Snowy 2.0 - Main Works

Objection letter as attached.

From many positions the plan is defective and not the best way to use this ‘increasingly rare’ resource, water.

1. Water is likely to decline substantially making the whole exercise short lived.
2. It is hugely costly when all the associated changes are included and given the extent of the scheme
2. These, and other bodies of water in the area could be contaminated by all the associated works, which are extensive - not just a couple of entry points..
3. The pipe will be huge - up to 1 km below ground and in the order of 100 km long! (96 km to drive btw the 2 lakes). The reach of this is mind boggling..
The amount of water needed to be in this pipe to make the system viable has to impact on the respective reservoirs.

Basically it is a nightmare- eg giant reversible turbines pushing water to and fro providing substantial electricity will involve immense weight and pressures and pipe cracking would seem highly likely. Repair of this would be interesting. Presumably that’s the reason for all the entry points???

The arguments seem to be multiplying indicating the absurdity of this scheme. One factor is the extraordinary drought associated with the Murray-Darling, eastern reaches of which include the area of the proposed system. https://www.mdba.gov.au/discover-basin/landscape/geography

Using this precious resource for electricity given other current options, particularly viable in Australia, is complete idiocy.

In brief:
▪︎1. The proposed project is a third of Kosciusko National Park, twice the size of Greater Sydney, in an internationally renowned conservation area. This is a vast scale. Monstrous!
▪︎2. This subalpine area has some of the rarest habitat in Australia. We have already destroyed other areas. Let us protect this region.
▪︎3. The EIS acknowledges that the construction footprint will disturb 1680 hectares of native vegetation and destroy 992 ha of threatened species habitat (fauna, flora, ecological communities) PLUS 109kms of new roads, 10km of transmission lines with 120m wide easement, dpleted groundwater above tunnels, construction camps and work areas. Massive destruction!
▪︎4. How can 14 million cubic metres of spoil, some of which is heavily contaminated by asbestos, be disposed of in Kosciusko National Park without further catastrophic environmental impacts? Dumping in Talbingo and Tantangarra Reservoirs will deplete their capacities.
▪︎5. There us a total disregard for the protection if water dependant ecosystems. Not acceptable.
▪︎6. Noxious pest species, particularly redfin perch, will make their way downstream to the Murrumbudgee River, Lake Eucumbene, Snowy River, Murray River. A catastrophe!
▪︎7. Wilderness and solitude are absolutely necessary in our lives and here we have that provided by nature. Destruction!
▪︎8. I have also read financial details and deem that this proposed project is totally uneconomic.
▪︎9. Snowy Hydro us owned by the Australian Government, therefore the Australian Community. Why should we bear these huge risks and suffer the consequences of a project which is uneconomic, staggeringly huge and will severely impact the environment. This is not reversible!
CW

I object to this project for the following reasons:
the cost is much greater than alternatives for accumulation of power.
The long term loss of jobs will be much greater than any shot term employment gains.
The concentration of power accumulation will make the power system vulnerable to natural attack ( fire, storm drought etc ) and terrorist and foreign sabotage.
The collateral damage during construction will cause permanent loss of natural heritage,( fauna, flora, and scenic ), as well tourism.
The clearing of vegetation will lower the rainfall ( snowfall ) threatening the future of snow sports in the Snowy Mountains.

The better alternatives to Snowy 2 are to manage the power usage in a multi faceted manner.
Utilizing both old and new technologies power accumulation can be managed more cheaply and providing greater security than Snowy 2
( Snowy 2 only contributes only accumulation capacity, and actually will have a reduced original power contribution due to dumping spoil in a dam )
Batteries are more efficient than hydro mechanical means of power storage.( Lead acid batteries although they are heavy can be used in static situations to advantage, will be cheaper than lithium batteries, and can be completely recycled.)
The use of "Smart Meters" enables the charging for energy at different rates at different times, ie high rates at peak demand times and cheaper rates for off peak
The use of domestic batteries has increased, and should be , as it can reduce the peak demand considerably.
Industrial users and also hospitals and other essential services should be encouraged to use batteries rather than diesel generator sets to provide power security, as batteries can provide cheaper power if power is charged for at different rates.
One other initiative that should be introduced is a lower charge for power used subject to remote switching, (as hot water and storage heaters were using ripple switching) so the compressor of an air conditioner can be switched off for 10 or 15 minutes at a time making little difference to the room temperature at the time but can be used to remove surges in usage.
The big advantage of using multiple battery storage is that the distribution more localized, and so is more secure and efficient.
If we were to build a hydro electric storage it should be north of Sydney, Armidale , Toowomba , closer to growth centers.
We should learn from the South Australian blackout of September 2016, that large and lengthy transmission lines are vulnerable to natural extremes (wind, fire, water, and earthquake ) as well as could be targets for terrorists or foreign powers.
Other technical advances are proceeding, such as thermal storage in solar thermal power generation plants.
It would be better to put more resourced into encouraging development of multiple ways and places of energy accumulation that make one vulnerable expensive inefficient project in the wrong place.

