Snowy 2.0 - Main Works

I've taken a good look at the EIS and conclude that there is a large amount of scientific rigor omitted that may negate many of the proposals within it. I find it astonishing that the EIS is so lengthy, often repeating rhetoric (eg. “it is just 0.25% of the park”) and laden with emotive images most of which are not linked to text or even identified, yet objection submission is limited to 10k characters.
Snowy Hydro has bombarded the public with emotive documents, claiming that Snowy 2.0 must go ahead because it is in the public interest to reduce power bills. eg. One defense of criticism absurdly compares the footprint in the national park to the Sydney Opera House; two very different projects in different eras. Emotion should be omitted and decisions back by peer reviewed science only. The unreasonable behaviour displayed by Snowy Hydro in the EIS and in associated public statements is repetitive, tantamount to bullying as defined by the Premier’s Dignity and Respect Charter.
My central objection centres around the prevention of feral fauna and/or introduced native predator species and pathogens in the event of water, polluted by uphill transfer into Tantangra from Talbingo, flowing into Eucumbene; in the event of overtopping into the Eucumbene R (or future environmental release) and/or water transfer into Jindabyne, the Snowy System is effected by, so far unmeasured and unmitigated invasion, both downstream and in the montane areas. An unacceptable and preventable alteration of what is left of the natural Snowy R. environment.
Two fauna species that will pose grave risk to Stocky Galaxias and Macquarie Perch are Climbing Galaxias and Redfin Perch. Attempts to address this problem appear severely inadequate. As I understand it mitigation measures for the preservation of fish species have been deemed too expensive in cost and environmental change and have been rejected.
Further, epizootic haematopoietic necrosis virus (EHNV) is widely studied. It will be transferred from the Tumut River Valley by pumping and decimate native species.

Macquarie Perch (EPBC listed species) and Stocky Galaxias (pending listing) must be protected on ethical grounds regardless of non-compulsion due to pending processes.

These species populations (and possibly more that have been omitted) knowingly suffering extinction is an unacceptable consequence of this project.
There are numerous impacts on ecology that are apparent. It appears that elements of the impact have divided between Transgrid, Snowy Hydro (3 separate EIS stages) and the governments in order to strategically confuse and exhaust concerned citizens for the benefit of a politically influenced agenda. Numerous alternatives have been proposed by prominent academics, yet are ridiculed by Snowy Hydro. The studies are economically viable, environmentally more responsible (particularly not in national parks) and provide socially acceptable assets (jobs, recreation, etc).
I put it to you that the damage to the ancient national park has been significant in the past 200 years (particularly in the past 70 years) and it must be left alone to recover as best as possible without the impacts posed by this project. More responsible alternative projects are viable.

I wish to indicate our strong opposition to the Snowy 2.0 project as described in the Main Works Environmental Impact Statement (EIS).
Please refer to the attached document for my full submission

Please refer to my attached submission.

I strongly object to the Snowy 2.0 project. I am alarmed at the widespread destruction of delicate sub-alpine habitat. We have enormous problems with the river systems and this area is the headwater for many large rivers. The water table will be disturbed and large quantities of tunnel debris will be dumped. The contribution to renewable energy is debatable. I am disgusted by this government's lack of credibility with regard to National Parks. They are supposed to be protected. We members of the public expect that the government would respect their protection but instead this government is pushing forward infrastructure at all costs. There is hardly any wilderness remaining. I am most concerned by the upcoming loss of a unique, irreplaceable piece of our planet.

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

5.11.2019

Submission on Snowy 2.0 Main Works Environmental Impact Statement

I, Marion Glover, wish to indicate my 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/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.

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. At anything approaching this amount the project is totally uneconomic.

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, Marion Glover.

I wish to indicate my 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 distinct 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 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 consider this assessment to be 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 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.

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.
• 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.

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.

For many years I have been a regular visitor to Kosciusko National Park for bush walking, cycling and camping. This is a unique and beautiful area. It is a fragile alpine ecosystem which is extremely slow to recover from disturbance and, in some cases will never fully recover.

