Snowy 2.0 - Main Works

The closing of Tantangara Rd for an extended period of time, will significantly affect land owners, business, tourists may and users of the Park. There must be a better way to take account of those greatly affected.

As per our attached submission, the Nature Conservation Society of South Australia objects to this project due to the unacceptable impacts on Kosciusko National Park and because there has been inadequate consideration of less expensive, lower impact alternatives.

See attachment

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

5 Nov 2019

Submission on Snowy 2.0 Main Works Environmental Impact Statement
I wish to indicate my 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 Kosciuszko National Park (KNP), one of our nation’s most iconic, Heritage Listed national parks.
In addition to the unacceptable environmental impacts on KNP, the fractured assessment process conceals the catastrophic extent of environmental impacts with is a 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 alone 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. However, issues of particular concern are:
* 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. However: 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; This construction will be the largest ever 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 (100 square kms), rather than the claimed 1,680 ha.
* 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. Unbelievably, over 8 million cubic metres is to be dumped in the active storage areas of Talbingo and Tantangara Reservoirs, depleting their capacities and risking serious contamination.
* The EIS describes extensive impacts on water-dependent 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-dependent ecosystems, not just in alpine areas but at the headwaters of our major waterways. I 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 these noxious species will be transferred from Talbingo to Tantangara. It is also 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 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 do 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 or so 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.
• 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 many times 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 more. At anything approaching this amount the project is totally uneconomic.
Snowy Hydro is wholly 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. Why was this necessary and why is the Commonwealth Government playing favourites in the National Electricity market?
Flawed planning and approval process: The Main Works EIS is only part of the assessment of the broader Snowy 2.0 Project.
It is over 2½ years since Snowy 2.0 was announced (March 2017). Over the intervening period the Snowy Hydro Board has authorised the Final Investment Decision, the Government has approved the project and kicked in $1.38 billion, a $5.1 billion contract has been awarded, construction commenced 8 months ago (February 2019) and major equipment is being ordered. Yet, the Main Works EIS has only just been released and the EIS for the high voltage transmission lines is yet to come.
The effect of this incremental planning and assessment process denies the community a holistic view of the scope and impacts of Snowy 2.0. This approach compromises transparency from both a proposal and assessment perspective and can only be seen as designed to obscure the full extent of environmental impact on KNP.
The Environmental Planning and Assessment Regulation 2000 has not been upheld and the project must be put on hold until such fundamental information is provided.
The EIS makes multiple references to mitigating the impacts of Snowy 2.0 through promising future plans and works in consultation with NPWS or through formal offsetting processes. No appropriate offsets for the habitats that would be destroyed by Snowy 2.0 could be provided, given that all of the comparable alpine and subalpine areas are already included in KNP.
The Snowy 2.0 project, as described in the Main Works EIS, does NOT meet the principles of Ecologically Sustainable Development as mandated in the Environmental Planning and Assessment Act.
I provide this sincerely, and in fear for our children's futures

I am absolutely furious that this project is allowed to go ahead in the only alpine region of Australia.
What’s the point of having heritage listed national parks if developments such as this are allowed in them.
I have been a cross country skier and bush walker in the KNP since the early 1980s and the proposed destruction makes me incredibly sad.
The billions of dollars allocated for this inappropriate development should be used to rid the park of feral animals and restore and protect it.
This is project is VANDALISM. See below for more details :
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/our concerns about the project. 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/we 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 ever 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 (100 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 these 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.

I am generally supportive of the project as a means to provide on-demand electricity to SE Australia. However, I have a few concerns relating to the threats to threatened fish introduced by the proposed works. Some of the mitigation measures need more detail, further justification and potentially reconsideration.

