely hood that power prices will not go down at all
- The closure of designated horse camps along Tantangara road.
- Access to Currango and old Camp Site
- Possibility of restricted access throughout the park - (this could last the entirety of the project, which at this stage is about 5-7 years, would likely be longer)
- Lack of access to mountain huts for conservation and maintenance works
- Potential impact of work required to upgrade the transmission network for Snowy 2.0;
- Boating, fishing and camping on and around Tantangara
- Access to the mountain rivers and streams
- The potential for the waterways flowing in and out of Tantangara to be compromised
- a 500 person campsite at Tantangara, complete with water treatment plant, accommodation etc.
- That there was not enough information publicly available about the true impacts of the scheme
- That multiple approvals would be sought for different components of Snowy 2.0;
All the community consultation / surveys were not wide spread enough to hear peoples true and valid concerns.
To say community consultation is mostly positive when people do not have the full picture is absurd

I am a supporter of this project. Since this great project is receiving criticism for damaging large area around Lobbs Hole, one way of reducing the damaging impact is by not constructing accommodation camps for workers at Lobbs Hole which will result in environmental adverse impact but accommodating them in nearby towns like Talbingo, Adimanaby etc.
Will be good both for project and environment.

I am shocked that the current government proposes to go ahead with the Snowy 2.0 project, in its current form. I perceive it to be unconscionable. The Environmental Impact Statement (EIS) for the Main Works phase of the Snowy 2.0 project, released on 26 September 2019, proposes immense and permanent damage to the rare montane habitats of Kosciuszko National Park.
I oppose the Snowy 2.0 project, in its current form and strongly urges everyone concerned about Australia and Australian National Parks, the unique flora and fauna of Kosciuszko National Park and the principle that National Parks are for conservation, not commercial development, to oppose this project.
I am not opposed to pumped hydro storage. There is no question that additional electricity storage capacity is needed as renewable generation expands. However, this doesn’t mean that pumped hydro projects require any less scrutiny than any other construction projects, especially when they are proposed in one of the most precious and delicate parts of our nation. The EIS contains an incomplete and inadequate assessment of alternatives to Snowy 2.0. How can such an environmentally destructive development be proposed without an exhaustive exploration of viable alternatives?
Snowy 2.0 is the wrong project in the wrong place. The case for Snowy 2.0 simply doesn’t stack up environmentally or economically. There must be better alternatives. Due diligence needs to be applied. Other more economical options should be explored, thoroughly evaluated and considered to avoid the catastrophic impacts on Kosciusko National Park at poor economic benefits to Australia and the Australian taxpayers.

See Attached File

See attachment

Dear Sir/Madam, I was a member of the National Parks Association (NPA) for about 10 years from 2007 to 2017. I still receive their emails and notifications. Often I support their submissions regarding the environment. However, I recently received an invitation from the NPA to make a submission regarding Snowy 2.0. I strongly support Snowy 2.0 and reject most of the NPA objections. I think that, in this case, the NPA is being narrow minded and that in t\his case, the NPA fails to see the big picture. The replacement of fossil fuel based electricity generation with intermittent renewable energy such as solar and wind requires the addition of significant energy storage. Pumped storage is by far the most effective and proven method of storing large amounts of energy.

Department of Planning, Industry and Environment
Major Projects Team
Attention: Anthony Ko
30 October 2019

Submission on Snowy 2.0 Main Works Environmental Impact Statement

I wish to indicate our strong opposition to the Snowy 2.0 project as described in the Main Works Environmental Impact Statement (EIS). The scale and intensity of environmental impact described in the EIS is inappropriate in any sensitive sub alpine region, let alone Kosciuszko National Park (KNP), one of our nation’s most iconic, National Heritage Listed national parks.

In addition to the unacceptable environmental impacts on KNP, the fractured assessment process seems designed to conceal the catastrophic extent of environmental impacts and there is a district lack of credible consideration of less expensive, lower impact alternatives.