I wish to object to the Snowy 2 project and the EIS which inadequately addresses the environmental impacts.
This is a project which will affect one third of the National Park and will involve work which will have long term negative impacts on native vegetation communities and the flora which depends on them. Activities such as clearing native vegetation, earthworks, dumping into streams, tunneling will all have significant impacts which have not been adequately assessed.
Road widening and construction has significant short and long term environmental impacts. I have already witnessed the destruction caused by the widening/construction of the road to Goandra hut. The environmental impacts were obvious and detrimental.
The waterways of this region are precious habitat and extremely fragile. It is not acceptable to dump excavated spoil into waterways. It appears that spoil which may contain asbestos will be dumped into Talbingo and Tantangara Reservoirs. This is not acceptable.
Montane streams and alpine bogs are essential components of these alpine ecosystems and yet this project , through activities such as tunneling, risks drying up these wet environments and/or affecting water quality.
Kosciusko National Park is a popular tourist destination. It is not appropriate to destroy the visual impact of this area through the construction of roads and high voltage transmission lines which also require 120m wide easements.

Hydroelectricity is an important, renewable energy resource. However, the Snowy Project 2 must be properly assessed on both environmental and economic grounds. It fails to adequately protect a fragile alpine environment which is of considerable significance. It also fails on economic grounds with the original $2 billion cost already expected to blowout to $10 billion. Other pumped storage opportunities have already been identified in NSW and should be considered.
With Climate Change predictions of a hotter and drier future we cannot be assured that this project will even be viable.
There are too many environmental and economic dangers to risk this unique and fragile alpine environment.

I support the project but I have a number of concerns arising from the EIS.
1. The EIS does not appear to have adequately canvassed various alternative sites for new pumped hydro schemes in much detail. While it refers to the work of Blakers et al, a detailed critique of the relative merits of various sites does not appear to have been provided. I acknowledge the central location of Snowy Hydro 2.0 in relation to eastern states capitals, and the use of existing storages, but the hard rock geology is a serious cost.
2. There is concern about the precedent set by encroaching on a national park with industrial development. I acknowledge that the existence of the Snowy Mountains National Park is largely as a result of the desire to reduce erosion from the impact hard-hoofed grazing animals (cattle and sheep) in an environment with a very short growing season, I would be very concerned if a precedent of development in conservation reserves were to be more widely adopted. The erosive effects of hard-hoofed animals continues with the explosion of feral deer and horse populations, further degrading the National Park.
3. The deposition of rock spoil from the tunneling operations in the existing dams should be carefully carried out to armour the perimeter against the erosive effects of rapid and repeated water level changes. This may involve considerable expenditure but this would probably be a worthwhile expense.
4. A more thorough examination of emerging technologies for storage of low-priced energy to provide peaking power should be included in a supplementary EIS. These technologies might include Zinc-Bromide batteries, Compressed Air and Hydrogen from electrolysis, stored as the compressed gas or chemically transformed to Ammonia or some other chemical.
Overall, I support the Snowy Hydro 2.0 scheme because the provision of storage in the system has the potential to increase the overall thermal efficiency of the East Coast Grid. The issues are whether the scheme is the most cost-effective way of doing this.

It is vital that Tantangara Road be kept open throughout the project as otherwise public access to Wares Yards, Currango Homestead & Old Camp site will not be possible for visitors to the park. These are major hubs for park activities. I appreciate that work needs to be carried out but it should be done in such a way that the road remains open. Port Phillip Fire Trail isn't an alternative as it is often closed due to dam levels

Snowy 2.0 is hugely expensive, will be uneconomic, will make a questionable contribution to the nation's power generation and critically, does not belong in a National Park. I object to this project.