I am strongly opposed to the Snowy 2.0 project as described in the Main Works Environmental Impact Statement.
The scale and intensity of the environmental impact is unacceptable for a sensitive sub-alpine region such as Kosciuszko National Park (KNP). In addition to the catastrophic environmental impact, the cost is excessive, the claims about energy storage potential are dubious, and there is no credible consideration of less expensive, lower impact alternatives. Consequently, in my view the Snowy 2.0 project does not meet the standards required of Environmentally Sustainable Development and therefore the Minister for Planning should refuse the project.
Details of my concerns are in the attached document.

Comments attached

Please see attached submission from NPA ACT

Please see attachment

Sample Submission for Snowy 2.0 Main Works EIS

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

6 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 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,
• I wish to maintain access to Tantangara Road, Wares Yards, Currango Homestead & Old Camp site, and
• Port Phillip Fire Trail isn't an alternative as it is often closed due to dam levels

Also 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.

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/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. 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.

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 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.
• 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 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.

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?

Conclusion

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. In short, the staggering scale and severity of environmental impacts are by no means commensurate with the environmental, economic and community benefits of the project.

Yours sincerely,
Peter Coorey

I am strongly opposed to Snowy 2.0 Main Works.

This project will have unacceptable environmental impacts on Kosciuszko National Park and the surrounding area. It will destroy much of the sub-alpine area which encompasses some of the rarest habitat in Australia.

In addition the cost of the project is uneconomic even at the current level of $5.1 billion which does not include the cost of transmission. Other options should be investigated and assessed.

The Kosciuszko National Park was set aside to preserve a precious alpine environment which is unique world-wide due to its existence at lower altitudes compared to other examples across the world and its far greater assemblage of plants again of a unique Australian Flora which other alpine regions do not possess.
Snowy 2.0 and its interconnecting transmission lines are located within Kosciuszko National Park. It is totally inappropriate and incompatible for infrastructure of such magnitude and environmental consequences to be permitted within the delicate alpine and sub-alpine environments of the Park.
Snowy 2.0 presents itself as an ill consider politically expedient stunt that was rushed by a then failing Government as a desperate initiative to claim some action on climate change and future energy supplies in an era of non-investment in such projects due to the lack of Government policy on energy and renewables. This has resulted in an unacceptable EIS which wallpapers over many significant concerns with unsubstantiated assertions. The EIS is all too prone to using executive style persuasive report jargon especially the use of the word ‘critical’ as it skates blithely over the complete lack of a business case and the already alarming escalation in costs.
The concerns, which alone should defeat the proposal are as follows: massive amounts of environmental destruction, a non-economic business case, the renewable energy hoax of the whole operation, better alternatives lying elsewhere.
Environmental Destruction will occur through Snowy 2.0 is proposed in one of the most significant natural landscapes in Australia, with its delicate alpine and sub- alpine environments involving a permanent impact on 10,000ha of Kosciuszko National Park involving the following
Land-clearing including 120ha or 1.2 million square metres for a 10km transmission corridor and 400ha at Lobs Hole, dumping rock wast in reservoirs - 14,000,000 cubic metres of excavated rock,
Invasive Pest Species Proliferations and Distribution including the voracious predator and Class 1 Noxious Fish, Redfin Perch which will be transported from Talbingo up to Tantangara Reservoir and thence throughout the Snowy,
Current Construction Activities underway without EIS assessment for the whole activity.
Non Economic Case
FLAWED BUSINESS CASE. Six weeks after the Business Case was approved by the Government, the cost estimate (of $3.8) was eclipsed by the first major contract to be signed (at $5.1 billion).
COSTS SOAR. The final cost, including transmission lines, could be as high as $10 billion – i.e. 500% higher than the original estimate of $2 billion! This staggering amount exceeds the value of the whole of Snowy Hydro ($7.8 billion).
ECONOMICALLY UNVIABLE. Snowy 2.0 could not cover the interest on its debt, let alone make a profit. The economics simply don’t stack up.
SUBSIDY. Taxpayers shouldn’t have to provide Snowy 2.0 with a $1.38 billion subsidy.
ELECTRICITY COST REDUCTIONS? No information is provided to support the claim that Snowy 2.0 will reduce electricity prices.
OVERLY OPTIMISTIC TIMING. The estimated construction time has more than doubled since Snowy 2.0 was first announced, from 2021 to 2027.
MINIMAL PAYMENT FOR USE OF KOSCIUSZKO.
Snowy 2.0 proposes to only make minimal payments for use of Kosciuszko National Park during construction and operation – another inappropriate subsidy and unfair advantage compared to Snowy 2.0’s competitors!