Claims about energy storage potential are dubious and the excessive cost will be paid for by the Australian public, the ultimate owners of the Snowy Hydro scheme.

These failures clearly demonstrate that the Snowy 2.0 project does not meet the standards required of Environmentally Sustainable Development and accordingly the project should be refused by the Minister for Planning.

The project is of vast scale and the quantity of documentation makes it very difficult to address all my concerns. Issues of particular concern are described below:

Environmental impacts

The EIS repeatedly asserts that the Snowy 2.0 project will have a minor impact on KNP on the basis that the development footprint represents approximately 0.25% of the total area of the park. I consider this assessment to be utterly incorrect for the following reasons:

• The “Project Area”, as depicted in the EIS, covers approximately 50 km by 50 km (250,000 hectares), which is a third of KNP - an area twice the size of Greater Sydney.
• While KNP is one of the largest National Parks in NSW (690,000 hectares), the portion containing sub-alpine habitats, the areas to be destroyed by Snowy 2.0, is much smaller. This sub-alpine area has some of the rarest habitat in Australia, and will prove increasingly important for the retreat of alpine species affected by the heating climate. These rare habitats provide the appropriate context for assessing the adverse environmental impacts of Snowy 2.0, not the lower altitude landscapes that characterise the majority of KNP.
• This construction will be largest proposed loss of critically important habitats in a NSW National Park. The EIS acknowledges that the construction footprint will ‘disturb’ 1,680 hectares, clear 1,053 hectares of native vegetation, and destroy 992 ha of threatened species habitat (threatened fauna, threatened flora and Threatened Ecological Communities). The construction footprint acknowledged in the EIS substantially understates the full extent of permanent damage outside the heavy construction zones, including Talbingo and Tantangara Reservoirs, 100 kms of new and upgraded roads, 10 kms of transmission lines with a 120 metre-wide easement swathe, ground water depleted areas above the tunnels, construction camps (for 2,100 workers) and multiple works areas. When all these areas are taken into account, Snowy 2.0 will permanently damage more than 10,000 ha of KNP (1,000 square kms), rather than the claimed 1,680 ha.
• No development of this scale or intensity is appropriate in the sensitive habitats of a declared conservation reserve. The issue should not be whether the impacts of a proposal of this scale and intensity can be ‘mitigated’, offset or otherwise approved under the Environmental Planning and Assessment Act framework. On the contrary, such a proposal simply should not be contemplated in an internationally renowned conservation reserve in the first place.
The project requires tunnelling through 27 kms of rock, large scale quarrying, road building and widening and the establishment of large accommodation and construction sites. The EIS does not provide a credible account of how 14 million cubic metres of spoil, some of which is heavily contaminated by asbestos and acidic compounds, can be disposed in KNP without further significant environmental impacts. It is clear that much of the excavated materials will be used in ‘landscaping’ works that will further exacerbate the damage to the Park. Unbelievably, over 8 million cubic metres is to be dumped in the active storage areas of Talbingo and Tantangara Reservoirs, depleting their capacities. How could approval be given for anyone to dump waste material, some of which is contaminated, in a National Park, let alone 14,000,000 m3 - enough to cover a football field to a height of 3 km?

The EIS describes extensive impacts on water dependant habitats and species through disruption to ground water systems by the tunnelling as well as in works beside 8 kms of the Yarrangobilly River.

Watertable drawdown is predicted to be in excess of 50 m above the tunnel in areas of high hydraulic conductivity (Gooandra Volcanics). The drawdown at 3 km either side of the tunnel is still 0.5 m in the western plateau. This will have a catastrophic impact on the environment along sections of the 27 km tunnel, will dry up existing creeks, impact the local fish and animals and reduce inflows to the reservoirs and hence water releases.