Cochran Horse treks in principle support the Snowy Hydro 2.0 project and make comments in regard to the immediate economic and logistical impact the project will have on our operation and profitability. In correspondence to Snowy Hydro in 2017 (see attached), those immediate issues identified as being a threat to the business, were anticipated to be addressed in the feasibility study and have not been addressed in the either the feasibility study or current EIS. This is disappointing.
Those issues identified in correspondence attached relate to, but are not limited to,
*access in areas used under the current NPWS licence- Tantangara Road, Port Phillip fire trail
* Logistical management of Staff, Plant and Equipment, horses and guests
* Loss of staff due to uncertainty in long term planning ( 2 key personnel have recently resigned)
* Increased costs to operate under substantially changed conditions
*Risk Management and changes to Safety management plan
* Visual amenity and impact of dust and noise.
As an Eco tourism operator offering a unique experience in Kosciuszko National Park for guests, access into the park to camp, ride and enjoy the wilderness and the visual amenity of the surrounds are a big part of our business and we will be greatly impacted by the closure of Tantangara road and exclusion zones created due to construction activities. Many of these locations are accessed during the treks due to their visual amenity and historical significance and will now be closed to our guests, diminishing the quality of the service we offer and have offered to the public for 20 years.
Given the impending disruptions to our business, attempts have been made with the NPWS to have our licence to operate and modus operandi amended, see attached letter to NPWS.
In addition Cochran Horse treks have initiated investigations into the possibility of relocating into other areas a far a field as NSW south coast, The Western fall and Northern tablelands. None of these options have been feasible or viable.
In closing Cochran Horse Treks remains concerned, as expressed in our previous correspondence that the future of the business is in immediate threat of serious negative impact or facing the prospect of permanent closure

5/11/2019
Submission on Snowy 2.0 Main Works Environmental Impact Statement
I would like to register my strong objection to the Snowy 2.0 Project as described in the Main Works Environmental Impact Statement (EIS). The huge size and blunt force of this project in a sensitive delicate environment such as that of the sub alpine region of the Kosciuszko National Park (KNP) is beyond inappropriate. I was shocked when I realized the full impact that this project would have on that beautiful delicate environment and frankly I am ashamed of our former Prime Minister Malcolm Turnbull for his unwavering support of Snowy 2.0, unless he was not fully informed.
The erratic planning and assessment process of this massive project and the piecemeal release of impact statements seems to have been designed to obscure the full extent of the environmental impact of Snowy 2.0 on the KNP. In addition, lower impact less expensive alternatives have not been properly considered - claims about energy storage potential are dubious and the excessive cost will ultimately be paid for by the Australian taxpayer.
These failures clearly demonstrate that the Snowy 2.0 project does not meet the requirements of an Environmentally Sustainable Development and should be rejected by the Minister for Planning.

Kosciuszko National Park is one of the most loved and frequently visited Parks in Australia. I have visited the Park many times in both summer and winter and I am always struck by the beauty and uniqueness of the landscape which is like nowhere else in Australia. I and others like me will be put off visiting KNP in the future if Snowy 2.0 goes ahead due to the visual blight of a massive civil engineering project and associated infrastructure on the pristine montane landscape, from vantage points over thousands of square kilometres. The ‘project area’ described in the EIS is 250,000 ha, one third of Kosciuszko National Park and the proportion of the landscape actually destroyed is seriously underestimated as when vegetation clearance, earthworks, dumping and damage to streams and water-dependant ecosystems are taken into account will exceed 10,000 ha. Major infrastructure, including the widening and construction of 100 km of roads and tracks as well as two side-by-side high voltage transmission lines with a 120m wide easement swathe are proposed, some of which will destroy sensitive environmental and geologically 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 warming. 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. On this basis alone, the project should be rejected.
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.
Despite the Environmental Planning and Assessment Regulation 2000 requiring "an analysis of any feasible alternatives to the carrying out of the development activity or infrastructure", no such analysis has been done. Given the amount of environmental destruction proposed within a National Park, this project must be put on hold until this information can be provided.
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. Even if this statement were true, it by no means justifies the destruction of a pristine mountainous National Park, especially when there has been no attempt to identify credible alternatives which would be more effective and less destructive, both within and outside the 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. Apart from the catastrophic effect on the environment of the Kosciuszko National Park it would have, the project is already costing 4 or 5 times more than in the original plan and would ultimately be a remarkably inefficient generator of electricity. Snowy 2.0 fails no matter how you look at it and it should be soundly rejected.
Yours sincerely
Rachel Cassidy