The renewable energy hoax
COAL-FIRED GENERATION. Snowy 2.0 is being promoted as a ‘green battery’ for renewable energy. Yet, for at least the next decade or so, most of Snowy 2.0’s pumping electricity will come from coal-fired generators.
Perversely, this will result in increased emissions. NET LOSSES (40%). Snowy 2.0 will consume more energy than it generates. For every 100 units of electricity used to pump water up to Tantangara Reservoir, only around 70 units of electricity will be retrieved when the water flows back down through the turbine generators to Talbingo Reservoir.
As well as having a ‘round-trip’ loss of 30% within the pumping / power cycle, there are also losses in transmitting electricity to and from Snowy 2.0 of typically 5% each way.
So, for every 100 units of electricity purchased by Snowy 2.0, it will deliver only about 60 units.
The lack of transparency
Alarmingly there is NO PUBLIC SCRUTINY OF THE BUSINESS CASE.
Snowy Hydro is a Commonwealth Government Corporation. All Australians bear the liabilities of this risky project, including a $1.38 billion taxpayer subsidy.
Electricity consumers and taxpayers need to know whether the project is financially viable and the claimed benefits are deliverable. Snowy Hydro has not released its Business Case or any financial information.
FLAWED PROCESS. The staged approach to the financial and environmental assessment, along with the limited release of information, means that neither the Government nor the public can comprehensively assess the entire project. The transmission lines EIS has yet to be released.
LACK OF RIGOROUS REVIEW. The Government’s review of Snowy 2.0’s Business Case was based primarily on advice from Snowy Hydro. The Government needs expert advice, independent of Snowy Hydro, on the environmental, economic and engineering impacts of the project.
Better Alternatives
IS SNOWY 2.0 THE BEST OPTION? Snowy Hydro has focused totally on the ‘Snowy 2.0’ project. No information has been provided on why Snowy 2.0 is the best option.
Alternative pumped storage options exist – even Snowy Hydro has made references to the future use of other sites.
Alarmingly, no substantive analysis of alternatives was included in the EIS, despite a legal requirement to do so.
There are alternatives involving less construction, cost, risk, transmission and environmental impact.
BROADER ALTERNATIVES NOT REVIEWED. Many other pumped storage opportunities have been identified in NSW, with a combined capacity considerably greater than Snowy 2.0. Before committing to Snowy 2.0 and providing a $1.38 billion subsidy, it was incumbent on the
Government to review all storage options, including other pumped hydro, batteries and demand response.
There is no need to cut corners on the pretext that Snowy 2.0 is the only option for electricity storage and must be urgently constructed.
Conclusion
The Kosciuszko National Park is suffering enough threatening processes from feral populations of horses and other non-indigenous animals including deer, dogs and cats without a massive human induced destruction of a key part.
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.
Snowy 2.0 is trying to boost its chances of approval through biased information. It is a government creation trying to justify its existence. The proponents are seeking their own security above what is best for the nation. I do not accept that that Snowy 2.0 will play a pivotal role in stabilising the national energy market and it certainly does not justify the extent and severity of environmental destruction that the project will cause to Kosciuszko National Park.
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. In short, the staggering scale and severity of environmental impacts are by no means commensurate with the environmental, economic and community benefits of the project.
Snowy 2.0 should be stopped in its tracks. The Commonwealth Government should revoke approval of the Business Case, due to its significantly underestimated costs and overstated benefits to the Australian public. And the NSW Minister for Planning should refuse approval for the EIS due to the overwhelming damage to Kosciuszko National Park.