It is remarkable that Snowy Hydro would show such disregard for the protection of water dependant ecosystems not just in alpine areas but at the headwaters of our major waterways. I/we do not accept the assertion that such impacts are ‘acceptable’. Experience demonstrates that once ground water systems are disrupted by mining activities the damage is irreversible and can become even more extensive over time.

Snowy 2.0 will disperse pest species (including redfin perch, eastern gambusia, wild goldfish, Epizootic Haematopoietic Necrosis Virus (EHNV) and elodea weed) throughout the waterways of KNP and downstream. Redfin is a Class One Noxious Pest - it is illegal to transfer Redfin between waterways in NSW. Snowy Hydro acknowledges that it is inevitable that noxious species will be transferred from Talbingo to Tantangara. Establishment of the dominant Redfin Perch will be to the detriment of both recreational anglers and significant populations of threatened native fish.

Even worse than it being accepted that these noxious species will be transferred to Tantangara, it is highly doubtful that the barrier and filtration systems proposed by Snowy Hydro will stop their eventual transfer downstream to the Murrumbidgee River and Lake Eucumbene and thence throughout the rest of the Snowy Scheme and downstream rivers (Snowy, Murrumbidgee and Murray).

One of KNP’s core values is the sense of wilderness and solitude unique to alpine landscapes. These aesthetic qualities, and the experience of visitors, will be seriously diminished by the increases in roads, permanent large structures and especially the transmission lines. The project will not only impact directly on the areas trashed by the project - the overall sense and experience of the Park landscape will be damaged forever. The implication in the EIS that the community will regard the proposed infrastructure as evidence of the nation’s engineering prowess offers hollow recompense for the loss of the Park’s unique aesthetic qualities.

Minimal contribution to renewable energy

Snowy Hydro claims that Snowy 2.0 will play a pivotal role in stabilising the national energy market as new renewable generation is added to the grid. I/we don’t not accept that such claims justify the extent and severity of environmental destruction that the project will cause to KNP, especially in the absence of a credible assessment of alternative ways of providing this service. In any case, the data provided in the EIS seriously undermines the claimed benefits of the project. Specifically:
• Snowy 2.0 will be a net consumer of electricity, not a generator, with ‘round-trip’ losses of 30%, plus another 10% for transmission.
• For the next decade most pumping electricity will come from coal-fired power stations, not renewables, belying the claim that Snowy 2.0 will ‘store’ electricity from renewable generators.
• The claimed 350 GWh would only be available in the most exceptional of circumstances, requiring the top reservoir (Tantangara) to be full. If the full volume was used, at least one-third of the water couldn’t ‘fit’ within the smaller capacity of the lower reservoir (Talbingo) and would be discharged to Blowering and ‘lost’ to the Snowy 2.0 system. If Talbingo were not empty (historically it is kept near full to provide for operation of the Tumut 3 pumped hydro station), then most of the water from Tantangara would be discharged to Blowering and ‘lost’ to Snowy 2.0.
• The practical recyclable capacity of Snowy 2.0 is considerably less than the claimed 350 GWh.
• Whenever Tantangara were emptied, it would then require several months of pumping to be returned to full supply.
• If Snowy 2.0 ever generated its claimed 350 GWh of energy, it would take 500 GWh of pumping energy to re-charge, incurring 150 GWh of losses.

Uneconomic

It is clear that the cost of Snowy 2.0 will be greater than the original $2 billion and then $3.8 billion estimates – a single contract for $5.1 billion has recently been awarded. It is likely that the project, including transmission, will be $10 billion, or even more. At anything approaching this amount the project is totally uneconomic.

Snowy Hydro is owned by the Commonwealth Government, hence the Australian community. The ultimate bearers of the risk of Snowy 2.0 are the Australian community.
In addition to its shareholding the Commonwealth increased the commitment of public funds through a $1.38 billion subsidy into the project.
I and my family are deeply disturbed by the disregard for the intrinsic values of the park that are reflected in this proposal.
Sincerely

M Hughes

The case for Snowy 2.0 simply doesn’t stack up on environmental or economic grounds. There are better alternatives, ones that avoid catastrophic impacts on Kosciusko National Park.