I am pleased to finally be able to make a submission as provided for in NSW Planning law. It is disgraceful that this project has proceeded so far before the EIS was exhibited and submissions were sought. The NSW Government should not let the haste of the Commonwealth Government to proceed with the proposal, get in the way of proper careful consideration of any of the many planning issues or deter the NSW Government from refusing planning consent.
I object to the Snowy 2.0 project because:
1. The environmental impacts of this scheme are unacceptable and outweigh any social or economic benefits. The location where the scheme is proposed is a National Park for good reason - it is a sensitive and very special environment. It has already been compromised by the original Snowy Scheme. The extensive clearing will cause permanent damage. Revegetation of some disturbed areas will only involve partial repair. Alterations to the hydrology and groundwater of the local area will adversely affect ecosystems beyond the cleared areas. Roads and vehicle movements will also have wider adverse effects on wildlife. It is not possible to "offset" the horrendous environmental impacts.
2. I do not believe it is a cost-effective way to improve the reliability or availability of electrical power. While I appreciate that pumped storage in the best locations can contribute to reliability and availability, the proponents have failed to justify their proposal. There are many other pumped storage sites in south-east Australia - some marginal, some very good in various ways. Many alternative combinations of these could produce similar peak supply capacity. They include sites that would have little impact on riverine ecosystems and relatively small impacts on terrestrial ecosystems or on existing social and economic values such as agricultural production. A combination of several projects in different parts of NSW could have less environmental impact and more social, economic and electricity system benefits than Snowy 2.0. The enormous cost of Snowy 2.0 has not been properly explained let alone contrasted through proper benefit-cost analysis with such a multi-project alternative. Nor has it been demonstrated that such a large, publicly subsidised scheme will be needed. Our needs could be met from a combination of smaller schemes, batteries, extra renewable generation from a diversity of sources and locations, and significant enticements to limit electrical demand management. The EIS fails to justify that Snowy 2.0 even in economic and electrical system terms.
3. Construction and operation of the scheme will have adverse effects on river management. Management of the Murray system is already complex due to multiple objectives. Meeting the needs of ecosystems as well as the wishes of irrigators and other extractive users is already made difficult by the sometimes-competing wishes in relation to power generation. The desire to operate storages to manage availability of storage space and water to be in the best locations for generation at times of peak demand will sometimes be at the expense of ecosystems and other water users.
4. Snowy 2.0 will have adverse global heating effects. The fossil fuels used to construct it including producing the materials used and the heat released from chemical energy in concrete will directly warm the planet. It will be a massive net consumer of electrical energy which initially will be supplied from burning fossil fuels so the mining and burning of that additional amount of fossil fuel will heat the planet and add to the greenhouse effect. Demand management has no such impacts. Puting half as much money into a combination of alternatives, including demand management, would enable our society to achieve al that is reasonably necessary for our electricity supply system with far less greenhouse gas contributions.
5. Snowy 2.0 is not ecologically sustainable development. Approving it would not be consistent with or achieve and of the objects of the Environmental Planning and Assessment Act. I request that the Minister refuse consent.

Please do no close Tantangara Road - we want access to Wares Yards, to Currango Homestead and to Old Camp Site. Members of our club regularly stay and/or ride around these areas. These areas are the ultimate for horse riding, please do not deny us this experience especially as horse riding areas are continually being reduced.