Please see attached PDF document which details my comments.
Thank you

5 November 2019
Submission on Snowy 2.0 Main Works Environmental Impact Statement
I SUSAN STEGGALL wish to indicate my 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 appears, to me, to be excessive for 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 assessment process seems designed to conceal the full extent of environmental impacts. In my opinion there is a lack of credible consideration of less expensive, lower impact alternatives.
Claims of energy storage potential need spelling out, especially if the excessive cost is to be paid for by the Australian public, the ultimate owners of the Snowy Hydro scheme.
It would seem that the Snowy 2.0 project does not meet the standards required of Environmentally Sustainable Development and accordingly the project, in its current form, 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 about the project. Issues of particular concern are described below:
• 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 have been told that this assessment is 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 , 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.
• This construction will be largest ever 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. 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 (100 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. Such a proposal simply should not be contemplated in the first place, in an internationally renowned conservation reserve in the first place.
The project requires tunnelling through 27 kilometres 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 soil, some of which is heavily contaminated by asbestos and acidic compounds, can be disposed of within KNP without further significant environmental impacts. The use of excavated materials in ‘landscaping’ works might further exacerbate the damage to the Park. I am shocked to learn that 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?
Water table drawdown at 3 kilometres either side of the tunnel is still 0.5 metres in the western plateau will have an as yet unknown impact on the environment along sections of the 27 kilometres tunnel, will dry up existing creeks, impact the local fish and animals and reduce inflows to the reservoirs and hence water releases.
I am amazed and dismayed 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 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.
I have learnt that Snowy 2.0 will disperse pest species 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 these noxious species will be transferred from Talbingo to Tantangara. Establishment of the dominant Redfin Perch will be to the detriment of significant populations of threatened native fish. It is 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 composition 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. In my opinion ‘the community’ has come a long way in environmental awareness and will not just accept everything it is told at face value. Uneconomic
It is clear that the cost of Snowy 2.0 will be many times 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. I am always wary of cost estimates, as these have a habit of blowing out to several orders of magnitude.
Snowy Hydro is wholly 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. Why was this necessary and why is the Commonwealth Government playing favourites in the National Electricity Market?

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 do 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 or so 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.
• 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.
It is clear that the cost of Snowy 2.0 will be many times 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. I am always wary of cost estimates, as these have a habit of blowing out. The scale and severity of environmental impacts are not commensurate with the environmental, economic and community benefits of of the project. I am not an expert in all the technical details and must take them on trust. I am a lover of KNP, visit it frequently and will staunchly defend its integrity. Once a fragile ecosystem such as KNP compromised it is very difficult to undo the damage. SUSAN STEGGALL

Please see attached

I do not support the Snowy 2.0 project for these reasons:
1. There are other, better options for the Australian Government to increase renewable energy production which would be much less damaging to our environment. Production of energy is not an excuse for trashing one of our few relatively unspoilt natural landscapes. The Snowy provides vital ecosystem services on a massive scale, worth far more to us than the proposed electricity generation.
2. We only have one alpine region in mainland Australia, and its flora and fauna are already under threat from the warming trend in our climate. We need to cherish and protect this area.
3. Wilderness areas such as the Kosciusko National Park are a carbon sink. Government funding should be directed towards establishing more forests, not destroying them. Snowy 2.0 will have a gigantic carbon footprint so is a totally unsuitable project for 2019.
4. Energy generation needs to be local and small-scale in order to protect us from the threats which climate change poses to both our ecosystems and ourselves. Large-scale infrastructure is vulnerable to extreme weather events and terrorism, both of which are increasing globally.
Thank you for this opportunity to comment on this proposal and I dearly hope that wisdom and not short-term political gain will guide decision-makers to scrap plans for Snowy 2.0.

My attached submission objects to the Snowy 2.0 Proposal

see attached

My comments have been provided on the attached submission

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

4th November 2019

Submission on Snowy 2.0 Main Works Environmental Impact Statement

I strongly appose the Snowy 2.0 project as described in the Main Works Environmental Impact Statement (EIS). I consider that the EIS is flawed in its conclusions.

The EIS admits that damage will be done to substantial areas of Kosciuszko National Park. This park has national heritage values and is much loved by Australians. Damage to alpine and river vegetation is not acceptable in a 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). Such extensive disturbance must not be allowed in this precious park.

However, the above estimates do not include large areas permanently cleared of mature vegetation for new and upgraded roads and along new transmission lines. When these are included the estimated areas damaged will be more like 10,000ha. This proposal is outrageous at a time when world biodiversity is under extreme threat of extinction and in Australia the alpine vegetation is suffering already from damage by feral animals and climate change.

Tunnel waste
Rock and soil from tunnelling is to be dumped into Talbingo and Tantangara Reservoirs. This is estimated to be over 8 million cubic metres which will reduce the water volume of these water storages, surely impacting on rivers downstream. Some of this material is contaminated with asbestos from the original Snowy Scheme.