Yours sincerely
Ian Hill

Department of Planing, Industry and Enviroment
Major Project Team
Attention: Anthony Ko

6 November 2019

Submission on Snowy 2.0 Main Works Environmental Impact Statement
I wish to register opposition to the Snowy 2.0 project as described in the Main Works
Environmental Impact Statement (EIS). Not only is it overpriced, not a net source of
renewable energy, and the EIS being revealed to the public piecemeal, it is
environmental vandalism.
Economically not profitable
Snowy 2.0 will not be economic. The cost has already increased by several times
from the original $2 billion. Add costs for high voltage transmission lines (two side-
by-side high voltage transmission lines for 10 km through the Park, with a 120m wide
easement swathe) the total cost will increase by ten or more times. We Australians
and taxpayers will bear the risk.
Snowy 2.0 a net consumer of electricity
Snowy 2.0 will be a net consumer of electricity, not a generator. For around a decade
it will use mostly coal fired power to pump — making a mockery of the claim that it
will store electricity from renewable generation. The supposed 350 GWh will rarely
be realised, owing to the peculiar physics used to figure the actual capacities of
Tantangara, Talbingo, and the role of Blowering.
Environmental vandalism
The footprint of the project is much larger than 0.25% of the 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.
Environmental damage will be huge and unacceptable, and not what the public
expected.
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 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?
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?
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? How can such
an environmentally destructive, expensive and inadequate development be proposed
without an exhaustive exploration of viable alternatives? Kosciuszko is a National
Park, not an industrial park!
Offsets are not possible as this alpine region is unique in Australia. The approval
process, as carried out here, has tried to obscure, not clarify, impact on the
environment. Never before has a project of such immense size and environmental
destruction been proposed within a National Park.
Sincerely,
Margery Street
AALIA, GradDipTourismM, M EnvStud

NSW Government Departments are subject to published code of conducts. To no comply with these codes would amount to corrupt conduct as per the ICAC Act. Snowy 2.0, in its current form, cannot meet the requirements of NSW legislation.

see submission as attached

The SNOWY 2.0 MAIN WORKS ENVIRONMENTAL IMPACT STATEMENT (EIS) confirms that the requirements of Section 4.15 of the NSW Environmental Planning & Assessment Act 1979, cannot be met nor can it satisfy other relevant legislation.
The Department of Primary Industries / Water have been silent. This department is responsible for the Fisheries Management Act and the Biosecurity Act.
It is the Fisheries Management Act that give the Snowy River catchments the EEC status.
The Biosecurity Act should prevent the spread of pests but the EIS calls for an exemption from this.
Section 404 enables an exemption to be given. This is untenable for a national park and the impacted ecosytems of the Snowy River and other waterways.

The EIS contradicts itself in the two section summary, where it states that transfers to Eucumbene Dam and onwards will be prevented, however, the appendixes then contradict this.
A critical deficiency of the Snowy 2.0 Main Works EIS relates to the absence of the primary research reports commissioned by Snowy 2.0.
Without these reports it is not possible to properly scrutinise the scope and cost of mitigation options reportedly examined (e.g. fish screening options for the invasive Red Fin), the potential for live fish transfer and survival; the design and suitability of the barrier to mitigate impacts from Climbing galaxias; and the design and sample size of EHN virus investigations.
Of concern to the Alliance and some members of the community is that Snowy Hydro has commenced construction works in the Ravine and signed the major works contractor before the major works has been given approval.
The offsets required should be follow the NSW Biodiversity Act offset formula minimum proposed by Snowy Hydro Hydro (M.3) since public lands will be used and water and damaging a national heritage area.

The proposal to not to screen off the Talbingo portal to prevent spread of the pest fish Red Fin and disease up the tunnel to Tantangara is not adequately explained and needs to be reconsidered for this proposal to progress any further.

Missing from the proposed offsets are further restoration of Snowy 1.0 sites and improving environmental flows in the Snowy and other impacted rivers. These outstanding Snowy 1.0 sites must be included.

While the Snowy River Alliance fully supports renewable energy projects, other more efficient pumped hydro sites have been identified in NSW which do not have the catastrophic environmental impacts of Snowy 2.0.

The Snowy 2.0 EIS is unacceptable to the Snowy River Alliance in its current form.
The Alliance requests that other pumped hydro sites be considered ahead of this Snowy 2.0 project, and one EIS be developed to cover the whole project, with independent scientific assessment sought and made publicly available before progressing any further.

My primary aged daughter attends Cabramurra School. My route to the school is from Snowy Mountain Hwy and along Link Road past the Lob's Hole turnoff. Therefore my vehicle (as well as the teachers vehicles) pass Lob's Hole four times a day due to the return trip. I'm concerned about safety during this trip due to the number of trucks on the road and the snow and ice conditions that prevails between July -Sept.

I am also unhappy that the rental arrangement for the principal/teacher has increased so dramatically that it is unlikely that teachers will be able to secure a rental for 2020. Currently weekly rent is approx. $350 . Snowy Hydro intend increasing rent to bring it in line with what it charges contractors ($100 per bedroom per night). The teacher accommodation is a 3 bedroom house - effectively this means that rent will increase to 4x$300 per night = $1200. If accommodation is not available to the teacher at a reasonable rate they will leave and it is unlikely that the school will re-open. If this occurs I am forced to relocate to Talbingo or Tumut for my daughters schooling.