I am a resident of Adaminaby NSW, the closest town to the Snowy 2.0 project and wish to raise some concerns with regard to the limited access to the Northern end of the National Park. Adaminaby survives on seasonal visitors to the area in all seasons as a ski town, but also as a fishing destination and also as a destination for horse riders, hikers, mountain bike riders and others. I am aware that Tantangra Road will be closed and as a result both Tantangra Dam and the many creeks and river will no longer be accessible nor will Currango, Wares Yards and Old Snowy Camp as horse camps. This will have a significant impact on both the social, cultural and economic viability of Adaminaby and surrounding areas. The local shops all stock fishing gear and trade will be significantly reduced. A number of commercial horse riding businesses will no longer be able to operate. These businesses employ local people who have been in their respective jobs for years. My family have a cultural history in the Northern end of the National Park, as my ancestors had leases in that country back when cattle and sheep were grazed during the warmer months. I now take my children (7th generation here) up there on horseback and reflect on the challenges our deceased relatives faced on a daily basis and the country they enjoyed in an era now passed.
The closure of Tantangra Road is completely unnecessary and will have a devastating effect on the entire area. I am aware of that heavy vehicles are intended to be used throughout the construction of the Snowy 2.0 project. As a retired police officer with 10yrs experience and a heavy vehicle operator I see no unmanageable risk in the road remaining open and access not being restricted.
Very little is known about this project and I think some further consultation and information should be provided. I'm sure that some common ground can be found where everyone is satisfied with the result.
The impact of restricting access will be wide spread and where the project is supported, this should not be at the expense of a community that has struggled to prosper since the snowy scheme started. We often see local projects postponed and Government funds being redirected away from Adaminaby to Jindabyne. The town has already been moved to its current location, away from Lake Eucumbene, where it should have been located on the foreshore of the lake as Jindabyne is. Adaminaby needs support, not limitations placed on the access to a major tourism draw card and access to places we have had access to for generations. 7 years (likely longer) is a long time for our area to suffer when it isn't necessary.
I respectively request that access remain open so our town and community can continue to enjoy the prosperity we currently are.

On a side note, we are a rural community with an ageing population and a lot of people are not IT savvy enough to provide a submission online so this process will not provide a true reflection of the community's general views and concerns.

See attached submission PDF document.

The area of the proposed works is very important to recreational users and it would therefore be very much appreciated if access for such users to Tantangara Road, Wares Yards, Currango Homestead and the Old Camp site were retained.

Please find attached my written submission expressing my strong opposition and concerns to the Snowy 2.0 project as outlined in the Main Works Environmental Impact Statement (EIS).

A submission is attached.

I wish to indicate my strong opposition to the Snowy 2.0 project as described in the Main Works Environmental Impact Statement (EIS).

I realize that work has already been done, and that contracts have already been signed, and that it seems a “done deal”.
However, when a project of this size clearly will cause such permanent and disastrous damage within a National Park, we must and can call a halt before it is too late. The size and scale of this project within a sensitive area should not proceed if we want to maintain and protect our bio-diversity and future proof the livability for us all.
I am no scientist, and lack the detail to make my own considered expertise, but I am very concerned with human causes to the continued destruction to our environment, causing significant loss of bio-diversity, and ultimately our own well-being.
I am always surprised how many roofs in our big cities still have no solar panels. We have some on our small city terrace, with a battery, and have more than enough to power all our needs, for no cost, after installation. And we feed into the grid, even though we are paid a pittance for doing so. If the government would incentivise installing solar panels on all existing roofs, and make it mandatory for all new homes and offices/factories to install maximum possible panels, then we would not need to degregate our valuable environment so, and it would be far more economic too.
Also, our worshiping the god of “expansion” needs careful looking at. That is clearly not possible forever, so let us work out a way to make our economy work without adding more population and the consequent need for more power.
I am all for using only renewable, but a more clever way, rather than trashing our environment. Certainly leave all fossil fuels in the ground. However, I digress….

The following is clearly taken directly from a submission form…I make no apologies. It says all I can possibly say much better than I could, and I fully concur.