I object to the main works proposal for the snowy 2.0
I am shocked to learn that this project intends to damage the Kosiusko National Park. I feel that Australians have been misled into thinking that this project was only about using excess power to pump water higher up into the snowy dam as a way of turning the dam into a battery. This proposal is nothing like that yet there as been months of talk and celebration about this idea as a brilliant way of storing energy.

I also object on the following grounds:

The ‘project area’ described in the EIS is 250,000 ha, one third of Kosciuszko National Park and three times the size of metropolitan Sydney.
The EIS seriously understates the full environmental impact on the Park, which, when vegetation clearance, earthworks, dumping and damage to streams and water-dependant ecosystems are included will exceed 10,000 ha.
Even the EIS admits that the Main Works will ‘disturb’ 1,680 ha, clear 1,053 ha of native vegetation and destroy 992 ha of threatened species habitat.
14 million cubic metres of excavated spoil, some of which contains asbestos and/or is acidic, will be dumped in Kosciuszko National Park. Most of the spoil will go into Talbingo and Tantangara Reservoirs, decreasing their storage capacities, with the remainder to go into roads or to ‘landscape’ the park.
Major infrastructure, including the widening and construction of 100 km of roads and tracks are proposed throughout the project area. Some of which will destroy sensitive environmental and geological significant areas. Under normal circumstances these would not be allowed within a National Park, so why under Snowy 2.0?
Two side-by-side high voltage transmission lines for 10 km through the Park, with a 120m wide easement swathe.
Snowy 2.0 requires tunnelling through 27 kms of rock. This will depress the water table in some sections by more than 50 m and have an impact for up to 2 kms either side of the tunnel. This will lead to montane streams and water dependant alpine bogs drying up, further impacting upon vulnerable habitats and native species. It will also lead to a reduction of inflows to Snowy reservoirs and downstream rivers. These river systems are already under threat from feral animals and global heating. Any works that threaten water quality and quantity must be avoided.
Noxious pests and weeds will be spread throughout the Snowy Scheme and downstream, including Redfin Perch (a Class One Noxious Pest) and aquatic weeds. These pests and weeds will be transported from Talbingo Reservoir up to pest-free Tantangara, the Upper Murrumbidgee catchment, and then to Eucumbene and throughout the Snowy Scheme and downstream rivers.
Kosciuszko National Park is one of the most loved and frequently visited Parks in Australia. Snowy 2.0 will put off future visitors by its visual blight on the pristine montane landscape from vantage points over thousands of square kilometres. Who wants to see transmission lines and major civil engineering structures in a natural landscape? And who will want to fish in Tantangara anymore, with introduced pest species?
The EIS contains a totally incomplete and inadequate assessment of alternatives to Snowy 2.0. How can such an environmentally destructive development be proposed without an exhaustive exploration of viable alternatives? Kosciuszko is a National Park, not an industrial park!
Snowy Hydro claims that Snowy 2.0 will benefit the renewable energy sector. Yet, for the next decade or so, most of the pumping electricity for Snowy 2.0 will come from coal-fired power stations, not renewables. Worse still, Snowy 2.0 will be a net consumer of electricity, not a generator, with ‘round-trip’ losses of 30%, plus another 10% for transmission.
Not only is Snowy 2.0 environmental vandalism, it isn’t economic. The original $2 billion cost estimate is now approaching $10 billion, including transmission.
Many other pumped storage opportunities have been identified in NSW with a combined capacity considerably greater than Snowy 2.0. Why were these alternatives, together with batteries and other forms of storage, not explored before proposing construction of such a huge project within a National Park?
Never before has a project of such immense size and environmental destruction been proposed within a National Park.

Sincerely,
Charlotte McCabe