Please see attached comments from Snowy Monaro Regional Council

Submission on Snowy 2.0 Main Works EIS

I wish to express my opposition to the Snowy2.0 as indicated in the main works EIS for the following reasons .
A- The project does not meet the requirements of Environmentally Sustainable Development (ESD) and should therefore be refused by the Minister for Planning.
B- The project will destroy 992ha of threatened species habitat, clear 1,053ha of native vegetation and disturb a further 1680ha all in an extremely limited and precious Alpine environment supposedly protected within a National Park.
C- Disturbance, Habitat Loss and Visual Impact from 100 km of new and upgraded roads, 10 km of ugly new transmission lines replete with 120m of razed easement, depletion of ground water from new tunnels , multiple site works, in Park disposal of massive amounts of Rock and Soil fill will all seriously impact on a declared National Park and are completely unacceptable.
D- The project will make a minimal contribution to renewable energy capability, given that it will be a net consumer of electricity with 40% losses on pumping cycles.
E- Claimed capacity of 350 GWH is grossly exaggerated given the rare rainfall circumstances required and lack of storage volumes available to allow such an amount.
F- Cost Blowouts are already occuring and will likely lead to a final completion cost of
$10 billion rather than the initial $2 billion estimate.
G- No serious analysis of any feasible alternative to the project have been carried out and approval for the project has been presented as a Certainty whatever it's failings.
CONCLUSION
The Snowy 2.0 Project does not meet the principles of ESD. The magnitude and and severity of environmental impacts are very high whilst the return is particularly small.
For these reasons I believe th project does not stack up in terms of public benefit.

The Snowy 2.0 project was presented to the public as an environmentally friendly, renewable energy project that would provide reliable, clean energy.
Nothing, apparently could be further from the truth.
1. The environmental impact on our fragile, alpine Kosciuszko National Park will be immense.
-250,000 ha or one third of the Park to be affected.
-Vegetation clearing, earthworks, dumping of spoil into reservoirs, damage to waterways and water dependant ecosystems is proposed in a National Park.
-Destruction of sensitive mountain environments for road widening and easement for transmission lines are proposed in a National Park.
-Tunnelling will interfere with both mountain bogs and reduce water flows into downstream waterways and rivers despite the prediction of further extreme droughts.
-There will be an inevitable spread of pests and weeds from disturbance creating major threats to fragile habitats.

2. Clean renewable energy it is not.
-For the next DECADE the electricity for pumping will com from coal fired power stations.
What an outrageous deception.
-Worse, the project will actually consume more energy than it generates for some unspecified time.

I strenuously object to spending $10 billion or more of taxpayers money on such an environmentally damaging, economically wasteful project that does not even produce clean energy. Lets see this project compared to other, cheaper alternatives.

I object to this project due to the extensive environmental impact on Kosciuszko National Park, the effect it will have on visitation to, and enjoyment of the Park, as well as the compromised nature of it's benefitting the Nation in respect of providing renewable energy.

The scale of the project will seriously impact on one third of the Park. The impacts include extensive earthworks with all the attendant effects such as vegetation clearance, soil dumping, damage to riparian zones, the introduction of noxious weeds, facilitation of pests, destruction of threatened species habitat quite apart from visual impacts. Many of these impacts will not be contained "at site" but will move downstream and across the landscape due to Kosciusko being such a major watershed. This cannot be underestimated.

Roads are to be constructed, powerlines with large easements constructed all with major impact in an environment gazetted as National Park.

Tunnelling is a vital component of the project which will also impact above ground as well as potentially affecting one of the most important water tables in Australia.

In the quest for providing renewable energy this project is highly compromised. It will rely on coal for construction, it has not been adequately assessed versus alternative solutions and once completed will be be an overall consumer of electricity.

Economically there are already clear indications of costs escalating which no doubt will only compound with time.

Kosciusko NP exists because of its unique environmental attributes, it is a vital source of water flows, it is also a major tourist destination. All of these factors are of paramount importance, all will be seriously compromised by this project. It is neither appropriate or a responsible solution.

This project is ill considered and appears to be an easy quick plan to suit political need.
Alternative options should be properly explored and considered.
It is economically unsound.
It is environmentally destructive in numerous respects.
It will affect the tourism activities in KNP.
It will adversely impact on all the water systems reliant on KNP which is simply irresponsible in this time of climate change.
It is, simply, utterly inappropriate to undertake this project within a National Park.

I believe that this project should be comprehensively reconsidered to find a viable alternative.