Renewable Energy?
According to data supplied in the EIS Snowy 2.0 will require coal-fired power for pumping for the next decade. 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 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.

Therefore, this project will fail to live up to its claimed benefit of providing renewable energy to help balance the electricity grid. Widely distributed, smaller storage systems would be a better option.

Cost to the Australian taxpayer
I object to expenditure on such a massive, costly project which will cause substantial damage to the rivers, groundwater systems, vegetation, fauna and tourism values of one of Australia’s largest national parks. Furthermore, the costs of ameliorating damage where it is possible to do so will be funded by the taxpayer.
Already the cost of the project has risen from $2billion to $5 billion and this does not include the transmission lines. This project will be uneconomic and a burden on taxpayers.



Alternatives
Neither the EIS nor the government has so far properly investigated alternative pumped hydro sites where there may be less damage caused to our natural heritage and water resources. A series of smaller pumped hydro projects across a wide range of latitude is likely to be a better option because climatic variations will impact each project differently over time.


I conclude that this project cannot be considered an Ecologically Sustainable Development as required by the Environmental Planning and Assessment Act. The extreme damage to the natural heritage of a national park and to rivers are unacceptable impacts. The costs of construction are likely to outweigh benefits to Australians especially if alternatives are properly considered.
I recommend that Snowy 2.0 be stopped.

I unequivocally object to the proposal to use the Kosciusko National Park for an expansion of the hydro- electricity scheme known as the "Snowy 2.0- Main Works". I have spent a lot of my life enjoying the natural beauty of the "Snowies" and the opportunity to access the alpine environment for bushwalking, cross country skiing and learning about the area's biodiversity. Our national parks are primarily for conservation and providing recreational experiences that protect those conservation values. The vision to expand the hydroelectricity scheme within a national park is contradictory to the conservation of biodiversity, is not in accordance with the principles of the National Parks and Wildlife Act and contrary to what the Australian community expect from a government.

As a schoolchild I visited the Snowy Mountains Hydro-electricity Scheme, and like others, was in awe of the engineering feat. However as an adult, every time I have visited the Kosciusko NP I have said to myself "My god how did we allow this?" or "We would't allow this to happen these days!"

The arguments for a sustainable energy supply do not justify the use of our national parks for this scale of development. There are many more alternative opportunities for solar or wind generated electricity on degraded landscapes rather than using our precious national park landscapes.

Please continue to allow access to the public to Tantagara Dam Road and Currango.

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.
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.

Please find attached my submission objecting to the snowy 2.0 project. This project is incredibly damaging to Kosciusko National Park and the economics of it are highly suspect with the reported cost blow outs.

regards,
Christine Cooper

I object to this project on environmental grounds due to its detrimental impact on the surrounding environment including threatened species of flora and fauna.
I object on grounds of energy sustainability where Australia has to be investing in sustainable energy production ,namely wind and solar.
I object on economic grounds -this project will not provide the necessary economic boost to number of Australians with minimum environmental harm needed for sustainable growth .

See attached submission

In response to the EIS for the Snowy 2.0 Main Works I would like to raise the following points.
1. Tunnel Boring Machine: This will cause powder & dust, unlike drill & blast method, will it cause a film on Talbingo & Tantangara Dams when the spoil is placed in the dams. What effect will this cause on ski / fishing boats and on the general fish population
2. Asbestos: This is found on the western side of Talbingo Dam, is it on the eastern side as well? What measures are in place that it won't enter water with the spoil in both solid & powder form?
3. Spoil: What guarantee is there that in the long term that there will be no effect on fish, both breeding & life expectancy for the long term of the tourist trade?
4. Will boring cause any damage to Yarrangobilly Caves, the water table and the minerals that create the stalagmites & stalactites? What guarantee that this will not harm or change the water quality to affect the caves long term as they have large visitor numbers and it will have a huge impact on tourism in the area if they are affected adversely.
5. The area is well known for its copper. Will a small or large amount of copper be in the spoil in either dust or solid form. What are the long term effects on water qulity and fish quality?
6. With large amounts of trucks using Link Road and the snow season increase in traffic, this will affect the tourists going to the snow with a build up of traffic around the National Park booth and the Selwyn Snowfields turn off. What measures will be in place?